# Roof Access and Egress Article



## LGreene (Sep 11, 2011)

I was asked to write an article about the locking of roof doors, and I was hoping that a few of you might be willing to read it before I submit it since this is a little bit of a grey area and there seem to be a lot of local "unofficial" preferences.  I need to address what the codes actually say, but include the possibility of local requirements.

Thanks in advance!

Decoded:  Roof Access and Egress

I continuously receive questions regarding roof doors - specifically whether free access is required from the stairwell to the roof, and whether free egress is required from the roof to the stairwell.  The codes don't address roof doors in detail so some interpretation is necessary, and in some jurisdictions the code officials have preferences that are beyond what the codes require.  I have spoken to quite a few code officials about their requirements for roof doors, but it's important to be aware of any special requirements for your project's location.

First, the question of free access to the roof.  By "free access," I mean that any building occupant can move freely from the stairwell to the roof without a key, tool, or special knowledge or effort.  Hollywood has taught us that in a fire we can just head out to the roof and wait for the helicopter to arrive, but this isn't based on reality.  Neither the International Building Code (IBC) nor the Life Safety Code (NFPA 101) typically require free access to the roof, and the false belief that building occupants can find safety by reaching the roof has lead to death and injury.  There is evidence that during the events of 9/11, several hundred occupants of the World Trade Center headed for the roof and perished in the stairwells.  In a recent fire in Boston, a resident was found on the stairwell side of the locked roof door, unable to reach fresh air and relative safety.  She was resuscitated and she survived.

In the case of the Boston fire, the media focused on the fact that the roof "fire door" was locked.  I spoke to several code officials in Boston and other cities around the country, and confirmed that free access to the roof is not required by code, and there are compelling reasons that free access to the roof is not desired.  If building occupants are allowed free access to the roof, an increase in accidental falls, attempted suicides, and vandalism will increase.  Some code officials indicated a preference for fail safe locks on the roof doors which unlock upon fire alarm to allow access to the roof, but this is not currently a requirement of the IBC or NFPA 101.

Whether a roof door is required to provide free egress from the roof depends on what the roof is used for.  We can separate roofs into two general types - occupied roofs including roof gardens and rooftop assembly spaces, and unoccupied roofs which contain mechanical equipment and would be occupied at limited times for equipment maintenance and repair.  The majority of roofs fall into the second category.  Although the preference from a life-safety standpoint would be to always allow free egress from the roof, security concerns can sometimes drive the need to lock the door from the roof to the stairwell to prevent unauthorized access to the building.  Both the IBC and NFPA 101 seem to support the option of locking these doors on the roof side:

NFPA 101 – 2006, 2009:

7.2.1.5.8 If a stair enclosure allows access to the roof of the building, the door to the roof either shall be kept locked or shall allow re-entry from the roof.

IBC – 2003, 2006: 1018.1;  IBC – 2009:  1021.1

… For the purposes of this chapter, occupied roofs shall be provided with exits as required for stories. The required number of exits from any story, basement or individual space shall be maintained until arrival at grade or the public way.

Paragraph 7.2.1.5.8 from NFPA 101 says that roof doors have to EITHER allow free egress from the roof, OR be kept locked.  I interpret this to mean that if the door is locked on the stair side preventing free access to the roof, it does not need to provide free egress from the roof.  The IBC addresses occupied roofs, requiring the doors to meet the same requirements as other egress doors, but does not address unoccupied roofs.  This is typically interpreted to mean that the door to an unoccupied roof can be locked on both sides.  If acceptable to the code official, I recommend a double-cylinder deadbolt for this application, so the door doesn't automatically lock behind the technician as he gains access to the roof.

As stated above, the IBC requires occupied roofs to be "provided with exits as required for stories."  For example, if a roof deck is classified as an Assembly use group, the same quantity of exits and the same hardware must be provided as if the space was not located on the roof but elsewhere in the building.  This would obviously require free egress from the occupied roof, including panic hardware if the occupant load was more than 50 or 100 depending on which code was in use.  Last year I visited a rooftop garden in a hospital, which had two egress doors providing free egress from the roof into the building.  If greater security is needed for occupied roof doors, it would have to be provided by the use of alarms, or delayed egress locks if allowed by code (Note:  The IBC does not allow delayed egress on Assembly occupancies).

In summary, free access to the roof from the stairwell is not required by the IBC or NFPA 101, but may be required or preferred by the local code official.  Free egress from the roof to the stairwell is required for occupied roofs, but is not mandated by the IBC or NFPA 101 for unoccupied roofs.  There may, however, be a local requirement for free egress from unoccupied roofs so it's best to check with the local code official.  For locking an unoccupied roof door when acceptable to the code official, a double cylinder deadbolt can avoid accidental lockouts.  If the door to the unoccupied roof is fire rated, a passage latch is required in addition to the deadbolt, and can be combined into one mortise lockset.  This is a good compromise between life safety and security that is also code-compliant, unless prohibited by the local code official.  If the code official requires fail safe locking to allow egress and/or access during an emergency, a fail safe electrified lockset with remote release can be used.


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## peach (Sep 11, 2011)

The roof access is generally for the firefighters.

Unless the egress plan includes some kind of roof access.. you need to send people down for emergency egress.

If there is a roof deck for assembly use, there needs to be open stairs and elevators (or you risk DOJ for ADA).  If there isn't a helicopter plan in place that is well known, egress is always down.

Firefighters will find a way to get onto the roof if they need to get there (axes).


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## imhotep (Sep 11, 2011)

> Paragraph 7.2.1.5.8 from NFPA 101 says that roof doors have to EITHER allow free egress from the roof, OR be kept locked. I interpret this to mean that if the door is locked on the stair side preventing free access to the roof, it does not need to provide free egress from the roof.


Paragraph 7.2.1.5.8 from NFPA 101 states that roof doors have to either allow free egress from the roof, or be kept locked.

I interpret this to mean that the door may be locked on the stair side preventing free access to the roof, but neither requires nor prohibits free egress from the roof.


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## imhotep (Sep 11, 2011)

Finding bodies at the top of a required stairway is disconcerting.  IBC 1009.13 requires one stairway extend to the roof in buildings four or more stories, but does not have a provision that requires identification similar to IBC 1022.7 when the stairway is continuation from flights below.


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## peach (Sep 11, 2011)

Rooftop access is not for residents of the building; it's fire fighter access.


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## imhotep (Sep 11, 2011)

peach said:
			
		

> Rooftop access is not for residents of the building; it's fire fighter access.


If a building Owner is a resident, but not a fire fighter may he/she use the 'fire fighter' access?


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## mark handler (Sep 11, 2011)

peach said:
			
		

> Rooftop access is not for residents of the building; it's fire fighter access.


Peach

If there is an "occupied roof", access can serve both

Like a rooftop pool...


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## mark handler (Sep 11, 2011)

WORLD TRADE CENTER LOCKED STAIRWELLS / EVACUATION PROBLEMS,

ACCUMULATING COMMENTS ON ...

http://mjbarkl.com/locked.htm

We have not learned anything from 9/11


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## mark handler (Sep 11, 2011)

Stair to Roof (NFPA 101®: 7.2.1.5.8, NFPA 5000™: 11.2.1.5.3)

If a stair enclosure allows access to the roof, the door to the roof either shall be kept locked or shall allow re-entry from the roof


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## LGreene (Sep 11, 2011)

Thanks everybody.  For those of you who posted the line from NFPA 101/5000, I (unofficially) interpret this to mean that re-entry from the roof is only required if there is access without a key from the stair side.  If the door is kept locked, as it would/should be when the roof is only used for mechanical equipment, re-entry from the roof is not required. What say you?


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## mark handler (Sep 11, 2011)

LGreene said:
			
		

> Thanks everybody.  For those of you who posted the line from NFPA 101/5000, I (unofficially) interpret this to mean that re-entry from the roof is only required if there is access without a key from the stair side.  If the door is kept locked, as it would/should be when the roof is only used for mechanical equipment, re-entry from the roof is not required. What say you?


Kept locked or shall allow re-entry


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## cda (Sep 12, 2011)

There are times that there may be a standpipe hook up on the roof, so one more reason why access to the roof may be needed/ required.


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## DwightB (Sep 12, 2011)

Unrelated tidbit; In Taiwan the top floor of multi-family housing is very desirable because it is assumed that top-floor tenancy comes with roof access - and a place for the kids to play with kiddie toys and pools, rooftop gardens, and personal space.  Then the problems develop when somebody adds a few walls and a roof and gets a "free" bedroom.


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## LGreene (Sep 12, 2011)

cda said:
			
		

> There are times that there may be a standpipe hook up on the roof, so one more reason why access to the roof may be needed/ required.


In this case, do the firefighters need free access to the roof, or do they find their own way out there?


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## LGreene (Sep 12, 2011)

Coincidentally, I saw this story today about a fall caused by a roof door locking behind someone:

http://www.people.com/people/article/0,,20527375,00.html?hpt=hp_t2


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## cda (Sep 12, 2011)

Will need to see if there is wording in the book

Maybe next Monday


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## Builder Bob (Sep 13, 2011)

Depends upon the local AHJ interpretation of IFC Code section 504.3 and/or 508.5.4.

IFC 504.3  Stairway access to roof. New buildings four or more stories in height, except those with a roof slope greater than four units vertical in 12 units horizontal (33.3 percent slope), shall be provided with a stairway to the roof. Stairway access to the roof shall be in accordance with Section 1009.12. Such stairway shall be marked at street and floor levels with a sign indicating that the stairway continues to the roof. *Where roofs are used for roof gardens or for other purposes, stairways shall be provided as required for such occupancy classification. * AND/OR

IFC 508.5.4 Obstruction. Posts, fences, vehicles, growth, trash, storage and other materials or objects shall not be placed or

kept near fire hydrants, fire department inlet connections or fire protection system control valves in a manner that would prevent such equipment or fire hydrants from being immediately discernible.*The fire department shall not be deterred or hindered from gaining immediate access to fire protection equipment or fire hydrants.*

Have seen this last sentence used to address access to rooftops for standpipes Stairways very rarely stay pure and uncontaminated from smoke products in a fire............ Nobody wants to be in a chimney and fumbleing with forcible entry tools to force a door.  (It takes approx. a minute for a fire fighter to climb a flight of stairs per/ story. So if I have a 45 minute air pack (in heavy exertion equals about 24 to 25 minutes of use ---- 10 stories = 10 minutes, It takes 10 minutes to get back down if a problem arises ---- so I have 5 minutes to force a door at the of the stairs in extreme heat. ---- Forcible entry is not the answer for rooftop or story access from a stairway IMHO.........


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## LGreene (Sep 13, 2011)

That's great input, Builder Bob.  Is it common for standpipes to be located on the roof?  I feel very strongly that the roof doors shouldn't be left unlocked and allow free access to the roof at all times.  Are there any arguments against allowing free access during a fire?  If there is a standpipe on the roof and we use a fail safe electrified lock to let firefighters out there, you could end up with building occupants out there too.  Is that a problem?  Would a roof door key in a knox box (either on the outside of the building or at the roof door) be acceptable, or does the unlocking need to be automatic?  I would love to know how common it is to have a standpipe on the roof, so I would appreciate input from everyone on that.


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## permitguy (Sep 13, 2011)

> I would love to know how common it is to have a standpipe on the roof, so I would appreciate input from everyone on that.


Where standpipes are required:

905.4 Location of Class I standpipe hose connections. Class I standpipe hose connections shall be provided in all of the following locations:

5. Where the roof has a slope less than four units vertical in 12 units horizontal (33.3-percent slope), each standpipe shall be provided with a hose connection located either on the roof or at the highest landing of a stairway with stair access to the roof. An additional hose connection shall be provided at the top of the most hydraulically remote standpipe for testing purposes.



> Would a roof door key in a knox box (either on the outside of the building or at the roof door) be acceptable, or does the unlocking need to be automatic?


We require a roof door key in the knox box (outside the building).  We have not and would not require the unlocking to be automatic.

Many of the issues and concerns on this subject are best addressed through the FD's public education program.


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## AegisFPE (Sep 13, 2011)

I had a client who was confused by the required signage per 1022.8, thinking that the intent of identifying that the stair served the roof was to help the occupants know which stair to use for rescue by helicopter.  Thanks Hollywood!

Perhaps the signage should be modified to clarify whether the rooftop access is locked or not.


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## permitguy (Sep 13, 2011)

I guess the wording could be more descriptive:  "Roof Access for Authorized Personnel".

If they are fully compliant with IFC Ch. 4, the confusion would be greatly reduced.


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## Builder Bob (Sep 13, 2011)

IFC Section 905........ Indicates by code requirements where a standpipe may be required --- However, often times a standpipe may be used as an alternate method as well to obtain coe compaliance when fire departmnet access may be limited or lacking.


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