# 2006 1028.2 Maintenance of Means of Egress



## TimNY (Aug 11, 2010)

Hi All,

I just took our code update class (based on 2006 IFC) and one change brought up was to 1028.4 which was amended to require that maintenance of the means of egress _only when the the areas served by such exits are occupied_.

I have my own thoughts on the matter, but I was hoping somebody here may have more information on the reasoning behind the change.  I know many of you are familiar with what the committees actually discussed on the matter, so hopefully I can gain some insight into the decision.

Also I was wondering if anybody could confirm this same wording exists in 2009?

Thanks!


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## mtlogcabin (Aug 11, 2010)

*Final Hearing Results*
​*Original Proposal*
​*Proponent: *Jim Budzinski, Vice-Chair, ICC/IAFC Southeast/Southwest Code Action Committee

*1027.2 Reliability. *Required exit accesses, exits or exit discharges shall be continuously maintained free from obstructions or impediments to full instant use in the case of fire or other emergency when the areas served by such exits are occupied. Security devices affecting means of egress shall be subject to approval of the fire code official.

Reason: As currently written, the two sentences of this section conflict: You cannot allow the provisions to the second sentence without violating the first. This change will clarify that it is allowable for a property owner or occupant to secure their property when it is not occupied.

Cost Impact: None

*Committee Action: Approved as Submitted*

*Public Hearing Results*
​Committee Reason: The proposal provides a needed clarification to the code and a recognition of common practice in the field. Property owners need to have the ability to secure their premises without violating the IFC. Approval will also reduce the number of instances where this section is removed from the code by adopting legislation at the state or local level at the behest of small business associations wishing to exercise reasonable control over their property, thus taking it out of the Fire Code Official's control. With this proposal, the Fire Code Official retains the approval authority over the security means.

*Assembly Action: None*

*Final Hearing Results*
​*F171-04105 AS*


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## mtlogcabin (Aug 11, 2010)

Yes the same wording exist in the 2009 IFC under Section 1030.2


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## FM William Burns (Aug 11, 2010)

Not speaking on the committee’s intent for the change and maybe Gene can chime in but I look at it as a necessary change for example:



A High School using the gymnasium and lobby area for a weekend volleyball tournament.  They have security gates in the school’s corridors off the lobby to prevent general public from entering the school area when not occupied.  The Gym and Lobby access, exits and discharge are all maintained for the area being occupied.


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## Uncle Bob (Aug 11, 2010)

Tim,

"amended to require maintenance of the means of egress _only when the the areas served by such exits are occupied_."

So they can pass the inspection; which will only be made when the area served is not occupied and therefore it will pass inspection even if a bunch of crap is blocking the exit.

Uncle Bob


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## mtlogcabin (Aug 11, 2010)

UB

Inspections are made during normal business hours so if an exit is blocked with a bunch of stuff then no it will not pass. I believe FM Example is more in line with the intent of this section.


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## TimNY (Aug 11, 2010)

Thank you for that info mtlog (btw, is there someplace I can find stuff like that?)

I really could not disagree more.  I have no problem with locking people out, but locking people in is a problem, even if it is assumed the area is not occupied.  We have a sentence saying security devices require approval.  So, I can stack my tables in front of the exit (not a security device) without approval.

Just make sure the exit sign above it is illuminated at all times, so the firefighter or the kid who fell asleep in the bathroom can crawl all the way there, curl up in a ball and die.

While I see the reasoning behind Fm's scenario, the section can be too broadly interpreted.  If everybody did the right thing, we wouldn't need half the code book.  If you watched your kids, we wouldn't need safety receptacles.  If you could actually trust people to follow plans, we wouldn't need inspections.

I see this as just rolling out the red carpet for somebody to get hurt. "Oh, well, we just opened up and hadn't had time to remove the chains from the exit doors, sorry your kids died".

If they want to secure their premises, get an alarm.  It's the cost of doing business.

Respectfully, just my opinion.

EDIT: They should change the title to "Reliability?"


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## Marshal Chris (Aug 12, 2010)

I agree with you Tim.  I took the update class yesterday, and the instructor said you can basically park a bull dozer in front of the exits, when the facility is not occupied, and you'd be code compliant.  Get something like the Arm-A-Door it's virtually the same way they are locking the rear exits, but it allows emergency egress.


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## mtlogcabin (Aug 12, 2010)

TimNY

ICC plublishes the Code Changes Resource Collection. Basically you would have to purchase a book for each individual code. Here is a link to  some of them

http://www.iccsafe.org/Store/Pages/StoreSearchResults.aspx?cat=StoreSearch&q=code%20changes%20resource%20collection


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## Mac (Aug 12, 2010)

If the MOE doesn't need to be maintained unless the space is occupied, then that's when the inspector needs to visit. Theaters, sports arenas, churches, performing arts venues, banquet halls and other high occupant load spaces would be first on my list....   Might mean some overtime!


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## TJacobs (Aug 12, 2010)

Emergency responders need to be taught that what they see during "normal business hours" will not be the same thing they see at 3 am, and they had better train for it.

Also, blocking a corridor "after hours" only works if the occupied space being occupied "after hours" was not designed to use that corridor as one of its required means of egress.  Good luck!


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## TJacobs (Aug 12, 2010)

How many line firefighters or police officers know about or train on areas of rescue or areas of refuge?  We put this stuff in the code and figure everything is fixed.  That knowledge needs to trickle down to those who need to know, and it needs to be preplanned and trained on.


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## TimNY (Aug 12, 2010)

mtlog, thank you for the link.

Obvisouly I feel very strongly about the matter.

"The proposal provides a needed clarification to the code and a recognition of common practice in the field. "  Perhaps they don't enforce the code in some parts, but I have never seen an exit obstructed or locked when the space is unoccupied and clear when occupied.  Granted my demographics may be different from other areas.  I can count on one hand the number of times a business owner has actually asked if they could lock an exit.  They don't ask because it's just common sense and assumed (rightfully so) that obstructing an exit is not permitted.  I hardly find obstructing an exit/MOE to be commonplace.

I look at it like this: is there any reason for an exit sign to be illuminated when the area is not occupied?  If the building is unoccupied why not turn off the fire alarm?

I am sure that somebody, somewhere, made a convincing argument for their situation.  I just think it is too broad.  I can't think of any business in my jurisdiction that would have any reasonable need to take advantage of the provision, but there it is for them to use.  I only see the use of this provision in my jurisdiction as a stepping stone to somebody getting hurt.

It seems out of line with all the efforts made in other parts of the code to protect people from themselves.  At the very least, make any obstruction subject to AHJ approval.


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## Mac (Aug 12, 2010)

Giant step backward.


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## mtlogcabin (Aug 12, 2010)

> and the instructor said you can basically park a bull dozer in front of the exits, when the facility is not occupied, and you'd be code compliant


I believe the problem may be the way the instructor has approached it with the example he used instead of one like FM Williams post suggest. Remember it is the security devices installed on the doors not what is piled in front that this section is talking about "Security devices affecting means of egress shall be subject to approval of the fire code official."

Look at Section 1028.3 Obstructions.

A means of egress shall be free from obstructions that would prevent its use, including the accumulation of snow and ice.

This would reiterate the fact the path of travel and doorways should be free from obstructions at all times.


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## LGreene (Aug 12, 2010)

Does this change the consensus regarding my question from a couple of weeks ago?

http://www.inspectpa.com/phpbb/showthread.php?2120-Mercantile-Egress&highlight=lgreene

It's hard enough for me to convince people that they need to provide free egress...this change could really confuse the issue.  I just posted some photos on my blog of a restaurant that locks its doors with a padlock and hasp after hours.  Let's say they only did it when the last of the staff left and the building was completely empty.  Some people might think it's acceptable per the revised language.  Here are the photos:  http://idighardware.com/2010/08/reader-photos-3/

If the building code requires free egress, and the fire code says that you only have to have free egress when the building is occupied, that means that building owners will be adding aftermarket products and rigging up their own ways of keeping the doors locked.  Given the creative applications I've seen, this is a really bad idea.  If anyone thinks that building owners are going to call the fire marshal to ask about each security device they want to add, that's not going to happen.

:-(


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## cda (Aug 12, 2010)

So I guess this provision makes the radio shacks and other businesses that have a gate across the entire front of the store legal


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## cda (Aug 12, 2010)

LG

First the ahj has to adopt the IFC edition with that provision

Second it allows the fire official to either approve or disapprove the practice

So MAYBE


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## LGreene (Aug 12, 2010)

> CDA: So I guess this provision makes the radio shacks and other businesses that have a gate across the entire front of the store legal


The IBC has language for the grilles:

_(2009 - no change from 2006) 1008.1.4.5 Security grilles. In Groups B, F, M and S, horizontal sliding or vertical security grilles are permitted at the main exit and shall be openable from the inside without the use of a key or special knowledge or effort during periods that the space is occupied. The grilles shall remain secured in the full-open position during the period of occupancy by the general public. Where two or more means of egress are required, not more than one-half of the exits or exit access doorways shall be equipped with horizontal sliding or vertical security grilles._



> CDA: First the ahj has to adopt the IFC edition with that provision.  Second it allows the fire official to either approve or disapprove the practice


I know, but it certainly muddies the waters.  I don't like mud.


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## mtlogcabin (Aug 12, 2010)

Does it make more sense if it was written this way?

Required exit accesses, exits or exit discharges shall be continuously maintained free from obstructions or impediments to full instant use in the case of fire or other emergency.

Exception:

1. Security devices affecting means of egress shall be subject to approval of the fire code official


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## FM William Burns (Aug 12, 2010)

MT,

That works for me but then again, I'm not trying to read too much into the "change" and would, as always evaluate any and all "means of egress" new, existing or questionable upon discovery and when applicable update our Pre-Incident drawings with "after occupancy" changes that still in the opinion of the code official, comply with adopted code provisions.


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## TimNY (Aug 13, 2010)

mtlogcabin said:
			
		

> I believe the problem may be the way the instructor has approached it with the example he used instead of one like FM Williams post suggest. Remember it is the security devices installed on the doors not what is piled in front that this section is talking about "Security devices affecting means of egress shall be subject to approval of the fire code official."Look at Section 1028.3 Obstructions.
> 
> A means of egress shall be free from obstructions that would prevent its use, including the accumulation of snow and ice.
> 
> This would reiterate the fact the path of travel and doorways should be free from obstructions at all times.


MT, again, I am sure there are some scenarios where it may be reasonable.  FM's may be one of them.  I just think the section is way too broad.

The section says _"__shall be continuously maintained free from obstructions__ or impediments to full instant use in the case of fire or other emergency __when the areas served by such exits are occupied__"_

based on the above, I would interpret this to mean that MOE (including exits, exit access, exit discharge) need only be maintained when the space is occupied.

Further it is stated, _"__Security devices__ affecting means of egress shall be subject to approval of the fire code official."_

I would interpret this as stating only security devices are regulated by the AHJ.  A bulldozer is not a security device.

When I put these together I arrive at:  You need only maintain any part of the MOE when the building is occupied.  You may obstruct the MOE with anything you would like, as long as I cannot reasonably determine it to be a security device.

I know I am repeating myself, but I am sure there are many valid cases where this may be warranted.  I don't believe I have any in my jurisdiction.  I also believe that this will afford less life safety protection.


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## TimNY (Aug 13, 2010)

mtlogcabin said:
			
		

> Does it make more sense if it was written this way?Required exit accesses, exits or exit discharges shall be continuously maintained free from obstructions or impediments to full instant use in the case of fire or other emergency.
> 
> Exception:
> 
> 1. Security devices affecting means of egress shall be subject to approval of the fire code official


MT, I believe that to be a much better wording.  I do not believe that is what the current section states.


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