# Defining a "Room" for I-4



## JenniferinHouston (Mar 6, 2020)

We are converting a quality lease house to an (I-4) nonprofit daycare for 10 children ages 6 weeks- 3 years old. The code indicates rooms where care is provided must have an exterior exit (or sprinklers).  To accommodate this the landlord is allowing us to convert a couple of the bedroom windows into doors (for example, one to be used as the crib/ sleeping room and the other as the play room with each opening to the backyard). Does anyone know if this code is interpreted so strictly that it would prevent us from even bringing the children into the dining room for lunch unless it also had an exterior door? Also, one of the bedrooms is directly next to the front door. In a fire we would surely just go out the front-- must I also add a door to that room as well? This seems extreme. The house is only 1700 sq ft and already has 4 exterior doors.


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## e hilton (Mar 6, 2020)

Do egress windows count as emergency exits?   
What is a “quality lease house”?


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## cda (Mar 6, 2020)

Welcome 

Houston you have a problem.


First if you have the doors to the outside you are an “E” occupancy



The I-4 kicks in for age and no doors to outside.

1. yes the children can wonder, it is just the room designated for the care, has to have the door.

2. No you can go through a room to get out, so the front room has to have a door directly to the outside.

3. you also have to make the great state of Texas day care inspector happy.


Is this in an incorporated city??   Or County area??


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## JenniferinHouston (Mar 6, 2020)

e hilton said:


> Do egress windows count as emergency exits?
> What is a “quality lease house”?



No windows do not count (to my knowledge).

"Quality lease house" = single family home in good condition. Not a legal term, just telling a story.


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## cda (Mar 6, 2020)

JenniferinHouston said:


> No windows do not count (to my knowledge).
> 
> "Quality lease house" = single family home in good condition. Not a legal term, just telling a story.




You are correct, Windows do not count.


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## JenniferinHouston (Mar 6, 2020)

cda said:


> Welcome
> 
> Houston you have a problem.
> 
> ...


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## JenniferinHouston (Mar 6, 2020)

I want to make sure I understand, CDA. Are you thinking we can't be I-4 bc we must be E (due to outside doors)?  I spoke to an architectural firm here in town (they build churches and schools) and they're the ones that told me that I-4 classification. They knew our kids ages. Do you think that might be incorrect?


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## RLGA (Mar 6, 2020)

Section 1006.2.2.4 states two exits or exit access doorways are required from "day care facitilies, rooms _or_ spaces." This does not require every day care room to have two means of egress. Your building is a _facility_, so it must provide two means of egress. If the day care was a tenant (multiple rooms) in an office building, for example, the tenant _space_ must have two means of egress. If the day care was just one _room_ in a church building, then that room would be required to have two means of egress.


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## cda (Mar 6, 2020)

You are an I-4 if

children under the age of two

and 


The room does not:::

each of these child care rooms has an _exit_ door directly to the exterior, 


*308.6 Institutional Group I-4, Day Care Facilities*

Institutional Group I-4 occupancy shall include buildings and structures occupied by more than four persons of any age who receive _custodial care _for fewer than 24 hours per day by persons other than parents or guardians, relatives by blood, marriage or adoption, and in a place other than the home of the person cared for. This group shall include, but not be limited to, the following: Adult day care Child day care


*308.6.1 Classification as Group E*

A child day care facility that provides care for more than four but not more than 100 children under the age of two, where the rooms in which the children are cared for are located on a _level of exit discharge_ serving such rooms and each of these child care rooms has an _exit_ door directly to the exterior, shall be classified as Group E. See Section 427 for special requirements for Day Care.


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## RLGA (Mar 6, 2020)

To add to my post above, the inclusion of "rooms or spaces," in my opinion, is superfluous. The IBC definition of a "facility" is "All or any portion of buildings, structures, site improvements, elements and pedestrian or vehicular routes located on a site." 

In the three examples I provided in my previous post, each day care described can be considered a _facility_ by definition. Thus, the mention of "rooms or spaces" just confuses the issue as the original post clearly illustrates.

To get even more geeky about it, the IBC tends to not use the Oxford comma (anywhere), which could also add to the confusion of interpreting the code if someone is not so grammatically inclined. If the Oxford comma was used, then the code requirement would have stated: "...facilities, rooms, or spaces." Thus, each item is clearly delineated as being optional in the series; whereas, without the additional comma (as it is currently printed), the sentence could be interpreted to read as follows: "...facilities _and_ rooms or spaces." Thus, based on this interpretation, all facilities and each room or space would be required to provide two means of egress. However, I don't think that was the intent--but it could be interpreted that way.

Don't believe me? Here's a case that was decided because of a lack of a comma: https://www.huffpost.com/entry/oxford-comma-court-case-ruling-overtime_n_58cad41ae4b0ec9d29d9dd28


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## RLGA (Mar 6, 2020)

cda said:


> You are an I-4 if
> 
> children under the age of two
> 
> ...


What code edition are you pulling this from? The reference to Section 427 is not mentioned in any IBC edition I have (which is all of them), which means it must be some local amendment.


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## cda (Mar 6, 2020)

RLGA said:


> What code edition are you pulling this from? The reference to Section 427 is not mentioned in any IBC edition I have (which is all of them), which means it must be some local amendment.




Close. 
From 2015

ok 2 1/2 or less

but door directly to outside


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## cda (Mar 6, 2020)

RLGA said:


> To add to my post above, the inclusion of "rooms or spaces," in my opinion, is superfluous. The IBC definition of a "facility" is "All or any portion of buildings, structures, site improvements, elements and pedestrian or vehicular routes located on a site."
> 
> In the three examples I provided in my previous post, each day care described can be considered a _facility_ by definition. Thus, the mention of "rooms or spaces" just confuses the issue as the original post clearly illustrates.
> 
> ...





in Texas there is a State day care regulator 

They will actually bring out the tape measure and measure each room.

From that they determine how many children can be in each room.

Plus divide them by age

Normally their occupant load is less than what we calculate.

Since I have been doing this, now in three cities, it has always been each room needs a door to the outside, to eliminate I-4. Never have been challenged


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## RLGA (Mar 6, 2020)

cda said:


> in Texas there is a State day care regulator
> 
> They will actually bring out the tape measure and measure each room.
> 
> ...


I agree, to make it a Group E, a door must open directly to the exterior. However, I don't think making it a Group E is what the OP was intending to do--I think they were planning to keep it a Group I-4. The Group E allows some minor relaxation of code requirements over the Group I-4, which is why they provide the alternative.


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## cda (Mar 6, 2020)

RLGA said:


> I agree, to make it a Group E, a door must open directly to the exterior. However, I don't think making it a Group E is what the OP was intending to do--I think they were planning to keep it a Group I-4. The Group E allows some minor relaxation of code requirements over the Group I-4, which is why they provide the alternative.




I think she is not getting good info, and wants to be an E.

If the rooms do not have doors directly to the outside, the building would require a fire sprinkler system.


I think this is unamended::


*903.2.6 Group I*

An _automatic sprinkler system _shall be provided throughout buildings with a Group I _fire area_. 

*Exceptions:* 

1. An _automatic sprinkler system _installed in accordance with Section 903.3.1.2 shall be permitted in Group I-1 Condition 1 facilities. 

2. An _automatic sprinkler system _is not required where Group I-4 day care facilities are at the _level of exit discharge _and where every room where care is provided has not fewer than one exterior _exit _door. 

3. In buildings where Group I-4 day care is provided on levels other than the _ level of exit discharge_, an _automatic sprinkler system_ in accordance with Section 903.3.1.1 shall be installed on the entire floor where care is provided, all floors between the level of care and the _level of exit discharge_ and all floors below the level of exit discharge other than areas classified as an open parking garage.





I normally tell prospective day cares, locate the younger children in the rooms that already have doors to the outside.


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## RLGA (Mar 6, 2020)

I think you are right, now that I look at it from the sprinkler vs. no sprinkler perspective.


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## cda (Mar 6, 2020)

RLGA said:


> I think you are right, now that I look at it from the sprinkler vs. no sprinkler perspective.




Yea  !!!!  I can be a footnote in your next book


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## ADAguy (Mar 6, 2020)

Comes down to $ signs "again", doesn't it?


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## JenniferinHouston (Mar 6, 2020)

This is the house: 428 Middle, Houston. How can I make this thing day care facility ready where the kids can go (in a group with a teacher) in and out of every room except the kitchen?


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## JenniferinHouston (Mar 6, 2020)

My plan was to convert a window to a door in each of the tow back bedrooms, but not the front one. I hoped to make the font one a children's library. As for the one's with the (new) exterior exits  the one nearest the backyard would be our play room and the middle one our crib room. However, I'd hoped the children could still eat in the dining room for meals, etc.


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## cda (Mar 6, 2020)

JenniferinHouston said:


> My plan was to convert a window to a door in each of the tow back bedrooms, but not the front one. I hoped to make the font one a children's library. As for the one's with the (new) exterior exits  the one nearest the backyard would be our play room and the middle one our crib room. However, I'd hoped the children could still eat in the dining room for meals, etc.




As stated before the room identified, to the state, that will be used for actual day care, where the children will be the majority of the time, 2 1/2 years and younger,,,,

Shall have a door direct to the outside.

If they are in a dining room or play room or other for an hour or so, do not worry about those doors.

So cheapest route is locate the 2 1/2’s in the rooms you wish to convert the windows to doors.



How many total children are you trying to get approved for??????


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## JenniferinHouston (Mar 6, 2020)

10 total children plus 3 teachers


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## cda (Mar 6, 2020)

JenniferinHouston said:


> 10 total children plus 3 teachers




So you have three rooms dedicated as day care rooms??

Plus other rooms to support these?


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## JenniferinHouston (Mar 6, 2020)

Yes, you got it. It's a house, so the rooms are not large. We went to the house again tonight. I think my ideal is to add only ONE pair of exterior french doors on the back bedroom heading into the yard and then join the two back bedrooms so it's one large (albeit weirdly shaped) space.  The front room would be our crib room for sleeping. The pickle I'm in is there's no real way to add another exterior door to that front room. I think CPS is going to say no to that even though Its SO close the front door. I mean literally you walk out the bedroom and you're standing in front entry... Rules are rules though, so I doubt they'll bend.


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## cda (Mar 6, 2020)

JenniferinHouston said:


> Yes, you got it. It's a house, so the rooms are not large. We went to the house again tonight. I think my ideal is to add only ONE pair of exterior french doors on the back bedroom heading into the yard and then join the two back bedrooms so it's one large (albeit weirdly shaped) space.  The front room would be our crib room for sleeping. The pickle I'm in is there's no real way to add another exterior door to that front room. I think CPS is going to say no to that even though Its SO close the front door. I mean literally you walk out the bedroom and you're standing in front entry... Rules are rules though, so I doubt they'll bend.



I don’t think TDHS cares, it will be the fire marshal or building dept, that TDHS normally requires an inspection and approval from.


A route to go is ask nicely the fire marshal and building Dept to do a pre walk through, before you go to far down the road.


Sometimes seeing it in person, changed the answer. Plus they have to see it anyway.


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## JenniferinHouston (Mar 6, 2020)

Good tip. I really appreciate your help. I'll try to see if I can get them to come out and do a walk through this week.

J


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