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mahrelizabeth

Registered User
Joined
Feb 7, 2024
Messages
3
Location
Cedar Rapids, Iowa
Hi there - first time posting, working with IBC 2021

I have a historic building in the city limits that we are turning into apartments. There are two units that are currently situated on the interior of the building with no access to windows. According to section 1031, it doesn't look like I need EEROs in this R-2 occupancy because I only have three stories with two sets of stairs on each floor. Even if I do need them, I have the ability to put a door in each bedroom that leads to a corridor so the unit would have a second means of egress but would still have no daylighting/ventilation. Is this allowed? Thanks!
 
Unfortunately, yes.

Section 1202.1 allows either natural or mechanical ventilation, and Section 1204.1 allows either natural or artificial light in a space intended for human occupancy. Thus, windows are not required for either natural light or ventilation.

However, a proposal in the current code development cycle intends to correct this for sleeping units and for sleeping rooms and living spaces within dwelling units.
 
Thanks for the response! I also think windows should be required and am trying to minimize the number of units this affects as much as possible but there are a couple wonky spaces that just aren't feasible.
 
Unfortunately, yes.

Section 1202.1 allows either natural or mechanical ventilation, and Section 1204.1 allows either natural or artificial light in a space intended for human occupancy. Thus, windows are not required for either natural light or ventilation.

However, a proposal in the current code development cycle intends to correct this for sleeping units and for sleeping rooms and living spaces within dwelling units.
Thanks for the response! I also think windows should be required and am trying to minimize the number of units this affects as much as possible but there are a couple wonky spaces that just aren't feasible.
 
EEROs are required in each sleeping room. IBC 1031.2:

1031.2 Where required. In addition to the means of egress
required by this chapter, emergency escape and rescue openings
shall be provided in the following occupancies:

1. Group R-2 occupancies located in stories with only one
exit or access to only one exit as permitted by Tables
1006.3.4(1) and 1006.3.4(2).
2. Group R-3 and R-4 occupancies.

Basements and sleeping rooms below the fourth story above
grade plane shall have not fewer than one emergency escape
and rescue opening in accordance with this section. Where
basements contain one or more sleeping rooms, an emergency
escape and rescue opening shall be required in each sleeping
room, but shall not be required in adjoining areas of the basement.
Such openings shall open directly into a public way or to
a yard or court that opens to a public way.

The Commentary adds this:

Emergency escape and rescue openings (EERO) are
required in single-exit Group R-2 apartment and congregate
residence buildings and all Group R-3 and R-4
dwellings where occupants may be sleeping during a
potential fire buildup. Group R-2 apartment buildings
permitted to have a single exit from a story are
required to have EERO by Table 1006.3.4(1), Note a.
Group R-2 congregate residences permitted to have a
single exit are required to have an EERO by Table
1006.3.4(2), Note a.
All basements and each bedroom/sleeping room are
to be provided with an exterior window or door that
meets the minimum size requirements and is operable
for emergency escape by methods that are obvious
and clearly understood by all users.
Sleeping rooms
four stories or more above grade are not required to be
so equipped, since fire service access at that height,
as well as escape through such an opening, may not
be practical or reliable. Since single-exit apartment
buildings are limited to three stories and most Group
R-3 and R-4 buildings are two or three stories, this limit
is not applicable very often. Section 1019.3, Item 2,
limits Groups R-3 and R-4 to four stories where using
a single open exit access stairway.
The provision for basements is in recognition that
they typically have only a single means of egress without
alternative routes through standard windows.
Many times a basement is finished at a later time;
therefore, as a safety precaution, at least one EERO is
required in every basement. If bedrooms are provided
within the basement, the location and number of
EERO are determined by the bedrooms.
It is important to note that this window is only an element
of escape and is not part of the means of egress
required from the story unless it is a door conforming
to normal egress requirements.
Exceptions 1 and 3 are intended to exempt basements
that would not likely be finished as living space
since this lessens the chance of such spaces having
sleeping rooms.
The intent of Exception 2 is to permit sleeping rooms
with a door that has direct access to an exterior-type
environment, such as a street or exit balcony, to not
have an EERO. With Section 1031.4 allowing doors to
serve as EEROs, this exception is redundant. The
open atmosphere of the escape route would increase
the likelihood that the means of egress would be available
even with the delayed response time for sleeping
residents. This would also exempt walk-out basements
that did not include bedrooms.
Exception 4 is in recognition that homeowners or
apartment building designers may want a tornado
shelter in their basement. ICC 500 allows for shelters
to serve other purposes, so a storm shelter could also
be a bedroom or other room in a basement. Since
openings in storm shelters must meet very strict wind
and debris requirements in ICC 500, EEROs are not
required for this important safety feature.
Exception 5 is applicable in buildings sprinklered
throughout with an NFPA 13, 13R or 13D system. In
Group R-2, if there are two, three or four units in the
basement, this exception is considered for each unit
separately. In recognition of this addition protection,
each bedroom in a basement is not required to have
an EERO if the basement as a whole has one exit
stairway/exterior door and one EERO or the occupants
have access to either two exit stairways and/or doors.
The overall effect is that in a sprinklered dwelling unit,
an EERO can be anywhere in the basement instead of
within the bedroom.
 
EEROs are required in each sleeping room. IBC 1031.2:



The Commentary adds this:
From what the OP indicated, I do not believe that they meet the following condition (1031.2 #1):

1. Group R-2 occupancies located in stories with only one exit or access to only one exit as permitted by Tables 1006.3.4(1) and 1006.3.4(2).
Thus, as a Group R-2 with two exits, EERO is not required.
 
IMHO it makes NO sense to construe the EERO requirements for R-2 to NOT apply to the 3-story apartment building when EVERY bedroom in a one-story single family residence has to have an EERO even if the house has four exterior doors. You can't stop reading when you get to condition #1. The paragraph that follows the numbered condition is part of IBC 1031.2

Basements and sleeping rooms below the fourth story above
grade plane shall have not fewer than one emergency escape
and rescue opening in accordance with this section. Where
basements contain one or more sleeping rooms, an emergency
escape and rescue opening shall be required in each sleeping
room, but shall not be required in adjoining areas of the basement.
Such openings shall open directly into a public way or to
a yard or court that opens to a public way.
 
IMHO it makes NO sense to construe the EERO requirements for R-2 to NOT apply to the 3-story apartment building when EVERY bedroom in a one-story single family residence has to have an EERO even if the house has four exterior doors. You can't stop reading when you get to condition #1. The paragraph that follows the numbered condition is part of IBC 1031.2
The first sentence, with the two numerated conditions set the scope. The following paragraph only applies if the scoping is met.
 
It states in the paragraph quoted "...in accordance with this section." That section states it is required when "only one exit or access to one exit" per Tables 1006.3.4(1) and (2). This has been supported by multiple building officials and even ICC.

From the Commentary:

Emergency escape and rescue openings (EERO) are required in single-exit Group R-2 apartment and congregate residence buildings and all Group R-3 and R-4 dwellings where occupants may be sleeping during a potential fire buildup. Group R-2 apartment buildings permitted to have a single exit from a story are required to have EERO by Table 1006.3.4(1), Note a. Group R-2 congregate residences permitted to have a single exit are required to have an EERO by Table 1006.3.4(2), Note a.
 
Are you using the change of use and historical chapters in the IEBC? Also, what level of alterations? or you using the Prescriptive Compliance? EERO's may not be required depending on what you use.
 
Last edited:
It states in the paragraph quoted "...in accordance with this section." That section states it is required when "only one exit or access to one exit" per Tables 1006.3.4(1) and (2). This has been supported by multiple building officials and even ICC.

From the Commentary:

Okay -- I am persuaded.
 
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