Q: There’s a lot of confusion surrounding this topic; primarily when and where elevator lobbies are required. The consensus of the architects and fire protection engineers I’ve talked to is that the section 7.2.13 of the 2012 Life Safety Code pertains to elevators used as a means of egress in the event of a fire (e.g. high-rise). However, not all AHJs see it this way and some have made hospitals construct one-hour barriers to create elevator lobbies on all floors. We have seen this in relatively old and new buildings of various heights. Do you agree with this interpretation of the Life Safety Code that elevator lobbies are required?
A: No, I do not. In healthcare occupancies, elevators are not permitted to be a means of egress according to section 19.2.2 of the 2012 Life Safety Code. Section 19.2.2 lists all of the approved means of egress components and elevators did not make the list. Under 19.2.2, the following means of egress components are approved for healthcare occupancies:
- Smokeproof enclosures
- Horizontal exits
- Exit passageways
- Fire escape ladders
- Alternating thread devices
- Areas of refuge
Section 7.2.13 does not apply to healthcare occupancies because the occupancy chapter has prohibited elevators to be considered a means of egress. Even though section 220.127.116.11 states: “An elevator complying with the requirements of 9.4 and 7.2.13 shall be used as a second means of egress from towers, as defined in 3.3.280…” it is trumped by the healthcare occupancy chapter. Whenever there is a conflict between a core chapter (1 through 11) and an occupancy chapter (12 through 42) the occupancy chapter prevails. Besides, 18.104.22.168 refers to 3.3.280 to define a tower which is a structure like an FAA control tower; not a high-rise building.
To be sure, section 7.2.13 does not apply to healthcare occupancies, and the healthcare occupancies are not required to comply with the requirements in 7.2.13 because the elevators are not a required means of egress. However, you can have elevators but since they are not considered a means of egress, they do not have to comply with 7.2.13. It is interesting to note that the Annex section of the LSC does recommend the use of elevators as an alternate means of egress. You just can’t place an ‘Exit’ sign over the entrance to an elevator and count it as a required means of egress.
I suggest you check with your state or local authorities to see if they have other regulations concerning elevators.