# Can an exit be an emergency escape opening?



## MAarch (Mar 23, 2015)

I'm working on a house with an ususual layout. Living space is entirely on second floor. First floor (directly at grade) is a two-bay garage. Basement is a full story below grade with access from an exterior, code-compliant staircase. Basement is a single room currently used as storage.

Homeowner wants to turn the basement room into a home office. The area and ceiling height are no problem- well above the minimums. We're below the minimums for natural light and ventilation, but they have artificial lighting and mechanical ventilation that comply with the alternate requirements, so they should be good there.

The question is about the emergency escape and rescue opening. I know this is required in a basement, but it seems redundant in this case, since there's a door in the room that opens directly into the egress staircase. Can the exit double as the eero, or do we need a separate window or hatch? Adding one would be a pretty significant amount of work in this case.


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## cda (Mar 23, 2015)

Welcome

No / maybe,  would say depends on what the "opens directly into the egress staircase."" looks like

if you are in the basement, do you open a door, walk up the stairs, and outside, and not through any other part of the house??

""""The intent of Exception 6 is to permit sleeping rooms with a direct access to an exterior-type environment, such as a street or exit balcony, to not have an emergency escape window. The open atmosphere of the escape route would increase the likelihood that the means of egress be available even with the delayed response time for sleeping residents. """""

Not sure what code you are under

R310.1 Emergency escape and rescue required. Basements, habitable attics and every sleeping room shall have at least one operable emergency escape and rescue opening. Where basements contain one or more sleeping rooms, emergency egress and rescue openings shall be required in each sleeping room. Where emergency escape and rescue openings are provided they shall have a sill height of not more than 44 inches (1118 mm) above the floor. Where a door opening having a threshold below the adjacent ground elevation serves as an emergency escape and rescue opening and is provided with a bulkhead enclosure, the bulkhead enclosure shall comply with Section R310.3. The net clear opening dimensions required by this section shall be obtained by the normal operation of the emergency escape and rescue opening from the inside. Emergency escape and rescue openings with a finished sill height below the adjacent ground elevation shall be provided with a window well in accordance with Section R310.2. Emergency escape and rescue openings shall open directly into a public way, or to a yard or court that opens to a public way.


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## north star (Mar 23, 2015)

*# ~ # ~ #*



MAarch,

Welcome to The Building Codes Forum !  

Which codes & the edition are you using ?

Will this "proposed" Home Office" be capable of actually sleeping in there ?

Thanks!

*# ~ # ~ #*


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## MAarch (Mar 23, 2015)

Thanks for the responses!

I'm using the 2009 IRC with Massachusetts amendments. The office will not be used for sleeping. The door opens directly from the room to an exposed exterior stairwell that goes up one story to grade.


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## mtlogcabin (Mar 23, 2015)

> The door opens directly from the room to an exposed exterior stairwell that goes up one story to grade.


Since it is an exterior stair it should be fine and no EERO would be required from that room.

Now if in the future you divide the basement into multiple rooms you may open the question back up

 Welcome to the board


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## fatboy (Mar 23, 2015)

Welcome!

And I agree, the exterior door to the exterior star is compliant.


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## steveray (Mar 23, 2015)

While specifically amended out of the code in CT as a requirement for basements, the door to the outside would meet EERO for a bedroom if there were one down there..


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## JBI (Mar 23, 2015)

My only concern would be that it sounds as though the exterior stair is the *only* way out of the basement... if that is the case I'm not so sure I'd allow it.


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## mtlogcabin (Mar 23, 2015)

JBI said:
			
		

> My only concern would be that it sounds as though the exterior stair is the *only* way out of the basement... if that is the case I'm not so sure I'd allow it.


Why

The building code allows a basement up to 1,500 sq ft with one exit (903.2.11.1)


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## Sifu (Mar 23, 2015)

Mtlogcabin, where are you getting that exception?  The only exception I know of similar to the one you mentioned is only for the housing of mechanical equipment (2009 IRC 310.1).


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## cda (Mar 23, 2015)

R311.1 Means of egress. All dwellings shall be provided with a means of egress as provided in this section. The means of egress shall provide a continuous and unobstructed path of vertical and horizontal egress travel from all portions of the dwelling to the exterior of the dwelling at the required egress door without requiring travel through a garage.

this basement has a direct access to the outside, no other exiting is required,

a house is only required one exit


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## Sifu (Mar 23, 2015)

I agree a house requires only one exit, but doesn't 310.1 also require basements and sleeping rooms to also have an alternate emergency escape opening?  Isn't it required in case the primary exit is obstructed, just as in an opening for a bedroom?  I have never encountered or thought about this situation before.  If the situation was reversed and the primary exit was up through the house an EEO would be required in the basement in case the primary exit through the house was blocked, would the same not apply in this case or is it different because the primary leads directly to the exterior?  I don't have any other references here that might address this but it is interesting and I will look around to see if they address this.


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## cda (Mar 23, 2015)

Sifu said:
			
		

> I agree a house requires only one exit, but doesn't 310.1 also require basements and sleeping rooms to also have an alternate emergency escape opening?  Isn't it required in case the primary exit is obstructed, just as in an opening for a bedroom?  I have never encountered or thought about this situation before.  If the situation was reversed and the primary exit was up through the house an EEO would be required in the basement in case the primary exit through the house was blocked, would the same not apply in this case or is it different because the primary leads directly to the exterior?  I don't have any other references here that might address this but it is interesting and I will look around to see if they address this.


Well you need to not mix gorillas and hippos

Yes a eeo is required sometimes

Kind of the exception is a door to the outside

Other requirements aside a bedroom could be windowless if it has a door directly to the outside.

Or think of a motel 6 , a one room with door to the outside, windows do not have to open.

Yes houses I think have exiting problems especially the McMansions


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## fatboy (Mar 23, 2015)

The point is an exit that does not require going back into the dwelling, you have immediate access and egress to the exterior of the structure.


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## steveray (Mar 24, 2015)

Then you would have 2 required egress doors....as long as the basement door meets those requirements, you are good.

R311.4 Vertical egress.

Egress from habitable levels including habitable attics and basements  not provided with an egress door in accordance with Section R311.2 shall be by a ramp in accordance with Section R311.8 or a stairway in accordance with Section R311.7.


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## ICE (Mar 24, 2015)

Anyplace with just one way out bothers me.  A basement with just one way out is creepy to say the least.  I have a problem if I can't see the exit.  My house has four exit doors and a garage with three.

I suppose a hole in the ground appeals to some people but for me basements are where you go when there's tornados.....and that's pretty much it.


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## fatboy (Mar 24, 2015)

This neck of the woods, basements are very viable, usable spaces. Would I want one with only one way out? He!! no! But it is compliant. My basement has a total of nine.


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## cda (Mar 24, 2015)

ICE said:
			
		

> Anyplace with just one way out bothers me.  A basement with just one way out is creepy to say the least.  I have a problem if I can't see the exit.  My house has four exit doors and a garage with three.  I suppose a hole in the ground appeals to some people but for me basements are where you go when there's tornados.....and that's pretty much it.


leave my man cave alone::

http://lifebythebayside.com/man-cave-basement-plans/

""but for me basements are where you go when there's tornados"""      and don't call my wife a toronado


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## steveray (Mar 24, 2015)

ALOT of our old basements here have only 2 ways out...up through the kitchen or in a bag...Bad stuff....Had 2 fires last year that I am amazed the people made it out of the basements alive.


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## mtlogcabin (Mar 24, 2015)

Sifu said:
			
		

> Mtlogcabin, where are you getting that exception?  The only exception I know of similar to the one you mentioned is only for the housing of mechanical equipment (2009 IRC 310.1).


It is not an exception in the IRC. It is permitted in the IBC

A door that leads directly to the outside of a basement meets the definition/size requirements of an EERO.

Fire is not the only way to die in a basement

Kate Fleming, 41, was in her basement sound room tending to her digital recording equipment when a four-foot wall of water rushed down Dewey Place East. The water slammed her small house in Seattle's Harrison neighborhood so hard that it smashed the north foundation and filled the basement, trapping Fleming inside.

Fleming's partner, dental assistant and interior designer Charlene Strong, rushed out of the house screaming for help, neighbors said.

"She ran out screaming, 'my partner is stuck in the basement, my partner is drowning,'" saidDavid Tilford, 28, an exercise specialist who works at Valley Medial Center who lives a few houses away and rushed to help when he heard Strong's calls for help.

Tilford couldn't reach the drowning woman.

​"The basement was 100 percent full of water," he said.

Other neighbors called 9-1-1 frantically. The Seattle Fire Department arrived with scuba diving gear, but it was too late, Tilford said.

Fleming, a voice-over actress, died of apparent drowning, a tragedy that has struck her neighbors hard. Four of her friends gathered outside her small green bungalow home about 10:30 this morning.

"She was a wonderful, goodhearted soul," said Sarah Trethewey, a longtime resident of the neighborhood who is building a new house next door and had come to the scene to check her property when the tragedy struck.

The neighborhood is near an area that has had flooding problems in the past. However, a poorly constructed storm drainage system has since been upgraded, and neighbors said the street had not been flooded in years, Trethewey and others said.

A huge pile of mud and debris and a dislodged power pole have completely clogged the roadway up the hill and around the corner from Fleming's house on Dewey Place East.

Ingrid Wiengren Link, 35, another neighbor and friend of Fleming, said she was caring for her two children after her husband David Link had left for the Seahawks game when water started to rise on Dewey Place.

She was just thinking of going out to clear leaves from the drain outside her house when the water rose rapidly, quickly topping the steps that lead to her house and filling the roadway completely. The street remains clogged with mud. The power went out, then a wall of water surged past her house and into Fleming's home. Soon, Weingren Link heard Strong's screams. She scrambled to find her cell phone to call for help.

'It just poured down here. I don't know where the water came from," she said. As she waited for the fire department to arrive, she hoped for Fleming's safety.


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## Sifu (Mar 25, 2015)

From the IRC commentary (2006) "The requirement for emergency escape and rescue openings in sleeping rooms exists because a fire will usually have spread before the occupants are aware of the problem, and the normal exit channels may be blocked. The requirement for basements exists because they are so often used as sleeping rooms. For example, a fire in a mechanical room adjacent to a stair could engulf the only means of egress for the basement without the egress window or door."

So a one exit space bothers me too but I am still up in the air as to whether it is compliant.  By the above text the intent is to provide two openings in case the primary is obstructed.  On the other hand I used to build houses with bonus rooms over the garage and the inspectors would want an EERO.  I always argued the point that it wasn't required.  The basement with an opening directly to the outside is arguably more safe than the bonus room where the only exit was through the house.  And, I have no issues with the door meeting the requirements of an EERO, rather I am questioning whether it is permitted to be the ONLY opening.  Still seems to be two requirements, one for exits in 311 and one for EERO's in 310.


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## north star (Mar 25, 2015)

*( ) + ( ) = 0*

Sifu,

Did any of your Bonus Rooms have closet spaces ?

*( ) + ( ) = 1*


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## fatboy (Mar 25, 2015)

Closet spaces do not define a sleeping room, if it's identified as a "bonus room" that is what it is. We used to define it as a sleeping room when it had a closet, and clothes rod..........try backing that up with a code book..........ain't happening.


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## mtlogcabin (Mar 25, 2015)

The OP was not clear if the basement is only accessed from the exterior stairs or if there is an interior stair.

The basement as described in the OP is not a dwelling use therefore if it would be permitted under the IBC it should be allowed

It is important to understand that the IRC contains coverage for what is conventional and common in residential construction practice. While the IRC will provide all of the needed coverage for most residential construction, it might not address construction practices and systems that are atypical or rarely encountered in the industry. Sections such as R301.1.3, R301.2.1, R301.2.2, R320.1, R322.1, M1301.1, G2401.1 and P2601.1 refer to other codes either as an alternative to the provisions of the IRC or where the IRC lacks coverage for a particular type of structure, design, system, appliance or method of construction. In other words, the IRC is meant to be all inclusive for typical residential construction and it relies on other codes only where alternatives are desired or where the code lacks coverage for the uncommon aspect of residential construction. Of course, the IRC constantly evolves to address new technologies and construction practices that were once uncommon, but now common.


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## cda (Mar 25, 2015)

Sifu said:
			
		

> From the IRC commentary (2006) "The requirement for emergency escape and rescue openings in sleeping rooms exists because a fire will usually have spread before the occupants are aware of the problem, and the normal exit channels may be blocked. The requirement for basements exists because they are so often used as sleeping rooms. For example, a fire in a mechanical room adjacent to a stair could engulf the only means of egress for the basement without the egress window or door."So a one exit space bothers me too but I am still up in the air as to whether it is compliant.  By the above text the intent is to provide two openings in case the primary is obstructed.  On the other hand I used to build houses with bonus rooms over the garage and the inspectors would want an EERO.  I always argued the point that it wasn't required.  The basement with an opening directly to the outside is arguably more safe than the bonus room where the only exit was through the house.  And, I have no issues with the door meeting the requirements of an EERO, rather I am questioning whether it is permitted to be the ONLY opening.  Still seems to be two requirements, one for exits in 311 and one for EERO's in 310.


if it is one basicly one room and there is a code complaint exit directly to the outside, that is all that is needed.


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## Sifu (Mar 25, 2015)

Maybe this is a little more clear, IBC 1029.1 #6 specifically says in R occupancies a basement with an exit to the exterior does not require an additional EERO.  So if using the IBC it looks pretty clear.

My bonus rooms had closets but what defines a space is typically the plans, not what someone might use it for.  I know some AHJ's don't see it that way but that is how I do it.  I think that is why the code specifically calls out a basement as requiring an EERO, because they are making a specific prediction for a specific place that someone will end up sleeping there so they require extra protection to mitigate the "predicted" use.


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## Sifu (May 22, 2015)

Well, just found out my AHJ has amended the code for basement sleeping rooms to say that if it has a closet then it is a bedroom, amazing what I learn by happenstance.  Also getting ready to adopt the 15 code and found that they have changed the requirement for basement finish permits to not require an EEO if a sleeping room is not added.  Took me a few times reading it but apparently the only time an EEO is required is for an "addition", not for remodel???  You all read that the same way?

R310.5 Where dwelling additions occur that contain sleeping rooms, an emergency escape and rescue opening shall be provided in each new sleeping room. Where dwelling additions occur that have basements, an emergency escape and rescue opening shall be provided in the new basement.


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## cda (May 22, 2015)

I read it when you

"Create a sleeping room"

Yes I guess you could read it, if you remodel a basement nothing needed.

But is that what they meant???


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## Sifu (May 23, 2015)

I think so........

R310.6 An emergency escape and rescue opening is not required where existing basements undergo alterations or repairs.

Exception: New sleeping rooms created in an existing basement shall be provided with emergency escape and rescue openings in accordance with Section R310.1.

So unless you create a sleeping room, by whatever criteria a jurisdiction uses, a basement finish does not require the inclusion of an EEO.


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## north star (May 23, 2015)

*& ~ ~ ~*

Sifu,

Suppose a closet is installed in that finished basement area ?

Would you consider that a [ very likely ] sleeping room ?

Does the inclusion of a closet in a room \ space lend creedence

towards that room \space being used for sleeping ?........Also,

if a closet IS installed, must the closet have doors to be

considered a closet ?

*~ ~ ~ &*


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## Sifu (May 24, 2015)

My "opinion" is that generally a room is identified by the designer.  If the construction documents, whether by a licensed architect or by Joe homeowner indicate a room as a study as opposed to a bedroom then that person is now responsible for all associated requirements and the unintended consequences of not adhering to them.  But as I mentioned, my current AHJ has a written

amendment  defining a sleeping room differently, if it has a closet then it is a sleeping room.  It does not get so far into the weeds as to define the closet or address the doors.  (And I don't have any issue with that).  I think the code may be deliberately ambiguous on this.  So to answer the question: if it were up to me- if the plans call it a study it is not a sleeping room whether it has a closet or not or whether it might be used a sleeping room or not.  I don't want to enforce behavior.  But it is not up to me.  BTW, I know this is not a fair example but I just looked across my kitchen and it has a closet.


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## fatboy (May 25, 2015)

Yeah, I have a 6X10 airlock foyer with a clothes closet for my front entry...........guess that makes it a sleeping room.


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## JBI (May 26, 2015)

fatboy, 6' x 10' is not wide enough to qualify as a sleeping room... 7' minimum in each horizontal direction. LOL


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