# CBC 1030 EERO and NFPA 1932 ladder inclination - is it incorporated by reference in IFC / CFC?



## Yikes (Jan 14, 2022)

Question:
If a municipal fire department is enforcing NFPA 1932 during plan check, doesn't it have to be either formally adopted in the state code or in the local municipal codes?  I couldn't find it it the local adoptions, nor in the California Fire Code, nor in the California Referenced Standards Code.

Background:
I have a municipal fire department in California that, during title 19 Fire Dept Plan check, is requiring at least a 2' larger side yard than the minimum 5' required by either the building code, fire code or zoning code for a 3 story apartment building.  Their logic is this:

CBC 1030 again requires Emergency Escape and Rescue Openings for sleeping rooms.
The word "Rescue" _implies_ the fire department will be provided space for ladder access.
NFPA 1932 "Standard on Use Maintenance and Service Testing of In-Service Fire Department Ground Ladders", section 5.1.7 "Angle of Inclination" says the _optimum_ combination of load carrying capacity and stability works out to a maximum 76 degrees angle of inclination, 75.5 degrees preferred.
For a 3rd story window sill that is 21.5' above the ground, the tangent of 76 (4.01) works out to about 5.36 feet, plus ladder frame thickness, plus I need space for my 8" property line block wall = nearly 7' side yard instead of 5' side yard.
On tight infill sites, this requirement (which seems more performance based instead of prescriptive) can be very problematic after CDs have already been completed.

Here's the NFPA 1932 excerpt that I found online:


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## steveray (Jan 14, 2022)

Yikes said:


> *recommends* a maximum 76 degrees angle of inclination,


Well there you go....


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## Yikes (Jan 14, 2022)

steveray said:


> Well there you go....


Sorry, I used the imprecise term "recommended", and I've since edited my post and added an excerpt of the actual wording.


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## steveray (Jan 14, 2022)

Again....5.1.8.1 and 2 imply that angle less than 70 are allowable...


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## mtlogcabin (Jan 14, 2022)

Yikes said:


> If a municipal fire department is enforcing NFPA 1932 during plan check, doesn't it have to be either formally adopted in the state code or in the local municipal codes?


Yes
1932 is not a standard to require setbacks it is instructing fire personnel how to properly use and maintain the equipment. In others don't use the ladder under certain conditions


NFPA 1932​ 
Standard on Use, Maintenance, and Service Testing of In-Service Fire Department Ground Ladders​This standard specifies requirements for the *use, maintenance, inspection, *and service testing of fire department ground ladders in order to provide safety for fire fighters and victims during the use of those ground ladders.


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## Joe.B (Jan 14, 2022)

Yikes said:


> Question:
> If a municipal fire department is enforcing NFPA 1932 during plan check,* doesn't it have to be either formally adopted in the state code or in the local municipal codes?*  I couldn't find it it the local adoptions, nor in the California Fire Code, nor in the California Referenced Standards Code.


I believe you are 100% correct. If the FD wants to enforce something on a plan review they need to be referencing adopted codes.


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## Yikes (Jan 14, 2022)

steveray said:


> Again....5.1.8.1 and 2 imply that angle less than 70 are allowable...


And going in the other (steeper) direction, per 5.1.7.2,  the phrase "An angle of inclination between 70 and 76 degrees shall be permitted" does NOT expressly prohibit other angles, either higher or lower.
Otherwise , if they intended it to be exclusionary, they would have said "the angle of inclination of the ladder shall be 70 degrees minimum and 76 degrees maximum".


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## my250r11 (Jan 18, 2022)

It May be in the AHJ's Zoning code.


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## Yikes (Jan 26, 2022)

Update:  it would appear that the fire official is using the following terminology in the California Fire Code to subjectively determine that they can ask for more space for ground ladders:
CFC 504.1 states:  
_An approved access walkway leading from fire apparatus access roads to exterior openings shall be provided where required by the fire code official._
CFC 202 definition of "approved": *[A] *_APPROVED. Acceptable to the fire code official._

504.1 mentions only a walkway, and does not mention ground ladder space.  However, the next sentence in CFC 504.1 states:
_“Exterior doors and openings required by this code or the California Building Code shall be maintained readily accessible for emergency access by the fire department.”_
CFC 202 definition “ready access” as: *[M] *_READY ACCESS (TO). That which enables a device, appliance or equipment to be directly reached, without requiring the removal or movement of any panel, door or similar obstruction [see "Access (to)"]._

So, it appears the fire official is using the subjective definition of "approved access walkway" along with the inference that an EERO is a "device" for which there must be "ready access".
In 2018, our state fire marshal issued this interpretation:


			https://osfm.fire.ca.gov/media/8132/18-005-bonnie_terra_emergency_escape_group_r_12-03-18_final.pdf
		





This still does not prescribe a minimum ladder angle.  It does seem to open the possibility to subjective interpretation on the part of the fire official regarding what constitutes an approved access walkway.


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## steveray (Jan 26, 2022)

Ready access by NFPA typically precludes the use of ladders as it is not directly reached...NFPA 70 for example....The EERO/ ground ladder thing is interesting, no "lower roofs" under EERO's that means....


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## Yikes (Jan 26, 2022)

steveray said:


> Ready access by NFPA typically precludes the use of ladders as it is not directly reached...NFPA 70 for example....The EERO/ ground ladder thing is interesting, no "lower roofs" under EERO's that means....


Or perhaps in means that a ground ladder is used to reach the lower roof, then the firefighter stands on the lower roof (or puts another ladder on the lower roof?) to reach the upper EERO.


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## steveray (Jan 27, 2022)

Yikes said:


> Or perhaps in means that a ground ladder is used to reach the lower roof, then the firefighter stands on the lower roof (or puts another ladder on the lower roof?) to reach the upper EERO.


On a 10/12 pitch?


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## Yikes (Jan 27, 2022)

steveray said:


> On a 10/12 pitch?


I agree, it is ridiculous.
Furthermore, the way the State Fire Marshal answered the question is a one-size-fits-all approach:  All EEROs are required to be accessible USING ground ladders.

Taken literally, that means that if you have a sleeping room on the ground floor and the EERO sill is 3' above grade, you MUST use a ground ladder to reach that 3' high EERO sill.


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## steveray (Jan 28, 2022)

Soooooo....do they require the site plan to show a 75.5 degree "cone" around the house or at  least at the EERO's to make sure there is no landscaping/ retaining walls/ window wells/ accessory structures in the way....?


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## Paul Sweet (Jan 28, 2022)

This really needs to be incorporated into the local zoning code, with minimum yard width based on height above grade, if they want to enforce it.


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