Today, I was reviewing a Fire Safety Evaluation System (FSES) equivalency request on behalf of AOA/HFAP, and the requester wanted an equivalency for an interior discharging exit stairwell, because it did not discharge into an exit passageway, but discharged into a common corridor.
I sent the requester an email asking if the stairwell qualified for the three (3) conditions on Section 7.7.2 of the 2000 edition of the LSC where no more than 50% of the exit stairwells may discharge on the level of exit discharge and not have to comply with exit passageway requirements.
Their reply said no, it did not, because the stairwell discharge was positioned in such a way that the occupants would not be able to see the exit when they discharged from the stairwell.
Well, that’s not what is required by the standard. Provision #1 of 7.7.2, reads:
“Such discharge shall lead to a free and unobstructed way to the exterior of the building, and such way is readily visible and identifiable from the point of discharge from the exit (stair)”
The provision says “…such way is readily visible…” it does not say the exterior (or exit) of the building is visible., but the ‘way’ to the exit is visible. This actually is a common mistake, and one that I remember making when I still worked in a hospital. It wasn’t until I was preparing an equivalency request myself and I sent it to a good friend of mine for review before I sent it to Joint Commission, and he informed me that I didn’t need to ask for an equivalency because the stairwell discharge (the one in the picture, above) qualified for the provisions under 7.7.2.
So, what did I do in regards to the equivalency request today? I denied it, of course. I informed them that the interpretation that AOA/HFAP has is there is no Life Safety Code deficiency, and therefore, there is no need for an equivalency.