# All doors out of a bldg required to be code compliant exits?



## akelly (Oct 11, 2021)

So there is a minimum requirement for door count out of a space but say your building has 12 doors to the exterior (assume warehouse with several convenience doors) and only (2) are required by code for exiting.  Do you find in some jurisdictions that you are required to make all of those doors code compliant exits... with signage and access to public way/area of refuge?


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## bill1952 (Oct 11, 2021)

Yes. Usually.

It's a long time - age old - issue of does a building element that is not required have to meet the code requirements the same as if it was required.  I submitted a code change to specifically say not some 15-18 years ago.  It garnered quite a bit of discussion but was ultimately shot down.  The interesting part of that it is the only proposal I've submitted that resulted in calls and emails after the hearings in support.

My observation is if you just design it that way - non-compliance - you might get away with it.  My worst case - rails in a flat floor room for lines had to meet guard requirements for height and strength.  Reverse, a play slide from entrance foyer to children's area in lower level if a church. It is a very steep ramp with no gate or guard or curb, and would be easy to fall, especially if sight impaired.

Some jurisdictions may be more lenient but, in my experience across the country, all of doors, stairs, corridors, ramps, railings, guards, etc. usually have to meet code as if they were required.


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## e hilton (Oct 11, 2021)

But if you don’t mark the door with a lighted exit sign, or any signs … seems like you would not need full compliance.


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## bill1952 (Oct 11, 2021)

The most common response from building official/ahj is "it might be used as an exit".


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## Yikes (Oct 11, 2021)

akelly, welcome to the forum! 
It really helps is you tell us (1) where the project is located, so we know which code/jurisdiction is applicable, and (2) whether it is (a) new, (b) existing with no changes, or (c) existing with an addition or alteration proposed.

If you have a space that requires 2 exit doors but has 12 exit doors, then only 2 doors need to be made "code compliant" with the provisions IBC chapter 10 'Means Of Egress'.  You certainly would not have exit signs on the other 10 doors if you don't intend to use them for exiting.

Since this was posted in the Accessibility forum, perhaps you meant to ask, "do the other 10 convenience doors in excess of those required by CBC chapter 10 need to be made mobility accessible per CBC chapter 11B?"

Assuming it is in Sacramento or somewhere in California, CBC 11B-206.4.1 for new buildings has a couple of exceptions:




ADA is a separate but related issue that you will want to consider as well.  It will not be enforced by your city building official.
ADA Standard 206.4.1 says:



Let us know if your building is existing - - there may be a different response for existing vs. new.


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## mtlogcabin (Oct 11, 2021)

akelly said:


> Do you find in some jurisdictions that you are required to make all of those doors code compliant exits... with signage and access to public way/area of refuge?


_Not every door is intended to be code compliant as an exit door. 
Example:  A large open S-1   11,195 sq ft warehouse occupant load is only 24 but the Common Path of Travel requires 2 exits. _
[F] 903.2.9 Group S-1.
An automatic sprinkler system shall be provided throughout all buildings containing a Group S-1 occupancy where one of the following conditions exists:
_Less than 12,000 sq ft so no fire suppression required and none of the other conditions exist._

_However Section 903.2.11.1 now has to be met_

[F] 903.2.11.1 Stories without openings.
An automatic sprinkler system shall be installed throughout all stories, including basements, of all buildings where the floor area exceeds 1,500 square feet (139.4 m2) and where the story does not comply with the following criteria for exterior wall openings:

2.    Openings entirely above the adjoining ground level *totaling not less than 20 square feet (1.86 m2) in each 50 linear feet* (15 240 mm), or fraction thereof, of exterior wall in the story on not fewer than one side. The required openings shall be distributed such that the lineal distance between adjacent openings does not exceed 50 feet (15 240 mm). The height of the bottom of the clear opening shall not exceed 44 inches (1118 mm) measured from the floor.

[F] 903.2.11.1.1 Opening dimensions and access.
*Openings shall have a minimum dimension of not less than 30 inches* (762 mm). Access to such openings shall be provided for the fire department from the exterior and shall not be obstructed in a manner such that fire fighting or rescue cannot be accomplished from the exterior.

_Those minimum required dimensions make a 3.0 door the easiest and least expensive way to comply with 903.2.11.1.1. No they are not designed as exit doors and do not have to meet all the requirements of an exit door. _


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## tmurray (Oct 12, 2021)

My take on this:

If the door is required to be an exit for some reason under the code, it must meet all the requirements for an exit door. 
If the door is signed as an exit, even if it is not required by code, it has to function like an exit (occupants cannot be expected to spot a "fake" signed exit). 
If it is what most people call a convenience door and is not signed as an exit, I don't care what you do with it, provided it does not violate other code provisions.


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## bill1952 (Oct 12, 2021)

tmurray said:


> If it is what most people call a convenience door and is not signed as an exit, I don't care what you do with it, provided it does not violate other code provisions.


So it could be exact same model door as the required two with signs over them, and could have a dead bolt not operable without a key so no egress possible?


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## e hilton (Oct 12, 2021)

Put a sign on the door “not an exit”.


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## steveray (Oct 12, 2021)

TM has the best synopsis.....No AHJ should be making you do what the code does not....The "Not an exit" is a good idea.....


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## Pcinspector1 (Oct 12, 2021)

I see a situation where a building is built as a shell building with front and back exit door with purposed tenant remodeling that include separation walls. You may see it set up with 6-8 units and a tenant takes two spaces that would have four exit doors. Not all the doors would need to be treated as exit doors with exit signage but still could be used as egress doors. There's an IBC 1013 exception 2, in the code that sez an obvious entrance does not require an exit sign if approved by the BO.


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## Pcinspector1 (Oct 12, 2021)

e hilton said:


> Put a sign on the door “not an exit”.


I could see that only if that was a true statement, If its actually an exit to the outside I might try it during an emergency situation?


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## Pcinspector1 (Oct 12, 2021)

Addition to post #11, *Exception #2 MAIN exterior exit door**s*


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## tmurray (Oct 12, 2021)

bill1952 said:


> So it could be exact same model door as the required two with signs over them, and could have a dead bolt not operable without a key so no egress possible?


Yup. It might as well be a wall for all I care. 

This might be different in your codes, but our code regulates an "exit". An "exit" is a very specific thing under the code. Anything not meeting the definition of an exit, cannot be regulated as one. The only fly in the ointment on this is if someone signs a door that is not an exit as an exit. In that case, I would be comfortable requiring it to meet the provisions of an exit (there is language in the fire code for this), or allowing them to remove the sign (guess which happens more often!).

I feel like this issue is a lot like the ones where a building officials goes down the "what if" rabbit hole and regulates something based on what might happen rather than what it is.


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## bill1952 (Oct 12, 2021)

I generally agree TMurray, but having been on design team on projects in many jurisdictions, the answer to the OPs question "Do you find in some jurisdictions that you are required to make all of those doors code compliant exits?" remains yes.  

I guess if you only work in one or a relatively few jurisdictions, not much of an issue.   You learn or decide what the interpretation is.


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## tmurray (Oct 12, 2021)

bill1952 said:


> I generally agree TMurray, but having been on design team on projects in many jurisdictions, the answer to the OPs question "Do you find in some jurisdictions that you are required to make all of those doors code compliant exits?" remains yes.
> 
> I guess if you only work in one or a relatively few jurisdictions, not much of an issue.   You learn or decide what the interpretation is.


I would imagine it would be quite frustrating to have an official obviously exceeding their legal authority. Do you fight them on this issue? Maybe, but what if they hold a grudge and get you back worse? But on the other side, if no one calls them on it, how does the problem get fixed? I have a hard time blaming contractors and designers for just complying sometimes.


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## bill1952 (Oct 12, 2021)

There's usually bigger fish to fry than a few exit signs and besides, arguing with a building official is like wrestling with a pig in mud.........and I'm sure you know the rest.


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## redeyedfly (Oct 12, 2021)

I argue with BOs all the time and win.  But in this case the BOs insisting all doors meet egress requirements have code to back them up.
1010.1Doors.
P​_Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. *Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.*_

The rationale is that people don't check the code plans for the designed egress route in a fire event, they look for the nearest way to get out of the building.


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## bill1952 (Oct 12, 2021)

this topic needs a pole!


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## ICE (Oct 12, 2021)

1010.1 Doors. Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.


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## mtlogcabin (Oct 12, 2021)

A door is not a means of egress it is only one portion of the means of egress system and if you can't or don't comply with all of it then that door is simple that. A door that leads out of the building

[BE] EXIT. *That portion of a means of egress system between the exit access and the exit discharge or public way*. Exit components include exterior exit doors at the level of exit discharge, interior exit stairways and ramps, exit passageways, exterior exit stairways and ramps and horizontal exits.

[BE] EXIT DISCHARGE. That portion of a means of egress system *between the termination of an exit and a public way.

[BE] MEANS OF EGRESS. *A continuous and unobstructed path of vertical and horizontal egress travel from any occupied portion of a building or structure to a public way*. A means of egress consists of three separate and distinct parts: the exit access, the exit and the exit discharge.*


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## steveray (Oct 13, 2021)

Doors *provided for egress purposes* in numbers greater than required by this code shall meet the requirements of this section.

The extra doors are not provided for egress purposes...


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## tmurray (Oct 13, 2021)

steveray said:


> Doors *provided for egress purposes* in numbers greater than required by this code shall meet the requirements of this section.
> 
> The extra doors are not provided for egress purposes...


Agreed. I think that section is trying to capture the doors that are not required, but have the exit sign above it anyway.


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## redeyedfly (Oct 13, 2021)

And this is why DPs get so frustrated with BOs.  Just keep arguing a stupid point instead of admitting you're wrong.  

The code can't get more clear.  If you have a door that goes outside what else would you use it for?  The intent is evident, the language is unambiguous.  No landings required either??  And if it's more than 30" to grade on the other side, no problem according to another thread about windows.


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## bill1952 (Oct 13, 2021)

I can only smile.  Some of the nearly ballistic opposition in the code hearings - where everyone was in a big room and lined up at the mics - to my proposal to clarify this told me to just design all m.o.e. components - whether required or not -  to the code requirements.  Inevitably, at least some of the times you don't, you'll spend more time and money on change orders then it would cost to leave out a sign or use different hardware or change the size.

I'd also have trouble defending a man-door in an exterior wall as NOT intended for an occupant to leave the building.  Besides the not an exit sign including one that disabled can read would cost more. It's just smart design IMHO.


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## ICE (Oct 13, 2021)

So there is a minimum requirement for door count out of a space but say your *building has 12 doors to the exterior* (assume warehouse with several convenience doors) and *only (2) are required* by code for exiting.  Do you find in some jurisdictions that you are required to make all of those doors code compliant exits... with signage and access to public way/area of refuge?



1010.1 Doors. Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. *Doors provided for egress purposes* in numbers greater than required by this code shall meet the requirements of this section.


The code requires a minimum number of means of egress doors.  The code recognizes that there  might be doors that facilitate egress that are *not part of* the minimum required means of egress. The code states that those extra doors provided for *egress purposes* shall meet the requirements of section 1010.
                                                                                                                                                                                                                                                                Section 1010.1 has two distinct types of doors....means of egress doors and doors provided for egress purposes.  Well then a door is a door and there's code for all of them.


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## steveray (Oct 13, 2021)

Example.....I have a large assembly area with proper side side hinged egress doors and I want to put a slider or some other fancy alternative door in the middle...Likely wouldn't qualify for egress, but it does not need to if it is not provided for egress.....


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## bill1952 (Oct 13, 2021)

steveray said:


> Example.....I have a large assembly area with proper side side hinged egress doors and I want to put a slider or some other fancy alternative door in the middle...Likely wouldn't qualify for egress, but it does not need to if it is not provided for egress.....


Slippery "not provided to for egress" vs "does not provide egress".  But since it's available to able bodied people it of course has to meet all the requirements for people with disabilities.

Railings on a stair that's not required? Guard strength for a guard that's not required?  No guards or curbs or handrails on a ramp that's not required?

Steveray - I think you are in the minority based on 40 years of designing nationwide, and a lot of code hearings and committee meetings  God bless you!


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## steveray (Oct 13, 2021)

Maybe I should move to Canada....I have no doubt that I am in the minority of building officials.


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## Yikes (Oct 13, 2021)

bill1952 said:


> Slippery "not provided to for egress" vs "does not provide egress".  But since it's available to able bodied people it of course has to meet all the requirements for people with disabilities.
> 
> Railings on a stair that's not required? Guard strength for a guard that's not required?  No guards or curbs or handrails on a ramp that's not required?
> 
> Steveray - I think you are in the minority based on 40 years of designing nationwide, and a lot of code hearings and committee meetings  God bless you!


bill1952, I provided one code and one ADA citation in post #5 showing where not all exit doors are required to be accessible to persons with disabilities.  If you have an alternate citation, please provide it.


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## ADAguy (Oct 13, 2021)

steveray said:


> TM has the best synopsis.....No AHJ should be making you do what the code does not....The "Not an exit" is a good idea.....


and what if the sign is obscured by smoke?


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## steveray (Oct 13, 2021)

ADAguy said:


> and what if the sign is obscured by smoke?


I don't care because it is not required.....Likely the door would be obscured at the same time....


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## bill1952 (Oct 13, 2021)

Yikes said:


> bill1952, I provided one code and one ADA citation in post #5 showing where not all exit doors are required to be accessible to persons with disabilities.  If you have an alternate citation, please provide it.


I forget if you're on they're all exit doors or only 2 are, but if they are not exit doors, what are they? If they are intended for something else, is it discrimination if disabled people can't use them for whatever else they are intended?

I've been told by members of the Board that even if I meet all the requirements, and everything is perfectly accessible, I can't add another door for convenience, like a short cut from a storage room, that isn't accesible.


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## Yikes (Oct 13, 2021)

ADAguy said:


> and what if the sign is obscured by smoke?


The required exits have lighted exit signs that say "EXIT".  Often they are both high and low exit signs.
When the non-required doors (and their signs) get obscured by smoke, then in that regard it's even MORE obvious which doors are the exit doors:  they're the ones with the illuminated EXIT signs that you can still see.


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## Yikes (Oct 13, 2021)

bill1952 said:


> I forget if you're on they're all exit doors or only 2 are, but if they are not exit doors, what are they? If they are intended for something else, is it discrimination if disabled people can't use them for whatever else they are intended?


According to the ADA excerpt that I quoted, up 40% of the doors leading out of a building can be non-accessible without violating ADA Standards.



bill1952 said:


> I've been told by members of the Board that even if I meet all the requirements, and everything is perfectly accessible, I can't add another door for convenience, like a short cut from a storage room, that isn't accesible.


Ask the board to provide a citation for that opinion.
Also, just to be clear, we are not talking about entrances - -we are talking about leaving the building.


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## mtlogcabin (Oct 13, 2021)

redeyedfly said:


> If you have a door that goes outside what else would you use it for?



I have an event center that has more than the required number of exits that meet all the requirements for exiting to a public way or safe dispersal area. There are also 4 sets of double doors that have no panic hardware, no exit signs or emergency illumination identifying them as exit doors. These doors are primarily used during set up and dismantling the various events that happen there every week. If it is a car, boat or RV show they may park a unit directly in front of these doors.
During a gun show there are very strict state limitations on the amount of black powder, smokeless powder and small arms primers you can have in a building (about 1/2 of what the IFC permits) Vendors will park their trailer near the door so they can restock as needed throughout the weekend events. 

 They also save energy since it is better than opening the two 20ft X 16ft tall garage doors when it is less than 30 degrees outside or 90 to 100 degrees during the summer months. 

Call them anything you want, just don't call them an exit


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## bill1952 (Oct 14, 2021)

Yikes said:


> According to the ADA excerpt that I quoted, up 40% of the doors leading out of a building can be non-accessible without violating ADA Standards.
> 
> 
> Ask the board to provide a citation for that opinion.
> Also, just to be clear, we are not talking about entrances - -we are talking about leaving the building.


Actually no.  The statement was made these additional doors are not intended for egress and therefore don't have to meet the requirements for doors in the means if egress.


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## bill1952 (Oct 14, 2021)

mtlogcabin said:


> I have an event center that has more than the required number of exits that meet all the requirements for exiting to a public way or safe dispersal area. There are also 4 sets of double doors that have no panic hardware, no exit signs or emergency illumination identifying them as exit doors. These doors are primarily used during set up and dismantling the various events that happen there every week. If it is a car, boat or RV show they may park a unit directly in front of these doors.
> During a gun show there are very strict state limitations on the amount of black powder, smokeless powder and small arms primers you can have in a building (about 1/2 of what the IFC permits) Vendors will park their trailer near the door so they can restock as needed throughout the weekend events.
> 
> They also save energy since it is better than opening the two 20ft X 16ft tall garage doors when it is less than 30 degrees outside or 90 to 100 degrees during the summer months.
> ...


Perfect. I hope all those non-egress doors are accessible so you don't didcriminate against vendors with disabilities.


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## steveray (Oct 14, 2021)

Lets start with only 2 MOE (from an area) need to be accessible by the IBC

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.

When they are not an AMOE they they need signage to the AMOE...

1111.2 Directional signage. Directional signage indicating
the route to the nearest like accessible element shall be provided
at the following locations. These directional signs shall
include the International Symbol of Accessibility and sign
characters shall meet the visual character requirements in
accordance with ICC A117.1.
1. Inaccessible building entrances.
2. Inaccessible public toilets and bathing facilities.
3. Elevators not serving an accessible route.
4. At each separate-sex toilet and bathing room indicating
the location of the nearest family/assisted use toilet or
bathing room where provided in accordance with Section
1109.2.1.
5. At exits and exit stairways serving a required accessible
space, but not providing an approved accessible means
of egress, signage shall be provided in accordance with
Section 1009.10.


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## bill1952 (Oct 14, 2021)

steveray said:


> Lets start with only 2 MOE (from an area) need to be accessible by the IBC
> 
> 1009.1 Accessible means of egress required. Accessible
> means of egress shall comply with this section. Accessible
> ...


No disagreement on m.o.e. doors.  It's the 


steveray said:


> The extra doors are not provided for egress purposes...


that I believe as an amenity in the space are required to be accesible.


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## Rick18071 (Oct 14, 2021)

I'm not sure if this is about accessible exits or any exit. If all exterior doors need to follow IBC as an means of egress, doors that do not swing like garage and sliding doors would not be allowed.


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## steveray (Oct 14, 2021)

Ok...but I can put a revolving door anywhere I want and it is not accessible? 

7. Revolving doors shall not be part of an accessible
route required by Section 1009 and Chapter 11.


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## steveray (Oct 14, 2021)

Rick18071 said:


> I'm not sure if this is about accessible exits or any exit. If all exterior doors need to follow IBC as an means of egress, doors that do not swing like garage and sliding doors would not be allowed.


A little bit of thread drift bringing in the accessibility at this point...Doors other than side hinge are allowed in specific limited cases....


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## Rick18071 (Oct 14, 2021)

steveray said:


> .Doors other than side hinge are allowed in specific limited cases....


I never knew this. What code sections limit the amount or location of non-side hinged doors?

Would a exterior side hinged door that only goes to a balcony need to follow the "means of egress" sections?


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## bill1952 (Oct 14, 2021)

The basic issue is means of egress components in excess of what is required and whether they have to comply with the requirements for means of egress.  Can a door in an exterior wall inswing, be less than minimum height and width, have no hardware to open it, or otherwise not comply with the requirements for a door in the means of egress?  Can a stair in addition to all that are required for m.o.e. have 10" risers and no handrails? Can a non-required corridor be 30" wide?  And for accessibility, if I add a door for convenience from room A to B, can it be inaccesible, requiring a person with a disability to take a much more circuitous route?  Seems discrimatory. (And the concept in a theatre that if a non-disabled person can go from seat to stage without leaving the auditorium and stage, than a person with a disability should also be able to do that, and it's in the standards with words I drafted decades ago.)

The idea of "intended" use, that as one thing is not intended for m.o.e. is a big black hole.  If I can evade code requirements by saying a door is not intended for egress, I can as easily claim a stair is not intended for egress, or a toilet not intended to or it's normal uses, or a big room in a school is not intended for assembly. And we all know how diligent owners are in applying for a permit for change of use. 

And from the designer's view, look at how much time is saved if all m.o.e. components, required or in addition to what is required,  comply with the m.o.e. requirements.


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## tmurray (Oct 14, 2021)

steveray said:


> Maybe I should move to Canada....I have no doubt that I am in the minority of building officials.


We'd love to have ya!


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## bill1952 (Oct 14, 2021)

Atikokan ON would be my choice.


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## tmurray (Oct 14, 2021)

What I keep coming back to is what problem is being solved by forcing doors that are not a required exit to comply with the requirement for exits. 

The building has already met the minimum standard of safety.

The designer could just block over the door, decreasing the level of actual safety.

Without an exit sign, the only people aware that they can get out of the building through that door will be staff, so we don't have an issue with crowd crush.


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## tmurray (Oct 14, 2021)

redeyedfly said:


> And this is why DPs get so frustrated with BOs.  Just keep arguing a stupid point instead of admitting you're wrong.
> 
> The code can't get more clear.  If you have a door that goes outside what else would you use it for?  The intent is evident, the language is unambiguous.  No landings required either??  And if it's more than 30" to grade on the other side, no problem according to another thread about windows.


The code provision appears to be limited to doors that are provided for egress.

The only person who can tell me the purpose for the door is the designer. As the AHJ, I can only hypothesize to the reason for the door.


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## mtlogcabin (Oct 14, 2021)

There are doors that are not permitted to be part of the means of egress
4.    Egress shall not pass through kitchens, storage rooms,


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## bill1952 (Oct 14, 2021)

Isn't the door to a storage room or kitchen the means of egress for occupants of the storage room or kitchen, and thus those doors have to comply?


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## tmurray (Oct 14, 2021)

I feel like people are getting stuck on the fact that on some rare occasion, someone could possible use any exterior door for egress and finding that it needs to comply based on that. However, based on that logic, overhead doors would likely need to comply as well. Maybe even some windows. 

What if, what if, what if...


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## steveray (Oct 14, 2021)

Rick18071 said:


> I never knew this. What code sections limit the amount or location of non-side hinged doors?
> 
> Would a exterior side hinged door that only goes to a balcony need to follow the "means of egress" sections?


For instance....And of course there are others in 1010, 9 in this particular section...

1010.1.2 Door swing. Egress doors shall be of the pivoted
or side-hinged swinging type.
Exceptions:
1. Private garages, office areas, factory and storage
areas with an occupant load of 10 or less.
2. Group I-3 occupancies used as a place of detention.
3. Critical or intensive care patient rooms within
suites of health care facilities.
4. Doors within or serving a single dwelling unit in
Groups R-2 and R-3.


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## steveray (Oct 14, 2021)

tmurray said:


> I feel like people are getting stuck on the fact that on some rare occasion, someone could possible use any exterior door for egress and finding that it needs to comply based on that. However, based on that logic, overhead doors would likely need to comply as well. Maybe even some windows.
> 
> What if, what if, what if...


What if...WTF...Whatever...


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## Yikes (Oct 14, 2021)

steveray said:


> A little bit of thread drift bringing in the accessibility at this point...Doors other than side hinge are allowed in specific limited cases....


There's a whole lot of drift on this thread, because the original poster has not provided sufficient information.

The post is in the "accessibility" forum, which leads us to believe that it might be a question about accessibility.  But the essence of the question in post #1 was unclear as to whether it was about life-safety means of egress, or about accessibility.
The OP did not say where the project is located, so we don't know the applicable code or authority having jurisdiction.
The OP did not say whether it was a code / plan check issue, or whether there was a concern about ADA civil enforcement / lawsuits.
In post #5, I encouraged the OP to provide this information, but saw no response.  So we're all going on whatever tangent interests us most.


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## mtlogcabin (Oct 14, 2021)

bill1952 said:


> Isn't the door to a storage room or kitchen the means of egress for occupants of the storage room or kitchen


Not unless it is signed as an exit door


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## ADAguy (Oct 14, 2021)

steveray said:


> Lets start with only 2 MOE (from an area) need to be accessible by the IBC
> 
> 1009.1 Accessible means of egress required. Accessible
> means of egress shall comply with this section. Accessible
> ...


Code may not be "less accessible" then ADA minimums, no?
Both code "and" law applies to owners


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## steveray (Oct 14, 2021)

If that tweaks you out look at this garbage from IBC commentary:

While there are no dispersement requirements
specific to accessible means of egress or travel distance
limitations where there is not an area of refuge
requirement (see Sections 1009.3, 1009.4 and
1009.6), the code requires all exits to be distinct, separate
and independent. The main intent is that a person
with mobility impairments will always have
options. If not all exits are accessible, possible
entrapment should be a consideration in determining
which exits are to be made accessible.


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## bill1952 (Oct 14, 2021)

mtlogcabin said:


> Not unless it is signed as an exit door
> 
> View attachment 8286


Isn't a path out of every room required for egress?  Doesn't a door from every storage room and every kitchen have to comply with code for egress, even if an exit access door? Maybe no sign, no rating, inswing, and perhaps it doesn't have to be accessible, but there are code requirements at least for size, force to open, landings, and maybe more. I believe the code requires a m.o.e. for all occupants.


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## Rick18071 (Oct 14, 2021)

mtlogcabin said:


> Not unless it is signed as an exit door
> 
> View attachment 8286


Thanks mtlogcabin for this. This doesn't mention doors that are not marked as exit doors so if unmarked they do not need to comply with this section.

in a building with an occupancy is less then 50 you don't need exit signs. So if only 1 exit is required in this building and there is 2 exterior doors and no exit signs and one door does not meet code as an exit because it is locked from the outside how does a person know which door to exit the building?


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## steveray (Oct 15, 2021)

Typically the door they came in, single entrance/ single egress....Reasoning behind signs required when two exits are required....


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## Bdonald (Oct 25, 2021)

akelly said:


> So there is a minimum requirement for door count out of a space but say your building has 12 doors to the exterior (assume warehouse with several convenience doors) and only (2) are required by code for exiting.  Do you find in some jurisdictions that you are required to make all of those doors code compliant exits... with signage and access to public way/area of refuge?


See IFC/IBC 2018 1010.1 where doors installed greater in number that is required must still comply with the egress requirements. Also, see 2018 IFC 504 access to buildings for fire department use.


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## steveray (Oct 25, 2021)

Bdonald said:


> See IFC/IBC 2018 1010.1 where doors installed greater in number that is required must still comply with the egress requirements. Also, see 2018 IFC 504 access to buildings for fire department use.



Same in the IBC and the point of debate.....

1010.1 Doors. Means of egress doors shall meet the requirements
of this section. Doors serving a means of egress system
shall meet the requirements of this section and Section
1022.2. Doors *provided for egress purposes* in numbers
greater than required by this code shall meet the requirements
of this section.


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## tmurray (Oct 25, 2021)

Bdonald said:


> See IFC/IBC 2018 1010.1 where doors installed greater in number that is required must still comply with the egress requirements. Also, see 2018 IFC 504 access to buildings for fire department use.


See, that's the thing. It is not required for all doors. Just those provided for egress purposes. It would be helpful to look at a slightly modified version of the clause to compare what is likely the original intent.

1022.2. Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.
- this means that doors provided for egress purposes must comply even if they are in excess of the minimum number.

1022.2. Doors provided in numbers greater than required by this code shall meet the requirements of this section.
- this would mean that all doors must comply.

Given the bolded section in Steveray's post, we can only conclude that it was the author's intention to limit the application of this clause in the manner stated and not to apply it to all doors. Of course any door could be used for egress, but as to the original intent of the door, what it was provided for, only the designer can answer if the door is provided for egress purposes or not.

We would all be best served to have the designer clearly indicate what doors a provided for egress purposes on their plans.


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## tmurray (Oct 25, 2021)

bill1952 said:


> Isn't a path out of every room required for egress?  Doesn't a door from every storage room and every kitchen have to comply with code for egress, even if an exit access door? Maybe no sign, no rating, inswing, and perhaps it doesn't have to be accessible, but there are code requirements at least for size, force to open, landings, and maybe more. I believe the code requires a m.o.e. for all occupants.


Not sure how it is there, but here the means of egress is the whole of the path from inside the building to the outside (safe area). There are components of the means of egress that include access to exits and exits themselves. Sometimes doors out of spaces need to comply with more stringent requirements based on what hazards are present in the building and/or how many people. 

For instance, who cares if the door to a small janitor's closet swings in. But the doors from a large theater to the lobby? Definitely should apply some requirements to door swing there.


----------



## mtlogcabin (Oct 25, 2021)

I just watched a 48 Hours show on the Rhode Island Station Fire 18 years later








						Watch 48 Hours Season 34 Episode 5: The Station Nightclub Fire: Who's Responsible? - Full show on CBS
					

Club owners open up for the first time after deadly fire kills 100. "48 Hours" contributor Jim Axelrod reports.




					www.cbs.com
				



and it was interesting how the owners insisted the door next to the stage was not an egress door yet the fire marshal and prosecuting attorney deemed it was (it opened inward). Maybe because it had an exit sign above it and that is how the band got out. The fire marshal only cited that the door had to be removed which if the owners had complied it just may have prevented the band from surviving.


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## steveray (Oct 25, 2021)

I could never see ordering a door removed.....Exit sign yes, but not a door....Work won't let me open that link, so I will have to check it from home...Good one to show to the new folks I assume...


----------



## Rick18071 (Oct 25, 2021)

It makes sense to remove an exit sign from an exit that does not comply to code as a means of egress but what section of the code requires this?


----------



## steveray (Oct 25, 2021)

It's not a legal exit so you cannot advertise it as such......

1013.1 Where required. Exits and exit access doors shall be
marked by an approved exit sign readily visible from any
direction of egress travel.


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## bill1952 (Oct 25, 2021)

Anyone suggest what purposes a door, much like those intended for egress, is intended for if not for egress? As a designer, I can just see the building officials reaction to "that door is not intended for egress, it's only for ventilation or the view (in a warehouse) or for Uber eats deliveries.  Would you allow key key deadbolts even?


----------



## steveray (Oct 25, 2021)

bill1952 said:


> Anyone suggest what purposes a door, much like those intended for egress, is intended for if not for egress? As a designer, I can just see the building officials reaction to "that door is not intended for egress, it's only for ventilation or the view (in a warehouse) or for Uber eats deliveries.  Would you allow key key deadbolts even?


Access? general circulation?.....Yes


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## Rick18071 (Oct 25, 2021)

steveray said:


> It's not a legal exit so you cannot advertise it as such......
> 
> 1013.1 Where required. Exits and exit access doors shall be
> marked by an approved exit sign readily visible from any
> direction of egress travel.


This only says exit are to be marked. Still it does not say when a door is not an exit it shall not be marked as an exit.


----------



## steveray (Oct 25, 2021)

Kinda like you don't mark a conference room a bathroom unless you want me to piss in the corner....


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## tmurray (Oct 26, 2021)

Rick18071 said:


> This only says exit are to be marked. Still it does not say when a door is not an exit it shall not be marked as an exit.


Here it is in the fire code. Basically, if it is signed as an exit it has to function as one.


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## tmurray (Oct 26, 2021)

bill1952 said:


> Anyone suggest what purposes a door, much like those intended for egress, is intended for if not for egress? As a designer, I can just see the building officials reaction to "that door is not intended for egress, it's only for ventilation or the view (in a warehouse) or for Uber eats deliveries.  Would you allow key key deadbolts even?


I did my internship with a local fire engineering firm. They are very reputable and work internationally. I was lucky to have the experience that I did there. 

I remember one saying that they had was that the proper interpretation of any code provision was the least restrictive, reasonable interpretation. 

When building officials reject a less restrictive, but reasonable interpretation of the code, they cease being a regulator enforcing the law and become an autocrat enforcing their preference.


----------



## Rick18071 (Oct 26, 2021)

tmurray said:


> Here it is in the fire code. Basically, if it is signed as an exit it has to function as one.




We don't use the IFC here unless the IBC section that sends us there, such as for high racks. So as an inspector I guess I can't make them take down any exit signs on non complying exit doors.
Do you make them take an exit sign down on an existing building that never had any exit doors that would comply with the latest code?


----------



## tmurray (Oct 27, 2021)

Rick18071 said:


> We don't use the IFC here unless the IBC section that sends us there, such as for high racks. So as an inspector I guess I can't make them take down any exit signs on non complying exit doors.
> Do you make them take an exit sign down on an existing building that never had any exit doors that would comply with the latest code?


I should clarify, this is only an option where the number and location of "exits" are constructed in excess of the code.

The fire code states that exits must be provided in accordance with the code and any door signed as an exit shall function as an exit. 

If the exits have never complied with the code (i.e. did not meet code when constructed), fire officials would order them to be brought to current code. If they met code when installed, but do not meet current code, it is really at their discretion, but they have largely shied away for this unless they note serious issues. 

The real question is how existing exits can be brought up to current code based on all the limitations we see with existing buildings. Sometimes all you can do is make them better than what they are today.


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## bill1952 (Oct 27, 2021)

tmurray said:


> I did my internship with a local fire engineering firm. They are very reputable and work internationally. I was lucky to have the experience that I did there.
> 
> I remember one saying that they had was that the proper interpretation of any code provision was the least restrictive, reasonable interpretation.
> 
> When building officials reject a less restrictive, but reasonable interpretation of the code, they cease being a regulator enforcing the law and become an autocrat enforcing their preference.


So ok to have a stair in a building with 8" treads and 10" risers if not required for nor intended for the means of egress?


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## steveray (Oct 27, 2021)

bill1952 said:


> So ok to have a stair in a building with 8" treads and 10" risers if not required for nor intended for the means of egress?


No...Stairs do not have the same language

1011.1 General. Stairways serving occupied portions of a
building shall comply with the requirements of Sections
1011.2 through 1011.13.

1010.1 Doors. Means of egress doors shall meet the requirements
of this section. Doors serving a means of egress system
shall meet the requirements of this section and Section
1022.2. Doors provided for egress purposes in numbers
greater than required by this code shall meet the requirements
of this section.

See the difference?


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## bill1952 (Oct 27, 2021)

OK


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## Rick18071 (Oct 28, 2021)

I looks like the code does not give me any power to make them take down an exit sign on a non conforming convenient door like a slider or a door that is screwed shut even in a brand new building (that already has the minimum complying exit doors). I think their should be a section to require this but I can't make one up.


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## steveray (Oct 28, 2021)

This section...If you really need one

1010.1 Doors. Means of egress doors shall meet the requirements
of this section. Doors serving a means of egress system
shall meet the requirements of this section and Section
1022.2. Doors provided for egress purposes in numbers
greater than required by this code shall meet the requirements
of this section.
Means of egress doors shall be readily distinguishable
from the adjacent construction and finishes such that the
doors are easily recognizable as doors.


----------



## tmurray (Oct 28, 2021)

Rick18071 said:


> I looks like the code does not give me any power to make them take down an exit sign on a non conforming convenient door like a slider or a door that is screwed shut even in a brand new building (that already has the minimum complying exit doors). I think their should be a section to require this but I can't make one up.


I would think about this another way. If it is signed as an exit, one could conclude that it is intended for egress purposes and thus must comply. If you cite something like "convenience doors that are signed as an exit must function as an exit" many can read between the lines and see the other option is to just remove the sign. 

What is that joke...

There are two types of people, those that can infer from incomplete data.


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## my250r11 (Oct 28, 2021)

Rick18071 said:


> non conforming convenient door


You just said it, it doesn't conform as an exit= remove sign/make complaint.


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## Rick18071 (Oct 28, 2021)

steveray said:


> This section...If you really need one
> 
> 1010.1 Doors. Means of egress doors shall meet the requirements
> of this section. Doors serving a means of egress system
> ...


The doors that I am talking about are not a means of egress.
I need would need a section number to put in my report to make them take the exit sign down.


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## steveray (Oct 28, 2021)

Rick18071 said:


> The doors that I am talking about are not a means of egress.
> I need would need a section number to put in my report to make them take the exit sign down.


Correct,,,they are not, so they are not allowed to look like one....


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## ADAguy (Oct 28, 2021)

bill1952 said:


> The basic issue is means of egress components in excess of what is required and whether they have to comply with the requirements for means of egress.  Can a door in an exterior wall inswing, be less than minimum height and width, have no hardware to open it, or otherwise not comply with the requirements for a door in the means of egress?  Can a stair in addition to all that are required for m.o.e. have 10" risers and no handrails? Can a non-required corridor be 30" wide?  And for accessibility, if I add a door for convenience from room A to B, can it be inaccesible, requiring a person with a disability to take a much more circuitous route?  Seems discrimatory. (And the concept in a theatre that if a non-disabled person can go from seat to stage without leaving the auditorium and stage, than a person with a disability should also be able to do that, and it's in the standards with words I drafted decades ago.)
> 
> The idea of "intended" use, that as one thing is not intended for m.o.e. is a big black hole.  If I can evade code requirements by saying a door is not intended for egress, I can as easily claim a stair is not intended for egress, or a toilet not intended to or it's normal uses, or a big room in a school is not intended for assembly. And we all know how diligent owners are in applying for a permit for change of use.
> 
> And from the designer's view, look at how much time is saved if all m.o.e. components, required or in addition to what is required,  comply with the m.o.e. requirements.



There are best practices and those who chose to "only" adhere to min./max's. Specifics vs. prescriptive. Anyone can be sued for anything, you takes your chances.


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## my250r11 (Oct 29, 2021)

Here is the commentary for that section:


SECTION 1010
DOORS, GATES AND TURNSTILES
1010.1 Doors. Means of egress doors shall meet the requirements
of this section. Doors serving a means of egress system
shall meet the requirements of this section and Section
1022.2. Doors provided for egress purposes in numbers
greater than required by this code shall meet the requirements
of this section.
Means of egress doors shall be readily distinguishable
from the adjacent construction and finishes such that the
doors are easily recognizable as doors. Mirrors or similar
reflecting materials shall not be used on means of egress
doors. Means of egress doors shall not be concealed by curtains,
drapes, decorations or similar materials.
The general requirements for doors are in this section
and the following subsections. The reference to Section
1022.2 is intended to emphasize that exterior exit
doors must lead to a route that will allow a path to a
public street or alley (see definition for “Public way”).
A door that is intended to be used for egress purposes,
even though that door may not be required by
the code, is also required to meet the requirements of
this section. An example may be an assembly occupancy
where four doors would be required to meet
the required capacity of the occupant load. But
assume the designer elects to provide six doors for
aesthetic reasons or occupant convenience. All six
doors must comply with the requirements of this section.
Doors need to be easily recognizable for immediate
use in an emergency condition. Thus, the code
specifies that doors are not to be hidden in such a
manner that a person would have trouble seeing
where to egress.


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## steveray (Oct 29, 2021)

Well it all comes down to intent then...


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## Rick18071 (Oct 29, 2021)

my250r11 said:


> Here is the commentary for that section:
> 
> 
> SECTION 1010
> ...




Like I said this door I'm talking about is not intended for a means of egress.


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## bill1952 (Oct 29, 2021)

Rick18071 said:


> Like I said this door I'm talking about is not intended for a means of egress.


What is it intended for?


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## ADAguy (Oct 29, 2021)

good question, a closet maybe?


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## bill1952 (Oct 29, 2021)

iirc, this began with doors to the exterior in a storage facility possibly.  If they aren't intended for going in and out of the building, I have trouble imaging what they are for.


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## mtlogcabin (Oct 30, 2021)

Exterior doors may lead to an outside area that will not lead to a public way or a safe dispersal area. Therefore they will not meet the code for an exit in a means of exit system since there is no exit discharge


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## bill1952 (Oct 30, 2021)

If it went to such a courtyard without a path to the public way, wouldn't then need to be a means of egress door from the courtyard?  Just exit sign if required for occupancy on outside?  Maybe we some markings or signage inside to prevent blocking it?


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## Rick18071 (Nov 1, 2021)

Why does it matter what the door is intended for as long as it is not intended as a "means of egress"?


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## ICE (Nov 1, 2021)

mtlogcabin said:


> Exterior doors may lead to an outside area that will not lead to a public way or a safe dispersal area. Therefore they will not meet the code for an exit in a means of exit system since there is no exit discharge


This is an open and shut case.


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## ADAguy (Nov 5, 2021)

Doing so may misdirect you to a dead end condition, no?


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## Cali_Code_Architect (Dec 10, 2021)

Yikes said:


> akelly, welcome to the forum!
> It really helps is you tell us (1) where the project is located, so we know which code/jurisdiction is applicable, and (2) whether it is (a) new, (b) existing with no changes, or (c) existing with an addition or alteration proposed.
> 
> If you have a space that requires 2 exit doors but has 12 exit doors, then only 2 doors need to be made "code compliant" with the provisions IBC chapter 10 'Means Of Egress'.  You certainly would not have exit signs on the other 10 doors if you don't intend to use them for exiting.
> ...





Yikes said:


> akelly, welcome to the forum!
> It really helps is you tell us (1) where the project is located, so we know which code/jurisdiction is applicable, and (2) whether it is (a) new, (b) existing with no changes, or (c) existing with an addition or alteration proposed.
> 
> If you have a space that requires 2 exit doors but has 12 exit doors, then only 2 doors need to be made "code compliant" with the provisions IBC chapter 10 'Means Of Egress'.  You certainly would not have exit signs on the other 10 doors if you don't intend to use them for exiting.
> ...


This post has me considering my current project, a 5000sf existing tenant improvement in California. The building has 7 existing doors but only requires one exit based on 30 or less occupancy. We are making the middle door accessible and the only designated exit for egress, but I've been assuming the other doors can remain as-is

The other 6 doors have accessibility issues. Several lead to a back alley less than 44", another has a single step, and the last has a shutter.


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## steveray (Dec 10, 2021)

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. Exceptions: 1. Accessible means of egress are not required to be provided in existing buildings.

YCMV....


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## Cali_Code_Architect (Dec 10, 2021)

steveray said:


> 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. Exceptions: 1. Accessible means of egress are not required to be provided in existing buildings.
> 
> YCMV....


Ah, thank you. That exception isn't mentioned in the CBC. But a similar exception is included in the CEBC under alterations.

CEBC 305.6 Alterations 

Exception 2 Accessible means of egress required by Chapter 10 of the _International Building Code_ are not required to be provided in existing facilities.






						Searchable platform for building codes
					

Explore a searchable database of US construction and building code. Code regulations are consolidated by state and city for easier navigation.




					up.codes


----------



## ICE (Dec 17, 2021)

_1010.1 Doors. Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section and Section 1022.2. Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section._

It does come down to who determines the purpose of a door. The purpose of a door is obvious. To assume that a door that is in addition to the required means of egress door need not meet the requirements of a means of egress door simply because an entity has determined that said door was not provided for egress purposes …. That’s just wrong.

How about the homeowners that tell you that no smoke alarm is required in that bedroom because they are using it as an office. Did that bedroom magically become not a bedroom. Didn’t happen did it. It didn’t happen because there is no reason to rely on the the occupants to respect the designation as an office and not use it as a bedroom. It is after all a bedroom.

Providing doors that do not meet the same requirements as a “means of egress system” doors Is legal as long as it is not possible to “egress“ through the door. Well then, what is the definition of egress through a door? My conclusion is that egressing a space means exiting that space.

I’ll provide an example. A nightclub is required to have four exits. The club has six doors to the exterior. Four of the doors open in the direction of travel and two swing in. All but the blind people see the six doors. The people don’t perform a mental exercise to decide which doors are the required egress doors…you know, much as the architect did. No, not at all. They see the doors….they know that the other side of the door is outside.

Now unfortunately a pyrotechnic display ignites the ceiling. People are fleeing. The people that found the four required exit doors got out. The people that found the extra exit doors that swung in were found later that night.

Buildings will present individual situations. Residential as opposed to commercial, etc. The final arbiter is the occupant that opens the door. An absolute exception applied to doors over and above the required number of doors due to semantics is not just wrong but is also unjustifiable.


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## steveray (Dec 17, 2021)

How did they not find the 4 doors with the lit exit signs but they did find the 2 unlit unmarked ones in a dark nightclub? And one of the required exits was locked at the station nightclub BTW....


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## bill1952 (Dec 17, 2021)

steveray said:


> How did they not find the 4 doors with the lit exit signs but they did find the 2 unlit unmarked ones in a dark nightclub? And one of the required exits was locked at the station nightclub BTW....


IIRC the door next to stage was deliberately blocked by the band and one of there crew prevented people from leaving that way.  One was through the kitchen and not easily located. The side door out of the bar area - can't recall.  And the main entrance was narrow and restricted by ticket counter and a second door for blocking sound.  As is predictable, most people tried to exit the way they came in. You go with what you know in an emergency.  But it was narrow and cramped and pushing from behind caused people in the door to get jammed. It was hard to imagine a crowd crush - people jammed so tight together they couldn't move - but that has been repeated at a lot of large loos of life assembly events.

Sorry to get off topic - just spend so much time on this tragedy visiting site and days of hearings at NFPA headquarters.


----------



## steveray (Dec 17, 2021)

Another example....Exterior door in a private office...now it is a required exit, now we have to add exit signs to get to it...Now you have created a violation of 1016.2 for egress through intervening and you can't lock the office.....

I am not saying we couldn't design stuff better, just saying that it shouldn't have to be "ALL EXTERIOR DOORS"....Common sense has to kick in somewhere...


----------



## ICE (Dec 17, 2021)

steveray said:


> *How did they not find the 4 doors with the lit exit signs but they did find the 2 unlit unmarked ones in a dark nightclub*? And one of the required exits was locked at the station nightclub BTW....


I did not give my example a name.  Of course in my world all of the egress doors have illuminated exit signs.  Why the lemming effect takes hold is not my problem to solve.  Providing the bare minimum as required by code is my problem.  If nothing else, the Station fire is proof that more can be done to protect life. The Station fire has no bearing on the issue at hand.


----------



## steveray (Dec 17, 2021)

In my world all of the required exit doors have lit exit signs as well (except when only one is required of course)...Human nature led them back to the entrance which should also be an exit and possibly a "main exit"

1029.2 Assembly main exit. A building, room or space used for assembly purposes that has an occupant load of greater than 300 and is provided with a main exit, that main exit shall be of sufficient capacity to accommodate not less than one half of the occupant load,

Which CT has revised further to require 2/3 the OL to get out....


----------



## bill1952 (Dec 17, 2021)

steveray said:


> Another example....Exterior door in a private office...now it is a required exit, now we have to add exit signs to get to it...Now you have created a violation of 1016.2 for egress through intervening and you can't lock the office.....
> 
> I am not saying we couldn't design stuff better, just saying that it shouldn't have to be "ALL EXTERIOR DOORS"....Common sense has to kick in somewhere...


Interesting example. I have several theatres with chorus dressing rooms - 10-20 occupants - with doors to exterior.  Similar situation. Doors to exterior are compliant with exit sign.  Doors from corridor/backstage are not signed and are lockable.  I don't know why door from dressing room shouldn't be compliant.  You might show me code doesn't require a sign for that number - but the fire marshal will require it 9 times out of 10 - which makes it required as far as I'm concerned.

All the doors in an auditorium are usually complaint with illuminated sing yet you can lock them barring entry, and not allow people in other parts of the building access to those exits to the exterior.

Where does it say that exits in excess of what is required have to be useable by all building occupants and that no exit door can be from an otherwise locked room?


----------



## steveray (Dec 17, 2021)

The last line of 1010.1 in post 102 above...If you want to treat it literally which is what this thread is about...Or has become about...


bill1952 said:


> Where does it say that exits in excess of what is required have to be useable by all building occupants and that no exit door can be from an otherwise locked room?


----------



## bill1952 (Dec 17, 2021)

Here is what it says in 2021 edition with my emphasis:

1010.1 General. 

Doors in the means of egress shall comply with the requirements of Sections 1010.1.1 through 1010.3.4. Exterior exit doors shall also comply with the requirements of Section 1022.2. Gates in the means of egress shall comply with the requirements of Sections 1010.4 and 1010.4.1. Turnstiles in the means of egress shall comply with the requirements of Sections 1010.5 through 1010.5.4.

*Doors, gates and turnstiles provided for egress purposes in numbers greater than required by this code shall comply with the requirements of this section.*

Doors in the means of egress shall be readily distinguishable from the adjacent construction and finishes such that the doors are easily recognizable as doors. Mirrors or similar reflecting materials shall not be used on means of egress doors. Means of egress doors shall not be concealed by curtains, drapes, decorations or similar materials.

"Egress through intervening spaces" is in section 1016, specifically 1016.2, and not in section 1010.

So is this fixed from earlier editions or do you think 2021 says same thing?    "this section" seems only to deal with size, projections, hardware, etc. - the doors and surroundings  physical properties - an not the arrangement.


----------



## steveray (Dec 17, 2021)

Lets boil this down a bit and see if we are misunderstanding each other....1010.1 basically says doors provided for egress purposes meet this section (1010 as a door) That I can mostly get on board with...which might bring in some hardware and some other stuff (still with MT in post 36 though)...What it does not say is that it has to be is an exit. ....and 1013 is signage so really would not be in play....Maybe we can clear this up in 2027..... 

Perfect example where code already recognizes non-egress doors:

1010.1.4.1.2 Other than egress component. A revolving door used as other than a component of a means of egress shall comply with Section 1010.1.4.1. The breakout force of a revolving door not used as a component of a means of egress shall not be more than 180 pounds (801 N).



bill1952 said:


> that I believe as an amenity in the space are required to be accesible.


I don't believe that doors are an amenity, but I certainly would review accessibility to all doors....As part of the circulation path or accessible route...


----------



## mtlogcabin (Dec 17, 2021)

A door that leads to a small outdoor dining area for lets say 40 people with no other means of exit is not an exit for the restaurant but it is the exit for the outdoor dinning area.
The door that leads to the outside fenced storage area or play area at a daycare might be an exterior door but not an exit door because the fenced area is not large enough to meet the requirements of a safe dispersal area and you can't get to the public way because of the fence


----------



## steveray (Dec 17, 2021)

Which again...might be better than burning, but I am not going to steer people there with signage and everything that goes along with an exit door.........


----------



## ICE (Dec 17, 2021)

mtlogcabin said:


> A door that leads to a small outdoor dining area for lets say 40 people with no other means of exit is not an exit for the restaurant but it is the exit for the outdoor dinning area.
> The door that leads to the outside fenced storage area or play area at a daycare might be an exterior door but not an exit door because the fenced area is not large enough to meet the requirements of a safe dispersal area and you can't get to the public way because of the fence


Providing doors that do not meet the same requirements as a “means of egress system” doors Is legal as long as it is not possible to “*egress*“ through the door. Well then, what is the definition of egress through a door? My conclusion is that egressing a space means *exiting* that space.

Exiting is not stepping into fenced dining area or a play room or a pallet yard.  I can’t remember which thread this is.  Whatever it is I agree to disagree.

At this point I am here just for the ads.


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## bill1952 (Dec 17, 2021)

It would seem that those doors to the exterior which do not lead to the public way are clearly not provided for egress (except into the building) We're just debating those doors to the exterior which do allow you to continue to the public way and the contention they are not provided for egress.


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## Rick18071 (Dec 17, 2021)

bill1952 said:


> Doors, gates and turnstiles provided for egress purposes in numbers greater than required by this code shall comply with the requirements of this section.



So if they had an extra door that they didn't want to be used for egress purposes they should put a "NO EXIT" sign and a padlock on it to prove the door is not provided for egress?


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## bill1952 (Dec 17, 2021)

Rick18071 said:


> So if they had an extra door that they didn't want to be used for egress purposes they should put a "NO EXIT" sign and a padlock on it to prove the door is not provided for egress?


My position is clear way up - doors to the exterior should be comply with the egress code requirement.  It's just simpler, saves time, and makes sense to me.  I'm not sure why if it could be an exit that someone wouldnt want it used but yes, fasten shut, paint same as wall, remove hardware.  Or put up some furring and cover it.  Or do what satisfies officials.

I've had the advantage of working on mostly new build, so don't usually install extra and un-needed doors.  Never had the money for extra doors.


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## steveray (Dec 20, 2021)

We can agree to disagree....A good portion of the buildings I have worked on have "extra" doors for some reason or other....I say the BO, FM, owner, and designer should talk about how to handle them in your AHJ....


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## wilgrp (Apr 9, 2022)

in my part of texas .. in new construction..any exit door has to be ADA compliant... we often design other doors that could be considered as exit doors but are for function only.. (not ada accessible)... and on those doors we do not put exit signs nor ADA signage... easy to tell which are exits and which are not.


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## Rick18071 (Apr 11, 2022)

wilgrp said:


> in my part of texas .. in new construction..any exit door has to be ADA compliant... we often design other doors that could be considered as exit doors but are for function only.. (not ada accessible)... and on those doors we do not put exit signs nor ADA signage... easy to tell which are exits and which are not.


It would be interesting to know what the wording of the code was changed to in your area from IBC 1009.1 which does not required more than 2 accessible means of egress.
Do all entrances need to be accessible in your area too?


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## bill1952 (Apr 11, 2022)

wilgrp said:


> easy to tell which are exits and which are not.


Even in in a dimly lit smoke filled environment?


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## steveray (Apr 11, 2022)

bill1952 said:


> Even in in a dimly lit smoke filled environment?


IF...that is a problem, maybe we need brighter exit signs or more floor proximity signs.....


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## ADAguy (Apr 11, 2022)

Yikes said:


> akelly, welcome to the forum!
> It really helps is you tell us (1) where the project is located, so we know which code/jurisdiction is applicable, and (2) whether it is (a) new, (b) existing with no changes, or (c) existing with an addition or alteration proposed.
> 
> If you have a space that requires 2 exit doors but has 12 exit doors, then only 2 doors need to be made "code compliant" with the provisions IBC chapter 10 'Means Of Egress'.  You certainly would not have exit signs on the other 10 doors if you don't intend to use them for exiting.
> ...


Thank you for this, remember if it looks like a door it must comply with ADA


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## Yikes (Apr 11, 2022)

ADAguy said:


> remember if it looks like a door it must comply with ADA


ADAguy, please provide a code or regulatory reference that backs up this statement.

In post #5, I provided a reference that indicated 40% of all entry doors are not required by ADA to be accessible.


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## steveray (Apr 11, 2022)

ADAguy said:


> Thank you for this, remember if it looks like a door it must comply with ADA


So an overhead door?


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## Rick18071 (Apr 11, 2022)

ADAguy said:


> remember if it looks like a door it must comply with ADA


It may be in the civil rights act we call ADA which I never read or enforce as an inspector, but this is not in the IBC


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## Paul Sweet (Apr 12, 2022)

ADASAD 206.4.1 Public Entrances requires at least 60 percent of all public entrances to comply with 404 (be accessible).  ADASAD 207.1 refers to IBC (2000 edition section 1003.2.13.4 or 2003 edition section 1007) for means of egress.


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## ADAguy (Apr 12, 2022)

bill1952 said:


> I generally agree TMurray, but having been on design team on projects in many jurisdictions, the answer to the OPs question "Do you find in some jurisdictions that you are required to make all of those doors code compliant exits?" remains yes.
> 
> I guess if you only work in one or a relatively few jurisdictions, not much of an issue.   You learn or decide what the interpretation is.


if "not a signed exit", it is "still a door"; must not a door still comply with the requirements for a door; as to: min/max size, manuvering approach, hardware?


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## bill1952 (Apr 12, 2022)

Always an interesting question. Do elements not required have to meet the same criteria as if they were required.  If I have met all requirements, can I add a 24" wide door for convenience?


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## ADAguy (Apr 13, 2022)

Yikes said:


> bill1952, I provided one code and one ADA citation in post #5 showing where not all exit doors are required to be accessible to persons with disabilities.  If you have an alternate citation, please provide it.


A door is a door with an intended purpose, to enter an exit a space (unless excepted). Code sets minimums in Chapter 11b & 10) for them, exclusive of whether they are egress or not. Ask an insurance company if they will deny coverage for excessive doors that don't comply?


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## Yikes (Apr 13, 2022)

ADAguy said:


> A door is a door with an intended purpose, to enter an exit a space (unless excepted). Code sets minimums in Chapter 11b & 10) for them, exclusive of whether they are egress or not. Ask an insurance company if they will deny coverage for excessive doors that don't comply?


Example:
If a project is required by ADA to have a minimum of 60% of its doors accessible, and the other 40% don't have to be accessible,
and it is built with 60% of its doors accessible, 40% not accessible,
 - - then 100% of its doors comply with the minimum requirements of ADA.
So I will be asking my insurance company:  "will you provide coverage for ADA-compliant door arrangement?"

Likewise if it is compliant with the minimum requirements of the code.


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## ADAguy (Apr 15, 2022)

eagerly awaiting their response


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## bill1952 (Apr 15, 2022)

So this started with a warehouse with 12 doors, but only 2 required. I sense the consensus here is that the 10 not required doors don't have to meet any requirements (except perhaps fire resistance).  So are 60% of the 2 (both) or the 12 (8) required to be accessible?


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## Rick18071 (Apr 15, 2022)

bill1952 said:


> o this started with a warehouse with 12 doors, but only 2 required. I sense the consensus here is that the 10 not required doors don't have to meet any requirements (except perhaps fire resistance).  So are 60% of the 2 (both) or the 12 (8) required to be accessible?


Depenes if they are entrance doors or exit doors or both.   only 60% of entrance doors need to be accessible entrances and only 2 exit doors are  requred  to be accessible means of egress


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