# Windowless bedroom.



## oxfordethan

Can anyone think of a way it is permissible to have a 2nd story bedroom in an R-2 occupancy (frat house) without an exterior emergency means of egress?  The house has a sprinkler system.  I've looked at IFC 2012 1029.1.  TIA.


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## cda

Build it under the 2009 IBC

1029.1 General. In addition to the means of egress required by this chapter, provisions shall be made for emergency escape and rescue in Group R and I-1 occupancies. Basements and sleeping rooms below the fourth story above grade plane shall have at least one exterior emergency escape and rescue opening in accordance with this section. Where basements contain one or more sleeping rooms, emergency escape and rescue openings 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.

Exceptions:

1. In other than Group R-3 occupancies, buildings equipped throughout with an approved automatic sprinkler system in accordance with Section 903.3.1.1 or 903.3.1.2.


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## cda

Why are there no windows?


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## Chad Pasquini

I have approved a skylight that met the minimum opening requirements.


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## cda

Chad Pasquini said:
			
		

> I have approved a skylight that met the minimum opening requirements.


How does a person in the room reach the skylight, open it and get out ?


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## mark handler

oxfordethan said:
			
		

> Can anyone think of a way it is permissible to have a 2nd story bedroom in an R-2 occupancy (frat house) without an exterior emergency means of egress?  The house has a sprinkler system.  I've looked at IFC 2012 1029.1.  TIA.


NOT Permitable

" ...every sleeping room below the fourth story shall have at least one operable

window or door approved for emergency escape or rescue that shall open directly into a public street, public

alley, yard or exit court. The door or window shall be operable from the inside to provide a full clear opening

without the use of separate tools..."


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## oxfordethan

cda said:
			
		

> Build it under the 2009 IBC1029.1 General. In addition to the means of egress required by this chapter, provisions shall be made for emergency escape and rescue in Group R and I-1 occupancies. Basements and sleeping rooms below the fourth story above grade plane shall have at least one exterior emergency escape and rescue opening in accordance with this section. Where basements contain one or more sleeping rooms, emergency escape and rescue openings 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.
> 
> Exceptions:
> 
> 1. In other than Group R-3 occupancies, buildings equipped throughout with an approved automatic sprinkler system in accordance with Section 903.3.1.1 or 903.3.1.2.


I believe this is the 2009 IFC...  Our state has adopted 2012. It doesn't give the "sprinkler exception".


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## oxfordethan

cda said:
			
		

> Why are there no windows?


Frat wanted to add some bedrooms on the second floor of the house. They were advised to submit plans to SFM for approval even though they were informed that a windowless bedroom would not fly.  They submitted plans but never received an approval letter or stamped prints.  They decided to build it out over the summer while the house was unoccupied.  I got a call from the house wanting the number for a sprinkler company to move sprinkler heads.  I asked for what reason.  That's how I found out.


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## Chad Pasquini

Sloping ceiling cda, even met less than 44 inches above ground, lower end opened straight up and had just a 6 inch overhang. Met minimum width and height.


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## ADAguy

And so it happens, Fratties think the laws were not intended for them and then they "burn".


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## cda

Sounds like they either not use them as bedrooms or add windows.

And do you know why the plans were not approved ?


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## cballinger

Came across this when searching for another issue.  Sorry I'm late to the discussion, but thought I'd add some input as we've come across this issue a lot here recently.   Section 1029.1 only applies to Group R-2s that are using Tables 1021.2(1) or 1021.2(2) for stories with a single exit.  If they have access to 2 exits from the 2nd floor, they wouldn't require emergency escape and rescue openings in the bedrooms.  (i.e. two exits available on 1st floor, with 2 exit access stairs on 2nd floor).  Do they have 2 stairways from 2nd floor?


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## cda

cballinger said:
			
		

> Came across this when searching for another issue.  Sorry I'm late to the discussion, but thought I'd add some input as we've come across this issue a lot here recently.   Section 1029.1 only applies to Group R-2s that are using Tables 1021.2(1) or 1021.2(2) for stories with a single exit.  If they have access to 2 exits from the 2nd floor, they wouldn't require emergency escape and rescue openings in the bedrooms.  (i.e. two exits available on 1st floor, with 2 exit access stairs on 2nd floor).  Do they have 2 stairways from 2nd floor?


What year edition are you looking at


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## mtlogcabin

cda said:
			
		

> What year edition are you looking at


2012 IBC and I believe he is correct

1029.1 General.

In addition to the means of egress required by this chapter, provisions shall be made for emergency escape and rescue openings in Group R-2 occupancies in accordance with Tables 1021.2(1) and 1021.2(2)

The Tables refer to stories with one exit. Hence if you have 2 exits then the Tables are not applicable and emergency egress windows are not required.


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## oxfordethan

2012 IFC 1029.1 General.

"In addition to the means of egress required by this chapter..."

I'm confused.  1021.2(2) does not allow one exit in floors above the first floor/basement in R-2 occupancies...  The frat house in question has three remote stairwells from the second floor (3rd above grade).  Therefore, wouldn't that make this frat house "in accordance with" 1021.2(2) and therefore 1029.1 is applicable? _"Basements and sleeping rooms below the fourth story above grade plane shall have at least one __*exterior *__emergency escape and rescue opening in accordance with this section."_


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## mtlogcabin

If you have two exits from each story then Tables 1021.2(1) and (2) do not apply to an R-2 use for emergency escape and rescue opening requirements


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## oxfordethan

So, Could I have a 2 story frat house (R2) with two remote exits and all of the 2nd story sleeping rooms be windowless?


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## cda

anyone have 2012 commentary?


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## oxfordethan

cda said:
			
		

> anyone have 2012 commentary?


It's on my Christmas list.


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## oxfordethan

I believe this is 2012 IFC 1029.1 commentary.


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## RFDACM02

As an NFPA "only" inspector, what is the IBC escape window size requirement? I'm wondering how far off the Life Safety Code and the IBC are in this area?


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## rogerpa

http://publicecodes.cyberregs.com/icod/ibc/2012/icod_ibc_2012_10_sec029.htm?bu=IC-P-2012-000001&bu2=IC-P-2012-000019


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## cda

RFDACM02 said:
			
		

> As an NFPA "only" inspector, what is the IBC escape window size requirement? I'm wondering how far off the Life Safety Code and the IBC are in this area?


101 for those that want to see it

24.2.2.3.3*   It shall be an outside window or door operable from the inside without the use of tools, keys, or special effort and shall provide a clear opening of not less than 5.7 ft2 (0.53 m2). The width shall be not less than 20 in. (510 mm), and the height shall be not less than 24 in. (610 mm). The bottom of the opening shall be not more than 44 in. (1120 mm) above the floor. Such means of escape shall be acceptable where one of the following criteria is met:

(1)

The window shall be within 20 ft (6100 mm) of the finished ground level.

(2)

The window shall be directly accessible to fire department rescue apparatus as approved by the authority having jurisdiction.

(3)

The window or door shall open onto an exterior balcony.

(4)

Windows having a sill height below the adjacent finished ground level shall be provided with a window well meeting all of the following criteria:

(a)

The window well shall have horizontal dimensions that allow the window to be fully opened.

(b)

The window well shall have an accessible net clear opening of not less than 9 ft2 (0.82 m2) with a length and width of not less than 36 in. (915 mm).

©

A window well with a vertical depth of more than 44 in. (1120 mm) shall be equipped with an approved permanently affixed ladder or with steps meeting both of the following criteria:

i.

The ladder or steps shall not encroach more than 6 in. (150 mm) into the required dimensions of the window well.

ii.

The ladder or steps shall not be obstructed by the window.


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## RFDACM02

Rogerpa: Thanks for the link, that looks a lot like NFPA 101.

We use 101 extensively, not a fan of the new "interpretation" of the 24.2 section for existing windows. Basically allowing the R/O to be 5.0 if the window is wood or vinyl and the operable area meets the minimum 20x24 dimensions. They noted that larger square footage was for firefighters to get in, but that's the first piece of 101 designed for FD access, where the rest of the Code is written for occupant self-preservation (other than detainees or non-ambulatory). Not a fan of this change, I'd like to see 50% of the population try and pass through a 20x24 opening! I suppose a fire chasing you elevates motivation, but...


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## oxfordethan

UPDATE:  The Mississippi State Fire Marshal's office has allowed the fraternity to occupy and use the rooms as bedrooms "as-is" without having an EERO.

I'm waiting to for them to send me their justification.


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## cda

> UPDATE:  The Mississippi State Fire Marshal's office has allowed the fraternity to occupy and use the rooms as bedrooms "as-is" without having an EERO.  I'm waiting to for them to send me their justification.


Plus get their approval in writing from them!!!!!!


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## oxfordethan

Here's an email that the SFM forwarded to me.  This was a 3rd party reviewer asking another 3rd party.

I am going to ask the same question from several different angles because this section is very confusing and there are many ways to interpret it.  Please indulge me on this since the new section seems to confuse more that it helps. I will color the actual question different from the explanation for clarity and simplicity. Again, my apologies in advance J

*2012 IBC Section 1029 Emergency Escape and Rescue*, no longer has the exception for fully sprinklered, R-2 buildings that was present in 2009 IBC 1029.

Exception 1 to section 1029 in the 2009 IBC states that the emergency escape and rescue openings are not required in other than R-3 occupancy’s if the building is fully sprinklered.  This recognized the increased safety provided to the occupants by the sprinkler system and allowed the emergency escape and rescue openings to not be required.

On the surface we read section 1029 in the 2012 IBC without reading and fully understanding the referenced tables 1021.1(1) and 1021.1(2), and say that due to the deletion of exception 1 as it appeared in the 2009, we must now have emergency escape and rescue openings in R-2 occupancies, however…

There is no need for the 2009-1029 exception 1, because it would never not apply since all R-2 occupancies are now sprinklered.

Inversely;

If all R-2 occupancies are sprinklered then they all meet the requirements of 2009 IBC 1029 exception 1.

So other than stories with a single exit according to 2012 IBC Section 1021, emergency escape and rescue opening are no longer required in R-2 occupancies. Correct?

Is the deletion of the exceptions found in the 2009 IBC Section 1029, as it appears in the 2012 IBC 1029, a direct response to the requirement that all R-2 occupancies are now required to be sprinklered so emergency escape and rescue opening are no longer required in any R-2 building with two means of egress?

IBC 2012 section 1029 states that in addition to the 1 exit door required from an R-2 sleeping room on the first floor, we must have emergency escape and rescue opening according to 1021.

2012 IBC Section 1021, Tables 1021.1(1) and 1021.1(2) and Foot Note a, provides the criteria for stories with a single exit and foot note “a” stipulates that  Buildings classified as Group R-2 equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1 or 903.3.1.2 and provided with emergency escape and rescue openings in accordance with Section 1029 can have just one means of egress from the entire story.

This means the only time emergency escape and rescue openings are required is when the story has a single exit.

Is this a correct understanding of the section?



Finally; Is an interior sleeping unit, fully sprinklered,  with no windows, a maximum occupant load of 10 (complying with 1015.1 for a space with a single exit) with only one 36 inch door, opening  to a corridor that is constructed in compliance with 2012 IBC and the corridor has two fully compliant exits allowed.

Is a story containing 30 of the sleeping units as described in the sentence above allowed if the corridor and exits are the correct width for the occupant load served?


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## oxfordethan

here's the response...

*Subject:*          12 IBC Section 1029 Emergency Escape and Rescue

*Question 1: *

Are emergency escape and rescue openings required in R-2 occupancies, where the story has more than one exit?

*Answer 1:*

No.

Emergency escape and rescue openings are not required in R-2 occupancies where the story has more than one exit.

Emergency escape and rescue openings are required in R-2 occupancies where the story with the single exit provision of Section 1021 is used. Even though emergency escape and rescue openings do not qualify as a means of egress / exit, they do offer a 2nd way of escape during an emergency.

*Question 2:*

Is the deletion of the exceptions found in the 2009 IBC Section 1029, as it appears in the 2012 IBC 1029, a direct response to the requirement that all R-2 occupancies are now required to be sprinklered so emergency escape and rescue opening are no longer required in any R-2 building with two means of egress?

*Answer 2:*

Yes.

*Question 2:*

2012 IBC Section 1029 states that in addition to the 1 exit door required from an R-2 sleeping room on the first floor, we must have emergency escape and rescue opening according to 1021.

2012 IBC Section 1021, Tables 1021.1(1) and 1021.1(2) and footnote “a”, provides the criteria for stories with a single exit and footnote “a” stipulates that “Buildings classified as Group R-2 equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1 or 903.3.1.2 and provided with emergency escape and rescue openings in accordance with Section 1029.” can have just one means of egress from the entire story.

Therefore, the only time emergency escape and rescue openings are required is when the story has a single exit.

Is this a correct understanding of the section?

*Answer 2:*

Yes. See Answer to Question 1.

*Question 3:*

Is an interior sleeping unit, fully sprinklered,  without emergency escape and rescue openings, with a maximum occupant load of 10 (complying with 1015.1 for a space with a single exit), with only one 36 inch door, opening  into a corridor that is constructed in compliance with 2012 IBC and the corridor has two compliant exits allowed?

*Answer 3:*

Yes. See answer to Question 1.

*Question 4:*

Is a story containing 30 of the sleeping units as described in Question 3 allowed if the corridor and exits are the correct width for the occupant load served?

*Answer 4:*

Yes. See answer to Question 1.

Code opinions issued by ICC staff are based on ICC-published codes and do not include local, state or federal codes, policies or amendments. This opinion is based on the information which you have provided. We have made no independent effort to verify the accuracy of this information nor have we conducted a review beyond the scope of your question. This opinion does not imply approval of an equivalency, specific product, specific design, or specific installation and cannot be published in any form implying such approval by the International Code Council. As this opinion is only advisory, the final decision is the responsibility of the designated authority charged with the administration and enforcement of this code.


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## oxfordethan

Guys, I have a letter from SFM approving the occupation of these windowless rooms as bedrooms.  I did what I thought was right by bringing it to their attention.  Apparently, I was wrong.  I'm done with this issue.


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## cda

> Guys' date=' I have a letter from SFM approving the occupation of these windowless rooms as bedrooms.  I did what I thought was right by bringing it to their attention.  Apparently, I was wrong.  I'm done with this issue.[/quote']The good thing is you questioned it!!!!


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## oxfordethan

> The good thing is you questioned it!!!!


Ahaha!!!  Around here they would rather me sit down and shut up!


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## cda

Than is when I talk up louder.

But found out have to do it with respect


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