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Where's the exit?

Yankee Chronicler

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Oct 17, 2023
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New England
Application currently under review. YMCA camp -- the application is for an addition to the office structure. The architect has drawn up a plan that basically ignores the existence of an open pavilion assembly structure that's under the same roof as the office building. Two of the exit doors from the office areas discharge into the roofed-over pavilion area. (See plan below.)

The question is, for egress from the office areas, is the "exit" the door out of the enclosed office portion of the structure, or is that still part of exit access and the "exit" is when occupants are no longer under the roof of the pavilion?

Definitions (2021 IBC):

Exit


That portion of a means of egress system between the exit access and the exit discharge or public way. Exit components include exterior exit doors at the level of exit discharge, interior exit stairways and ramps, exit passageways, exterior exit stairways and ramps and horizontal

Exit Access


That portion of a means of egress system that leads from any occupied portion of a building or structure to an exit.

Exit Discharge


That portion of a means of egress system between the termination of an exit and a public way.

Public Way


A street, alley or other parcel of land open to the outside air leading to a street, that has been deeded, dedicated or otherwise permanently appropriated to the public for public use and which has a clear width and height of not less than 10 feet (3048 mm).

Since the area under the pavilion roof is considered by the code to be occupiable building area, I'm inclined to take the approach that the space under the roof is still exit access, and the exit discharge is wherever people can step out from under the roof. What are your thought?

1751140123571.png
 
I agree, the pavilion is not open to the sky, and possible less thatn10 feet tall.

Why do they need exiting out through the pavilion as opposed to the existing exit doors ?
 
Since the area under the pavilion roof is considered by the code to be occupiable building area, I'm inclined to take the approach that the space under the roof is still exit access, and the exit discharge is wherever people can step out from under the roof. What are your thought?
In my opinion, you can be more than “inclined” - you can stand firmly on your conclusion that the pavilion is exit access. As you said, the building code defines the pavilion as building area, that is not the public way. Their architect needs to define one or more points along the perimeter of the pavilion that will be the exits with an appropriate exit discharge leading to the public way.

Since the area under the pavilion roof is considered by the code to be occupiable building area,
Maybe their architect doesn’t want the pavilion to be considered building area because then it would have an occupant load and then they’d have to provide toilet facilities?

Funny how they label the restroom “ADA toilet,” I guess they really mean to say “accessible toilet.” Assuming A117.1 applies to the project, A117.1 has the additional requirement for the vertical grab bar, looks like their plan might be showing that, hard to tell. Point is, sometimes it’s not enough to just meet the ADA requirements.

possible less thatn10 feet tall.
How does the height affect how the pavilion would be classified?
 
When I look at the occupant loads, they may be able to exit out of the other doors instead, leaving the pavilion doors as convenience rather than a mandatory MOE.

Also, without a site plan, it’s hard to tell what’s going on. As a practical matter, the two pavilion doors appear to be only 3’ away from an open-to-the-sky yard area. If the pavilion is open on the sides and has no obstacles to exiting, this may not be a big deal.
 
In my opinion, you can be more than “inclined” - you can stand firmly on your conclusion that the pavilion is exit access. As you said, the building code defines the pavilion as building area, that is not the public way. Their architect needs to define one or more points along the perimeter of the pavilion that will be the exits with an appropriate exit discharge leading to the public way.

Thank you for the confirmation

Maybe their architect doesn’t want the pavilion to be considered building area because then it would have an occupant load and then they’d have to provide toilet facilities?

I don't know if that's his logic, but fixture count is a major issue here. However, it was a major issue even without the proposed addition to the office area, so I'm not sure how hard I can push that under the IEBC.

Funny how they label the restroom “ADA toilet,” I guess they really mean to say “accessible toilet.” Assuming A117.1 applies to the project, A117.1 has the additional requirement for the vertical grab bar, looks like their plan might be showing that, hard to tell. Point is, sometimes it’s not enough to just meet the ADA requirements.

This particular architect is not the only one whose plans routinely label the toilet rooms as "ADA" even though this state has adopted A117.1 and the State has expressly told building officials that we do not enforce the ADA. "ADA" seems to have become the new shorthand for "Accessible."

How does the height affect how the pavilion would be classified?

IMHO, no. The IBC still defines building area as area under roofs.
 
When I look at the occupant loads, they may be able to exit out of the other doors instead, leaving the pavilion doors as convenience rather than a mandatory MOE.

Also, without a site plan, it’s hard to tell what’s going on. As a practical matter, the two pavilion doors appear to be only 3’ away from an open-to-the-sky yard area. If the pavilion is open on the sides and has no obstacles to exiting, this may not be a big deal.

It may not be a big deal, but that evades the question. Suppose it was one door, right in the middle of the rear wall of the office area. I'm concerned with the general question of whether a door that discharges into a roofed, occupiable area can be considered to be an exit door (which would make the path of travel under the pavilion roof exit discharge), or would such doors properly be classified as exit access, the egress travel under the pavilion roof considered to be exit access, and the exit discharge is wherever people can leave the shelter of the roof and be under open sky.

As for a site plan -- there isn't one. This architect does a lot of commercial alterations in town. I always ding him for lack of a site plan (and I cite the code sections that specifically require one), and he always cops an attitude when we ask him to just fly the mission.
 
Out here in California where the weather is mild, we have a lot of schools that have covered walkways (instead of enclosed halls) connecting one building to another. It is roof and posts only, not side walls.

Many school cafeterias will have a “lunch shelter” connected to the cafeteria via a covered walkway. I don’t know of a single time when the state architect treated the covered walkway as “exit access” for the cafeteria. (Likewise our green building code requires us to have a canopy shelter over the main entrance to a building, and most code officials treat that doorway as an exit discharge.)

I think they accept it because it is obvious that the canopy-covered space between the doors and the edge of the canopy will not be used for any purpose other than circulation.

The image in the first post does not provide enough information about how the pavilion might get used. For example, could the camp use it to put on a play, with the scenery flats against the exit wall, and the exit doors now a “backstage”? Without further info or stated restrictions, that is a possibility.

Frankly, I’m surprised anyone can submit building plans without a site plan. How do you verify allowable building size and openings relative to property line? Exit discharge to a public ROW? Zoning compliance? Accessible path of travel?
How does an inspector even know where to go on the property to inspect the construction?
The plans should be rejected as an insufficient submittal.
 
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The plans should be rejected as an insufficient submittal.

I routinely reject them. I cite the code sections that specifically require a site plan.

And the architects invariably complain to town hall that I'm being obstructionist. That may help explain why as of Tuesday (July 1, new fiscal year) I will no longer be working for my current municipality. They didn't fire me -- they eliminated my position.
 
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They advertise it as "One of our large pavilions that can accommodate 200 or more people. This pavilion features electricity, an attached walk-in refrigerator, and full sized freezer." [emphasis added]
 
If it has an occupant load (and a roof I guess), it is exit access....Can they use the 20% IEBC gimmie for bathrooms? I guess that is only COO....

They may be able to use the 20% rule -- but applying the 20% rule requires that the architect first recognize that he (or she) needs to ask to apply the 20% rule, and then that they provide some sort of cost breakdown to show that they are spending 20% of the project cost on other accessibility upgrades. I really don't understand the current crop of architects. Back when I was doing construction documents in architecture firms, we knew from the git-go that we would have to provide the breakdown, so we always had it ready to go. Today, when I ask for it, the architects are like deer in the headlights. And they repeat on EVERY project. A sane person might think that if we have asked for this information on your last five projects, we're probably going to ask for it on the sixth project. Nope -- it's always like this is totally new to them.
 
I guess this would get them on bathrooms...Weird part is that it does not say you have to correct the non-conformity, so if the office addition does not cross a threshold for the office occupancy, they do nothing...Outdoor dining and covered dining get missed a lot on fixture count..

1101.2​

An addition shall not create or extend any nonconformity in the existing building to which the addition is being made with regard to accessibility, structural strength, fire safety, means of egress or the capacity of mechanical, plumbing or electrical systems.

This is how you get the upgrade with outdoor dining....You can do several 20% increases...just not 1 20.2% one...

1009.1​

Where the occupancy of an existing building or part of an existing building is changed such that the new occupancy is subject to increased or different plumbing fixture requirements or to increased water supply requirements in accordance with the International Plumbing Code, the new occupancy shall comply with the intent of the respective International Plumbing Code provisions.

Exception:
Only where the occupant load of the story is increased by more than 20 percent, plumbing fixtures for the story shall be provided in quantities specified in the International Plumbing Code based on the increased occupant load.
 
If it has an occupant load (and a roof I guess), it is exit access....Can they use the 20% IEBC gimmie for bathrooms? I guess that is only COO....
Post #1 said the pavilion was existing, and the office is the alteration. If the existing pavilion was done under previous permit, that would’ve been the time to check for related plumbing facilities. It’s not uncommon for a camp “campus” to have central restroom facilities that serve multiple adjacent buildings.

Again, without a site plan, no one can evaluate those kind of things.
 
Post #1 said the pavilion was existing, and the office is the alteration. If the existing pavilion was done under previous permit, that would’ve been the time to check for related plumbing facilities. It’s not uncommon for a camp “campus” to have central restroom facilities that serve multiple adjacent buildings.

Again, without a site plan, no one can evaluate those kind of things.
Absolutely.....You didn't see the fine print? *All of my answers are based on insufficient information given at the time of the question and my attitude at the particular moment. They should never be misconstrued as fact.....Unless there is money involved....
 
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