A question came up recently as to the proper mounting of the stairwell identification signs that are required in stairwells of a certain height. The wall-mounted stair identification signs are supposed to be mounted within the enclosure on each landing in stairs serving five or more stories. The mounting height is ‘approximately’ 5 feet above the floor landing, according to section 126.96.36.199.4 of the 2000 edition of the Life Safety Code. What does the word ‘approximately’ mean, in this situation? Is the 5 foot measured from the bottom, middle or top of the sign?
The NFPA 101 handbook (2000 edition) has a picture showing the 5 foot measurement is between the bottom of the sign and the floor. One could take this to mean the required 5 foot measurement is from the floor to the bottom of the sign, but that is not necessarily true. The handbook is just a commentary written by a NFPA staff individual, who is also a liaison between the Life Safety Code technical committees and the NFPA. While that person is very knowledgeable, it is still his (or her) opinion and is not considered part of the code.
The annex section of the Life Safety Code explains some of the rationale behind the decisions making up the code language. Unfortunately, the annex section for 188.8.131.52.4 does not discuss the 5 foot mounting height, but does say the sign is intended not only for individuals evacuating the building, but also for the fire department responders to understand critical information about the building during an emergency. The annex section also says the information on the sign can be divided up into two signs to eliminate information over-load.
So, when the Life Safety Code is not specific or clear as to its meaning, the interpretation is left up to those entities that enforce the code in your facility. Those entities are called the authorities having jurisdiction (AHJ) and for healthcare organizations, the national AHJs are the Centers for Medicare & Medicaid Services (CMS), Joint Commission, Healthcare Facilities Accreditation Program (HFAP), and Det Norske Veritas Healthcare (DNV). As far as I know, none of the above AHJs have publicly stated where the 5 foot measurement has to be, therefore since the official code language says ‘approximate’, then the 5 foot distance can be interpreted to be to either the top, the center or the bottom of the sign. You will be safe with any of those measurements. Keep in mind that the requirement for stairwell identification signs is found in chapter 7 of the Life Safety Code, which makes the signs required in any building with 5 or more stories, not just healthcare occupancies.
Always check with your local and state AHJs to determine if they have a more restrictive interpretation.