Carpeting in Stairwells

Q: I have several hospitals that have been cited by surveyors for having carpet in the stairwells. Can you tell me if there is any code requirement that states that carpet is not allowed in the fire exit stairwell?

A: Excellent question. No… as far as I know, there is no direct standard that prohibits carpeting in exit enclosure stairwells. However, there are a few sections of the LSC that could shed light on this issue.

Section 7.1.6.4 of the 2012 LSC says walking surfaces must be slip resistant. If a surveyor believes the carpet can be slippery, then that would be a problem. Section 7.2.2.3.3.2 of the 2012 LSC says stair treads and landings must be free of projections that could trip stair users. This may be a bit of a stretch, but if the surveyor believes a carpet could become loose, it may trip the people using the stairs.

Annex section A.7.2.2.3.5 of the 2012 LSC says carpeting over the nose of a stair can create an unstable surface. “Any horizontal projections of resilient covering materials beyond the tread nosing and riser, such as carpet and underlayment, can interfere with user’s feet and thereby reduce usable tread depth.”

I think it is safe to say that carpeting is not prohibited, but in the opinion of the NFPA 101 technical committee, carpeting can interfere with the user of the stairs. If the technical committee fully believed carpeting on stairs was a serious impediment to exiting, they definitely would have banned it. It is important to understand that the Annex section is not part of the enforceable code, but rather is explanatory information provided by the technical committee for users of the Life Safety Code to understand what the technical committee was thinking when they wrote the standards.

Therefore, it is perfectly acceptable for an authority having jurisdiction (AHJ) to follow the recommendations provided in the Annex section… or not. It is just advisory information to help the AHJ interpret the LSC. The AHJ can use the information in the Annex section… or they can choose to ignore the information. I can’t say that I disagree with the surveyor… although I can’t remember the last time I saw carpeting in exit access stairwells.

 

Carpet on Corridor Walls

Q: I have a nursing home that is over 20 years old that has carpet on the corridor walls below the handrails. I am been told that this carpet must be removed. I am not able to find any information on the 20-year old carpet that gives the flame spread rating. What are my options other than removing it?

A: It depends on who is telling you to remove the carpet and why. If you were cited by a state surveyor or an accreditation organization, ask them to please identify the standard and reason for the citation. They should be able to identify the precise standard, code, or regulation why the carpet needs to be removed.

I suspect the violation comes from 19.3.3.2 of the 2012 Life Safety code where existing interior finish materials have to be Class A or Class B on corridor walls, which would require a flame spread rating between 0 – 75, and a smoke development rating of 0 – 450.

If you cannot prove that the flame spread rating and smoke development rating of the carpet falls within these parameters, then you have no choice but to remove the carpet from the walls. After 20 years… it’s time for an upgrade.