# Are stairwell landings required to have 5' clear floor space at door?



## Yikes (Feb 24, 2021)

CBC 11A / FHA private apartment building, 4 stories, with elevator providing access to all floors.
Exit access door swings into a stairwell enclosure.  Stairwell enclosure is NOT an area of refuge, as the building is fully sprinklered (1009.3.3.2)
Landings are 4'-4" deep and meet requirements in Chapter 10 for egress width, door swing, etc.; and 1123A for interior stairways.

Builder is questioning if the landing needs to be 8" deeper, to achieve 5' deep floor clearance on the pull side approach to the stairwell door, as we typically see for doorways on accessible routes?

My initial thinking is that although the door and the stairwell is part of an "accessible means of egress" per 1009.2, the direction of travel is only supposed to be one-way, exiting out of the building.  Therefore there is no "pull side approach" (1126A.3.2.1, fig. 11A8A(a)) when you are standing in the stairwell landing.  

Am I correct?


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## redeyedfly (Feb 24, 2021)

I can't be certain of your local codes but per ANSI A117.1 stairs are not part of an Accessible Route.  Door clearance requirements are only for doors on an Accessible Route per Ch. 4.  Scoping for what must be included in the Accessible Route is local beyond ay FHADM requirements.  An Accessible Route may be part of an Accessible Means of Egress but they are not the same thing and do not have the same requirements.  An Accessible Route can't have stairs for example.


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## Yikes (Feb 25, 2021)

redeyedfly said:


> I can't be certain of your local codes but per ANSI A117.1 stairs are not part of an Accessible Route.  Door clearance requirements are only for doors on an Accessible Route per Ch. 4.  Scoping for what must be included in the Accessible Route is local beyond ay FHADM requirements.  An Accessible Route may be part of an Accessible Means of Egress but they are not the same thing and do not have the same requirements.  An Accessible Route can't have stairs for example.


Thanks, I had forgotten about that super-important distinction between an AMOE and an AR.  You are very helpful!


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## steveray (Feb 25, 2021)

Yikes said:


> My initial thinking is that although the door and the stairwell is part of an "accessible means of egress" per 1009.2, the direction of travel is only supposed to be one-way, exiting out of the building. Therefore there is no "pull side approach" (1126A.3.2.1, fig. 11A8A(a)) when you are standing in the stairwell landing.
> 
> Am I correct?


Until smoke starts filling the stairs...


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## khsmith55 (Feb 25, 2021)

Be sure to check the required with of landing for door encroachment. The door swing can not reduce the required width more than 50%. The "ole" rule of thumb I was taught was 36" (door) + 44"/2 (exit width divided by two) = 58" (round to 60"). Note this is a conservative rule of thumb, check the actual condition.
Ken


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## mark handler (Feb 26, 2021)

*1011.6 Stairway Landings*

There shall be a floor or landing at the top and bottom of each stairway. The width of landings, measured perpendicularly to the direction of travel, shall be not less than the width of stairways served. Every landing shall have a minimum depth, measured parallel to the direction of travel, equal to the width of the stairway or 48 inches (1219 mm), whichever is less. Doors opening onto a landing shall not reduce the landing to less than one-half the required width. When fully open, the door shall not project more than 7 inches (178 mm) into a landing. Where wheelchair spaces are required on the stairway landing in accordance with Section 1009.6.3, the wheelchair space shall not be located in the required width of the landing and doors shall not swing over the wheelchair spaces.


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## Yikes (Feb 26, 2021)

Thanks, Mark.  In the case of this particular building, we are sprinklered, so the Area of Refuge is not required per 1009.3.3, item #2.
In fact, on this building we have a horizontal exit on each floor, so we are not utilizing the stairwells for AMOE per 1009.3.3 item 6.


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## steveray (Feb 26, 2021)

Don't you need 2 AMOE? So the stair would have to be? Or existing building?

1009.1 Accessible means of egress required. Accessible
means of egress shall comply with this section. Accessible
spaces shall be provided with not less than one accessible
means of egress. Where more than one means of egress are
required by Section 1006.2 or 1006.3 from any accessible
space, each accessible portion of the space shall be served by
not less than two accessible means of egress.


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## redeyedfly (Feb 26, 2021)

Allow me to amend my response.  I had this question come up twice this week and finally found a solid reference.
FHADM shows doors to exit stairs as accessible doors. It references ANSI A117.1-1986 but 2009 is safe harbor also.  4.13 is now 404.  



https://imgur.com/EVWTv4v


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## Yikes (Mar 2, 2021)

steveray said:


> Don't you need 2 AMOE? So the stair would have to be? Or existing building?
> 
> 1009.1 Accessible means of egress required. Accessible
> means of egress shall comply with this section. Accessible
> ...


Steveray, yes you are right, we would need 2 AMOE, and I amend my response.  Still, the AMOE is different than "accessible route" (AR), so the door clearance provisions in ADA for an "accessible route" don't apply to AMOE.


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## redeyedfly (Mar 3, 2021)

Yikes said:


> Steveray, yes you are right, we would need 2 AMOE, and I amend my response.  Still, the AMOE is different than "accessible route" (AR), so the door clearance provisions in ADA for an "accessible route" don't apply to AMOE.


ADA doesn't apply to private apartments.  ANSI A117.1 and FHADM apply in addition to any local requirements.


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## timothy kim (Mar 5, 2022)

trying to figure out the same thing.  What's the conclusion here?  the screenshot of the FHADM suggests that the door to the exit stair needs to provide the door clearances, but Yikes seems to have concluded that stairs are not part of accessible route, so the door clearances are not required.


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## dancinbear (Mar 7, 2022)

When is an accessible means of egress not accessible? A: From upper floors of a building, almost always. (Read the definitions of accessible means of egress and accessible route). This is a perfect example of the code overusing the same term to describe different things (Another example: vent). Redeyedfly is right on with his initial comment. The code has created a mumbo-jumbo word salad by calling stairs accessible when they cannot be part of an accessible route per ANSI 402.2. They should have called stairs used for such purpose "Assisted means of egress" or some such, anything but super-confusing "accessible".


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## Yikes (Mar 7, 2022)

The other thing to remember is that even when a door must be "accessible" per ADA 404, the required clearances are only on the "approach" side of a door.  IF (and this is a big ‘if’) a stair is "exit-only", not intended for entering into the upper floor, then in the illustration in FHADM manual the "exit stair" (notice they didn’t call it an "entrance stair") door only needs to have the hallway/exit side with the door clearances.


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## Paul Sweet (Mar 7, 2022)

The only time I could see the need for maneuvering space inside a stair is if an area of refuge (or rescue assistance) is inside the stairs at the landing.  The area of refuge will probably provide the necessary clearance to exit the stairway once the fire is out or the drill is over.


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## steveray (Mar 7, 2022)

Yep...no reason to ever enable someone to let themselves out of a stair....Especially when the smoke start coming up....


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## Yikes (Mar 7, 2022)

timothy kim said:


> Yikes seems to have concluded that stairs are not part of accessible route, so the door clearances are not required.


What I am saying is that there is a requirement for at least one "accessible route" (AR) to get INTO the building and into the room, and that route might be the stairs, or could be something other than the stairs; it could be the elevator.  In that instance the stairs would not need to be the AR.
I am also saying there is a requirement for an "accessible means of egress" (AMOR).  The AMOR might include the stair, or it might not, depending on how you design the building.


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## ADAguy (Mar 10, 2022)

redeyedfly said:


> I can't be certain of your local codes but per ANSI A117.1 stairs are not part of an Accessible Route.  Door clearance requirements are only for doors on an Accessible Route per Ch. 4.  Scoping for what must be included in the Accessible Route is local beyond ay FHADM requirements.  An Accessible Route may be part of an Accessible Means of Egress but they are not the same thing and do not have the same requirements.  An Accessible Route can't have stairs for example.


Bad practice to not provide it.


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## Access Specialist (Mar 18, 2022)

This is actually a debated topic in the accessibility consulting community. Like ADAguy says, it's best practice to provide it but you're looking if it's required or not. 

Here is how I justify my answers. We know stairs are not part of an Accessible Route but sometimes they are part of the Accessible Means of Egress (MoE). This depends on your code study but typically if 2 stairs and an elevator are provided then 2 Accessible MoE are required and typically the designer will want the elevator to be one of two. So one stair will need to be part of your Accessible MoE. Whichever stair that is now makes the stair core an accessible space. Accessible spaces require door maneuvering clearances.


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## dancinbear (Mar 24, 2022)

For those of you with 2018 IBC Commentary, I strongly advise you to read Section 1009, way way too much to provide in full. Here are some snippets:

1009.1 "accessible means of egress are to be provided for occupants who have gained access into the building but are incapable of independently utilizing the typical means of egress facilities, such as the exit stairways"

"utilization of the exit and exit discharge may require assistance. This assistance is typically provided by the fire department"

1009.3 "Stairways (exit or exit access) between floor levels, while not part of an accessible route, can serve as part of the accessible means of egress where they are used as part of an assisted evacuation route"

1009.3.2 "The dimension of 48 inches in clear width between handrails is sufficient to enable two persons to carry a person in a basket carry or fireman's carry"

"With the sprinkler system in place, there is more opportunity for the fire department to bring in evacuation chairs or possibly bring people to the elevator for evacuation, thus the extra width for carrying someone down the stairway is not needed"

So, IMO, it is pretty clear the code intends people who use a wheelchair, who would otherwise need the clearance provided by a 5 ft. turning circle to maneuver through the door, to be *CARRIED *out of the building. The stair core, IMO, is clearly NOT an "accessible space", as Access Specialist claims, because it is not part of an accessible route and you are being assisted out by firefighters through that space.


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## redeyedfly (Mar 30, 2022)

dancinbear said:


> For those of you with 2018 IBC Commentary, I strongly advise you to read Section 1009, way way too much to provide in full. Here are some snippets:
> 
> 1009.1 "accessible means of egress are to be provided for occupants who have gained access into the building but are incapable of independently utilizing the typical means of egress facilities, such as the exit stairways"
> 
> ...


It's an FHA requirement, not IBC.  See p. 3.2 FHADM.  AMOE is a separate issue from FHA.

The turning circle is not required but door maneuvering clearances are.  There are many more people with mobility issues than just those in wheelchairs.


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## mtp (Jan 6, 2023)

It looks like the 2022 CBC has cleared up the question regarding accessible clearances at stairwell doors. 

Sec. 11B-207.1: Means of egress shall comply with Sec. 1009 & 11B-207

- except. 4: Doors that provide access only to interior or exterior stairways shall not be required to comply with Sec. 11B-404


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## redeyedfly (Tuesday at 4:18 PM)

mtp said:


> It looks like the 2022 CBC has cleared up the question regarding accessible clearances at stairwell doors.
> 
> Sec. 11B-207.1: Means of egress shall comply with Sec. 1009 & 11B-207
> 
> - except. 4: Doors that provide access only to interior or exterior stairways shall not be required to comply with Sec. 11B-404


That won't help you with FHA.


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## mark handler (Wednesday at 11:01 AM)

mtp said:


> It looks like the 2022 CBC has cleared up the question regarding accessible clearances at stairwell doors.
> 
> Sec. 11B-207.1: Means of egress shall comply with Sec. 1009 & 11B-207
> 
> - except. 4: Doors that provide access only to interior or exterior stairways shall not be required to comply with Sec. 11B-404


Looks like they are trying to keep chair users away from the stairs.


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## redeyedfly (Wednesday at 11:08 AM)

mark handler said:


> Looks like they are trying to keep chair users away from the stairs.


Door maneuvering clearances are not for wheelchairs only.  There are many other mobility impairments that requre the space.


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