Jun 12 2017

Evacuation Chairs in Stairwells

Category: Evacuation,Questions and Answers,StairwellsBKeyes @ 12:00 am
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Q: I just got cited by the Joint Commission for having evacuation chairs at tops of our stairwells. The chairs were not causing any egress issues in my opinion, but the surveyor did not care that state fire marshal gave his blessing 8 years ago to have chairs at tops of stairwell and during the previous two Joint Commission surveys the chairs were not an issue. Your thoughts on this would be greatly appreciated.

A: First of all, it doesn’t matter what a state or local inspector or fire marshal says. Joint Commission and/or CMS does not have to comply with what a state or local authority says on an issue, and often does not care. All authorities having jurisdiction (AHJ) are equal, but separate. To have the permission or interpretation of one authority does not provide you with any leverage or influence with any other authority. Often times the authorities simply do not care what the other authorities say.

The Life Safety Code is not entirely clear on the subject of evacuation chairs mounted in stairwells. At one point (section 7.2.2.5.3 of the 2012 Life Safety Code) the code says no space in the exit enclosure may be used for any purpose that has the potential to interfere with egress. One may conclude that if the evacuation chairs are mounted off to the side of the top landing where there is no possibility of egress interference, then you can mount an evacuation chair there. But the code does not specifically say that and it would have to be an interpretation by the authority to allow it.

But section 7.1.3.2.3 also says an exit enclosure cannot be used for any purpose that has the potential to interfere with its use as an exit. According to the Annex section, the intent of this standard is the exit enclosure should be sterile with respect for fire safety hazards. The authorities can interpret this any way they want since the code is not clear.

Apparently, the Joint Commission (through the surveyor) is saying they will not allow it, and it is well within their right to say so. I have been in conferences where representatives from the Joint Commission engineering department say they do not allow stairwell evacuation chairs to be stored inside the stairwell.


Jun 08 2017

Stairwell Tread Marking

Category: Questions and Answers,StairwellsBKeyes @ 12:00 am
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Q: We are being told that section 7.2.2.5.4.3 of the 2012 Life Safety Code requires us to install paint on the nose tread on stairs in existing egress stairways as a requirement. I read it as if you want to install a paint stripe, here is what you need to do. Who is correct?

A: Section 7.2.2.5.4.3 in the 2012 LSC is very clear: Where new contrasting marking is applied to stairs, there are four (4) criterions to follow. It does not say all stairs must have contrasting markings applied to the stairs. This section only applies if you decide to apply contrasting markings to the stairs. Also, section 7.2.2.5.5 says exit stair path markings are only required if the occupancy chapter requires them. Healthcare occupancy does not require them.


Mar 09 2017

Pictures Hanging in Stairwells

Category: Questions and Answers,StairwellsBKeyes @ 12:00 am
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Q: I have a question about putting pictures up in stairwells. Someone in our administration department at our hospital wants to put pictures up in a stairwell. We have already received a citation for having a camera in a stairwell so I am almost certain we would get one for this also. I want to quote this section: A 7.1.3.2.3 from the NFPA 101 Life Safety Code as I cannot find any other section on it but want to make sure there is nothing I missed since it is an executive asking to do this and I want to make sure I have every angle covered.

A: You’re correct…. AHJs can be very tough on anything placed in a stairwell that does not serve the function of the stairwell. Under previous editions of the Life Safety Code, a camera would not be permitted because it was not considered to serve the stairwell. But in the Annex section A.7.1.3.2.1(10)(b) of the 2012 Life Safety Code, penetrations for electrical wiring for security cameras would be permitted as long as the AHJ approves. You would have to ask all of your AHJs for approval. Pictures would not serve the function of the stairwell and likely would be cited by AHJs. Section 7.1.3.2.3 of the 2012 Life Safety Code says the exit enclosure (i.e. stairwell) cannot be used for any other purpose that has the potential to interfere with the use of the exit enclosure. A picture hanging on the wall could interfere with individuals exiting the facility. The intent is to prohibit any equipment (i.e. pictures) not necessary for safety. The Life Safety Code intends for the exit enclosure to essentially be “sterile” with respect to safety hazards.


Feb 17 2017

Evacuation Chairs Stored in Stairwells

Category: Evacuation,Questions and Answers,StairwellsBKeyes @ 12:00 am
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Q: I understand it would be best to not place something affixed to the walls of the exit stairwell that protrudes in to the path of egress, which in turn, may interfere with egress. But we have two sets of stairwells, that in the middle of each floor, is a landing which has about a 7’ alcove going away from the path of egress on the landing, and the path of egress does not use this alcove.

So my question is, can we store evacuation chairs in these alcoves? I can understand affixing these items in the path of egress within the stairwell, can interfere with egress, but these alcoves are clearly out of the way and not in the path of egress.

A: To answer your question, let’s first take a look at section 7.2.2.5.3 of the 2012 Life Safety Code (LSC), which says there shall be no enclosed, usable space within an exit enclosure, including under the stairs, nor shall any open space within the enclosure be used for any purpose that has the potential to interfere with egress.

What this section appears to say is you may store your evacuation chairs in the alcove of your stairwell since the alcove is not part of the egress, and the stored evacuation chairs would not interfere with egress. But there are surveyors and AHJs that take a much more severe look at this issue, based on section 7.1.3.2.3 of the 2012 LSC, which says an exit enclosure shall not be used for any purpose that has the potential to interfere with its use as an exit and, if so designated, as an area of refuge.

Some AHJs take a very strong stand against anything being stored in the stairwells, but the Annex section of 7.1.3.2.3 explains this requirement a bit further, and says the provision prohibits the use of exit enclosures for storage or for installation of equipment not necessary for safety. Occupancy is prohibited other than for egress, refuge, and access. The intent is that the exit enclosure essentially be ‘sterile’ with respect to fire safety hazards.

The above reference is in the Annex section of the LSC which means it is not part of the enforceable section of the code, but it is an explanatory section to help authorities understand the intent of the technical committee who wrote the code. Most AHJs follow what the Annex section says, although they do not have to. The Annex section for 7.1.3.2.3 does prohibit storage in the stairwell that is “not necessary for safety”, but one could make the point that evacuation chairs are necessary for safety and therefore are permitted to be stored in the stairwell, as long as they do not interfere with egress.

The bottom line is it is apparent to me that the Life Safety Code does permit the storage of evacuation chairs in an exit stairwell, as long as the chairs are stored in such a way as to not interfere with egress. However, not all AHJs actually agree with this and some do cite hospitals if they have anything stored in the stairwells. If you want to pursue this and store the evacuation chairs in the alcove of your stairwells, I suggest you document these sections of the Life Safety Code and show them to any surveyor who questions the practice. It may prevent you from having a citation, or it may not.


Feb 01 2017

Stairwell Chair Lift

Category: Questions and Answers,StairwellsBKeyes @ 12:00 am
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Q: Can a chair lift device be installed in an exit stairwell? What are the regulations?

A: The Life Safety Code and the local building codes set minimum widths of the required exit stairwells, pertaining to the required doors to the exit stairwells, and they set a minimum number of exit stairwells the hospital must have. These are all calculated by the architect who designed the facility to accommodate people exiting the building during an emergency. To install a chair-lift device in a stairwell would violate these conditions and would cause the building to be non-compliant with the Life Safety Code.

The following sections of the 2012 Life Safety Code set the requirements for minimum widths of required egress components:

  • 7.2.2.2.1.1(b)   36 inches clear width for existing stairs
  • 7.2.2.2.1.2(A)  36 inches clear width for new stairs serving less than 50 occupants
  • 7.2.2.2.1.2(B)  44 inches clear width for new stairs serving 50 to less than 2000 occupants
  • 7.2.2.2.1.2(B)  56 inches clear width for new stairs serving 2000 or more occupants
  • 19.2.3.6           The minimum clear width of doors in existing healthcare occupancies is 32 inches
  • 19.2.3.7           The minimum clear width of doors in existing healthcare occupancies is 28 inches where evacuation by bed, gurney or wheelchair is required

These are minimum width requirements, and actual widths would have to increase based on the number of occupants calculated to use these components.

Section 7.2.2.5.3.1 of the 2012 LSC says nothing may be installed in exit enclosures that could interfere with egress. I suspect a chair-lift would interfere with egress.

If you have a stairwell that is not an exit stairwell, then the possibility may be that a chair-lift could be installed as long as minimum aisle widths (36 inches) are met. Check with your design professional and your state and local AHJs to determine if that is possible.

I’m also told that the ADA requirements do not allow chair lifts in exit stairwells, and check with your state department of hospital licensing to see if they have any additional restrictions.


Aug 31 2015

Stairwell Signage

Category: Questions and Answers,Signs,StairwellsBKeyes @ 12:00 am
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Q: I am looking for a code reference which specifies the installation height for stairwell signage. It appears that NFPA 101 indicates 5 feet above the stairwell landing but does not indicate whether it is to the top or bottom of the sign. Can you provide guidance?

A: If you are referring to the wall-mounted stair identification signs mounted within the enclosure on each landing in stairs serving five or more stories, then the mounting height is ‘approximately’ 5 feet above the floor landing, according to 7.2.2.5.4 of the 2000 Life Safety Code. The NFPA 101 Handbook has a picture showing the 5 foot measurement is between the bottom of the sign and the floor. Since the official code language says ‘approximate’, then the 5 foot distance can be interpreted to be to the top, the center or the bottom of the sign. You should be safe with any of those measurements.


Mar 23 2015

Storage in Stairwells

Category: Questions and Answers,Stairwells,StorageBKeyes @ 6:00 am
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Q: Is there any specific regulation that addresses storing items under stairwells and if so does it differentiate between public stairs and stairs which are utilized to access areas not open to the public?

A: Yes, section 7.2.2.5.3 of the 2000 edition of the Life Safety Code specifically says there must be no enclosed, usable space within an exit enclosure, including under stairs, nor shall any open space within the enclosure be used for any purpose that has the potential to interfere with egress. There is an exception that says enclosed usable space is permitted under the stairs, provided that the space is separated from the stair enclosure by the same fire resistance as the exit enclosure, and entrance to that enclosed usable space is not from within the stair enclosure. The common conclusion of this (and other sections) is general storage is prohibited in stairwells. The concept of an exit enclosure is to provide an egress environment which is sterile from safety hazards. It is recognized that general storage usually ends up (or has the potential of) being a hazardous area, and exiting through a hazardous area is not permitted. From that point of view, this makes perfect sense. However, the LSC does not prohibit safety items stored in the stairwell as long as they do not interfere with the egress. As mentioned in a posting on March 2,  evacuation chairs stored at the top of the stairwell could be considered to not interfere with egress.  Hospitals have such a difficult time finding adequate useful storage space I believe a safety item (such as patient evacuation chairs) should be permitted inside an exit enclosure provided it does not interfere with egress in any way.


Apr 14 2014

Card Readers on Door Locks

Category: Door Locks,Questions and Answers,StairwellsBKeyes @ 5:00 am
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Q: During a recent survey, the surveyor said a card reader on the stairwell door cannot be located on an adjacent wall or door frame, but it must be an integral part of the lockset itself. Is this true? They were talking about card readers on the stairwell side for re-entry to a floor.

A: Did the surveyor cite you for non-compliance? If not, surveyors sometimes say things that are misunderstood, especially if there is no citation. Doors not in the path of egress are permitted to be locked, and a re-entry door from a stairwell usually is not in the path of egress. As long as the re-entry door in the stairwell is not in the path of egress then I do not see any reason that what you describe would be a problem. The Life Safety Code would allow for a card reader device to unlock a stairwell re-entry door as long as the door is not in the path of egress.  If the card reader is mounted in the stairwell on the door leading to a floor of the building (not a discharge door), then the card reader is not on the egress side of the door. There is nothing in the Life Safety Code, or in NFPA 80 Standard for Fire Doors and Fire Windows, (1999 edition) that would require the card reader to be mounted on the door leaf, rather than the on the wall near the door. Therefore, it is clear that the LSC permits card-access readers to be mounted on the wall near the door, since it is not a device or motion to operate the door. I cannot think of any situation that would require the card-access reader to be mounted on the door leaf, itself.


Feb 17 2014

Evacuation Chairs

Category: Blog,Questions and Answers,StairwellsBKeyes @ 6:00 am
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Q: Can evacuation chairs be installed in stairwells?

A: The answer is… maybe yes and maybe no. Sorry, that’s not a direct answer, so please allow me to explain. Section 7.2.2.5.3 of the 2000 edition of the Life Safety Code says: “There shall be no enclosed, usable space within an exit enclosure, including under stairs, nor shall any open space within the enclosure be used for any purpose that has the potential to interfere with egress.” So, if we take the latter half of this requirement, it says we cannot place anything in the stairwell that could interfere with egress. Would hanging an evacuation chair on the inside wall of a stairwell interfere with egress? This is a question that is not directly addressed by NFPA, so that means the authorities having jurisdiction (AHJ) get to make that interpretation. My experience with many AHJs is they do not want anything hung on the wall on the inside of a stairwell where it could be an obstruction to those individuals trying to egress down the stairs. That means to me, that you would NOT be able to hang these evacuation chairs anywhere in the path of egress inside the stairs, no matter how wide those stairs are. However, not all is lost. If there is a landing at the very top of the stairwell that is open and not used as part of the path of egress, and there is no other items on the walls around this landing, such as a fire hose cabinet or fire extinguisher, then I could see that area being used successfully to hang an evacuation chair. The downside of this is the arrangement only seems to apply to the very top of the stairwell, and if you wanted to hang evacuation chairs on every landing in the stairwell, I don’t believe you would be able. Something else to think about: Even if one AHJ says it is okay to hang evacuation chairs inside the stairwell on every landing, I strongly suggest you do not do it. You may have as many as 5 or 6 AHJs that inspect your hospital for compliance with the Life Safety Code. Just because one AHJ says it is okay that does not mean all of the other AHJs have to abide by that decision.


Feb 01 2012

Stairwell Re-Entry Signage

Category: Questions and Answers,StairwellsBKeyes @ 9:41 pm
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Q: In regards to stairwell signage, when you have restrictive access back into the building from a stairwell in accordance with section 7.2.1.5.2 of the NFPA 101 Life Safety Code, should the signs indicate the status of the doors (locked or unlocked) during normal building conditions or when the building is in alarm.

A: I understand your question, but I am not sure I understand your motive. Is it your position that you desire to have stairwell re-entry in your hospital, or is it your position that you do NOT want stairwell re-entry at your hospital? To answer your direct question, I would say the stairwell signage referred to in 7.2.1.5.2, Exception 1 (d) and (e) should identify the stairwell door that allows re-entry when the building fire alarm system is in alarm. But section 19.2.2.2.8 says existing hospital are exempt from complying with 7.2.1.5.2 and the Annex section of 19.2.2.2.8 says doors in the stairwell should allow re-entry at not less than every third floor.  So I see the following points made here:

  1. Doors in a stairwell serving 3 or more stories have to allow re-entry, or have automatic unlocking devices tied to the fire alarm system (7.2.1.5.2)
  2. Existing healthcare occupancies are exempt from the mandatory re-entry requirement in 7.2.1.5.2 (19.2.2.2.8), which means you can lock the doors and prevent re-entry
  3. A suggestion (recommendation) is made that if you choose not to be exempt from 7.2.1.5.2 and you want to prevent re-entry, then at the very least the stairwell door should allow re-entry at every third floor (A.19.2.2.2.8)

So, if you want to prevent re-entry, then I’d suggest you follow the recommendation in A.19.2.2.2.8 and provide automatic unlocking on the stairwell doors at every third floor .If you want to allow re-entry then I don’t see any problem to simply allow it without any locks on the stairwell doors or any automatic releasing devices.


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