# Egress Window for R-2 occupancy



## Philip L (Sep 13, 2019)

I have an existing motel project where they would like to replace the windows, but the existing sills are greater than 44" AFF which was acceptable when the structure was built. Would these be required to be lowered to meet current egress code if they are replaced?

Thanks, I did a wide search and could not fide a clear answer.


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## cda (Sep 13, 2019)

Welcome!!


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## cda (Sep 13, 2019)

Does the building have a fire sprinkler system?


How many stories ??


You are talking about just the window in the bedroom?


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## Philip L (Sep 13, 2019)

Thanks for the reply!  Old 50's building in Florida. Two story.  Type II-B, not sprinklered. Each unit has one sleeping room and one living area. Living area has a sliding glass door on one side and a 3' man door on the other side to an open covered entryway. Sleeping rooms have 6' wide by 2' tall windows with a 4'-8" sill height. Owner would like to replace windows but not enlarge the openings. All exterior doors are also being replaced with more energy efficient ones, but no rough opening changes. Masonry building with concrete floors and roof. 

Thanks again for any insight.


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## steveray (Sep 13, 2019)

Sounds like a Level 1 alteration....So no....

702.5 Emergency escape and rescue openings. Where windows
are required to provide emergency escape and rescue
openings in Group R-2 and R-3 occupancies and one- and
two-family dwellings and townhouses regulated by the International
Residential Code, replacement windows shall be
exempt from the requirements of Sections 1030.2, 1030.3 and
1030.5 of the International Building Code and Sections
R310.21 and R310.2.3 of the International Residential Code
accordingly, provided the replacement window is the manufacturer’s
largest standard size window that will fit within the
existing frame or existing rough opening. The replacement
window shall be permitted to be of the same operating style
as the existing window or a style that provides for an equal or
greater window opening area than the existing window.
Window opening control devices complying with ASTM F
2090 shall be permitted for use on windows required to provide
emergency escape and rescue openings.


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## my250r11 (Sep 13, 2019)

Steveray got it.


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## cda (Sep 13, 2019)

Has the Great State of Florida adopted the existing building code?


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## Philip L (Sep 13, 2019)

Thanks. They are also doing slight kitchen reconfigurations in each unit, so the project is being considered a level 2 alteration.


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## Philip L (Sep 13, 2019)

Ahhhh, Yes, the Great State of Florida has adopted the existing building code.


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## Philip L (Sep 13, 2019)

Also, I think the motel will be considered R-1 as it is transient housing if that makes a difference.


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## cda (Sep 13, 2019)

Philip L said:


> Ahhhh, Yes, the Great State of Florida has adopted the existing building code.




Well Bless Mickey

Welcome, come back when you have a brain cell burning question!!!!


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## Philip L (Sep 13, 2019)

Thanks for all the info everyone! Very much appreciated.


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## RLGA (Sep 13, 2019)

EEROs are not required for Group R-1, since Table 1006.3.2(2) only requires them for Group R-2 when on the first story and Group R-1 occupancies are not permitted one exit for stories above grade plane.


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## e hilton (Sep 13, 2019)

If it is cmu construction, seems like it would be easy to remove one course of block to lower the sill.  Or two courses.  Not messing with the header.


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## classicT (Sep 13, 2019)

RLGA said:


> EEROs are not required for Group R-1, since Table 1006.3.2(2) only requires them for Group R-2 when on the first story and Group R-1 occupancies are not permitted one exit for stories above grade plane.


B I N G O

Although I do have to question the OP. The title of the post introduces this as an 'R-2', however the proper classification of a motel is 'R-1'. (Unless it is a non-transient mote/hotel, but how often is that the case)


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## Philip L (Sep 13, 2019)

Yep. I mislabeled. It is indeed R-1. Thanks again everyone for the input...I was stuck in the code and over analyzing it.


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## fatboy (Sep 13, 2019)

Welcome! Come on back soon!


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## Yikes (Sep 13, 2019)

steveray, California adopted that section (about allowing replacement windows of the same kind, even if it makes the rescue openings slightly smaller) when it became apparent that any other option (such as reframing/enlarging openings) would disincentivize people from purchasing more energy efficient replacement windows.


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## ICE (Sep 13, 2019)

California code

APPENDIX J
EXISTING BUILDINGS AND STRUCTURES


AJ102.4.3 Emergency escape and rescue openings.
Where windows are required to provide emergency escape and rescue openings, replacement windows shall be exempt from the maximum sill height requirements of Section R310.1 and the requirements of Sections R310.1.1, R310.1.2, R310.1.3 and R310.2 provided that the replacement window meets the following conditions:


The replacement window is the manufacturer’s largest standard size window that will fit within the existing frame or existing rough opening. The replacement window shall be permitted to be of the same operating style as the existing window or a style that provides for an equal or greater window opening area than the existing window.


The replacement window is not part of a change of occupancy.


Window opening control devices complying with ASTM F2090 shall be permitted for use on windows required to provide emergency escape and rescue openings.


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## steveray (Sep 16, 2019)

my250r11 said:


> Steveray got it.



Had it....Until the motel monkeywrench....Drats....


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## Inspector Gift (Sep 16, 2019)

Did the OP say the motel has a FIRE SPRINKLER SYSTEM?  If so, then possibly reclassifying the motel as an R-1 to use the exclusion for EERO would be acceptable.

However, IF it does NOT have a compliant fire sprinkler system, then it does not qualify as a R-1 occupancy, IMHO.   The 1973 Uniform Building Code classified it as an Group R, Division 2 Occupancy.


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## RLGA (Sep 16, 2019)

Inspector Gift said:


> Did the OP say the motel has a FIRE SPRINKLER SYSTEM?  If so, then possibly reclassifying the motel as an R-1 to use the exclusion for EERO would be acceptable.
> 
> However, IF it does NOT have a compliant fire sprinkler system, then it does not qualify as a R-1 occupancy, IMHO.   The 1973 Uniform Building Code classified it as an Group R, Division 2 Occupancy.


Actually, the 1973 UBC didn’t have a Group “R”—it was Group H, since they classified everything in alphabetical order: A,B, C, D, E, F, G, H, I, and J. All residential occupancies were in the same occupancy group. The EEROs then (although they weren’t called that in the 1973 UBC) required a maximum sill height of 48 inches, so the building was compliant at the time. 

So they could comply with the current code, which doesn’t require EEROs for Group R-1; or, they could comply with the original code (if permitted by the BO per exception 2015 IEBC Section 301.1) which does require them, but at the height of 48 inches.


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## RLGA (Sep 16, 2019)

Correction to my post above, the OP said the sills were 4’-8” not 48 inches, so it *wasn’t* compliant at the time (assuming the 1973 UBC was adopted then). Best option then would be to comply with the current code...


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