Jun 11 2018

Stairwell Exit Locked Door

Category: BlogBKeyes @ 12:00 am

Q: Can a stairwell door that leads to the outside of a hospital be locked with a lock that requires a code to unlock it? I seem to recall that the doors could be on magnets that release upon activation of the fire alarm and that have a touch pad that releases the doors within 15 seconds.

A: No… it can’t. According to of the 2012 LSC, doors in the means of egress must not be equipped with a latch or lock that requires the use of a tool or key from the egress side, unless otherwise permitted as follows:

  • Delayed egress locks (
  • Access-control locks (
  • Elevator lobby locks (
  • Clinical needs locks (
  • Specialized protective measure locks (

I don’t know where in the hospital this stairwell exit door is located, but let’s assume it does not qualify for clinical needs locks (psychiatric care patients), specialized protected measure locks (OB, Peds, Nursery, ICU, ER), and elevator lobby locks. That leaves delayed egress locks, which requires the entire building to be sprinklered, and access-control locks which do not lock the door in the path of egress, just in the path of ingress, neither of which allows the use of key-pads to unlock the door in the path of egress.

If you decide to use one of the approved exceptions for door locking, please make sure you read the appropriate section of the Life Safety Code and comply with everything it requires. Most surveyors are pretty well informed on the LSC requirements for door locks and they will hold you accountable.

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Jan 20 2016

Strange Observations – Part 1

Category: BlogBKeyes @ 12:00 am

Cage in StairwellI thought you might be interested in seeing some of the strange things I have observed as a consultant for healthcare organizations. This is a picture of a cage that a hospital built inside the stairwell. It was their attempt to create a locked door to prevent access to the roof.

It was successful in keeping unauthorized people from having access to the roof but it is not compliant with section of the 2000 LSC which says you cannot lock doors in the path of egress. Also, section says you cannot have anything in the stairwell that could interfere with exiting.

A cage with a locked door would certainly interfere with exiting.


Mar 19 2015

Stairwell Signage

Category: BlogBKeyes @ 1:00 am

In Case of Fire Web 2If you were a bit surprised by the wording of the sign to the left… You’re not alone. I had to do a double-take when I first saw it, as it certainly got my attention.

The sign is a marketing strategy by the Stairwell Signage Solutions company in Palm Beach Gardens, Florida, and is re-printed here with permission. The sign is an ominous warning to facility managers that their existing stairwell signage may not be compliant with the new 2012 Life Safety Code.

When the new 2012 LSC is adopted facilities will have to comply with the following requirements, found in section


  • New enclosed stairwells serving three or more stories and existing enclosed stairwells serving five or more stories must have stairwell identification signs (previously, the 2000 LSC only required stairwells serving five or more stories to have stairwell identification signs);
  • The stairwell must be provided with identification signs inside the enclosure at each floor landing;
  • The signage must indicate the floor level;
  • The signage must indicate the terminus of the top and the bottom of the stairwell;
  • The signage must indicate the stairwell name (identification);
  • The signage must indicate the floor level of, and the direction to, the exit discharge;
  • The signage must be located inside the enclosure approximately 60 inches above the floor landing in a position that is visible when the door is open or closed;
  • The signage must be continuously illuminated with emergency power back-up capability (this was not previously required);
  • The floor level designation must be tactile in accordance with ICC/ANSI A117.1 (this was not previously required);
  • The signage must be painted or stenciled on the wall or on a separate sign securely attached to the wall (this was not previously required);
  • The name of the stairwell must be located at the top of the sign in minimum 1 inch tall lettering (this was not previously required);
  • Stairwells that do not provide roof access must read ‘NO ROOF ACCESS’ underneath the name of the stairwell in 1 inch tall lettering (this was not previously required);
  • The floor level number must be located in the middle of the sign in 5 inch tall numbers (this was not previously required);
  • The identification of the lower and upper terminus of the stairwell must be located at the bottom of the sign in 1 inch tall lettering (this was not previously required).

The phrase ‘this was not previously required’ is referring to the 2000 LSC. If you would like to contact Stairwell Signage Solutions, contact Stephen Salzberg, at imagemaven@aol.com.


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Dec 25 2014

Items Stored in a Stairwell

Category: BlogBKeyes @ 6:00 am

photo 1 web 2We should all know that storage of items in an exit enclosure, such as a stairwell, is not permitted by the Life Safety Code. Right? Well… there are exceptions that would allow certain items to be stored in a stairwell, but not all of the authorities having jurisdiction (AHJ) actually recognize these exceptions.

I was recently asked if a hospital could store their evacuation chairs in the alcoves of a stairwell (see the picture to the left). The alcoves are not in the direct path of egress inside the stairwells and appear to have been designed to allow a overlook to the scenery outside the building.

So let’s take a look at section of the 2000 LSC which says the following:

“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.”

This section makes it clear that you cannot have enclosed storage space in the exit enclosure, although the exception to this section does allow an enclosed storage underneath the stairs as long as it is separated by barriers with the same fire resistive rating as the exit enclosure and it is accessible from outside the stairs.

Another section ( of the 2000 LSC) says the following:

 “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.”

The Annex section of says the following:

“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.”

What this section means is the storage of evacuation chairs would be permitted in the alcove of a stairwell since the alcove is not part of the egress, as long as 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.

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 does prohibit storage in the stairwell that is “not necessary for safety”, so 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 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 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.

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May 08 2014

Stairwell Interruption Gates

Category: BlogBKeyes @ 5:00 am

Stairwell Interuption Gate Web 2Stairwell interruption gates are those bars or half-size gates that are mounted inside the stairwells on the level of exit discharge. they swing freely allowing exiting in the direction of egress, but they do not swing and prevent people from exiting in the direction away from the stairwell discharge. Section 7.7.3 of the 2000 LSC says stairwell interruption gates are required at the level of exit discharge in stairwells that continue more than one-half story beyond the level of exit discharge. The intent with this standard is to stop people who are egressing down the stairwell before they go beyond the exit discharge door.

Why would this be necessary? Why couldn’t we just post a sign inside the stairwell that says “Exit Here” over the door for the discharge from the stairwell? All good questions, and case histories have proven that people who are exiting under emergency conditions often do not read signs and just run down the stairs to the bottom, where they think the stairwell discharge is located. Then, it is a mess of people who are trying to climb back up to the level of exit discharge. Often, the stairwell interruption gate is on the first floor, preventing exiting to the lower level(s). But, that is not always the case.

Under normal circumstances, if you are on an upper floor, the direction in the stairwell to the exit discharge is downward. Stairs are supposed to be arranged so it is clear as to the direction to the public way. But there may be a situation where you might be on the second floor and the path of egress is upward to the third floor, or something similar. In that situation, a stairwell interruption gate is appropriate on the second floor to direct the direct the path of egress upwards.

Also, please be aware that stairwell interruption gates are not mandatory on the top occupied level of a stairwell, to prevent unauthorized persons from travel upward to a penthouse mechanical room. It is permitted, but it is not a requirement. The Life Safety Code accepts the premise that people will correctly assume that the path of egress is downward in a stairwell when they are on the upper floors. However, if there is an unusual circumstance where people may assume the path of egress is upwards (when it is not), then an interruption gate may be appropriate.

 These interruption gates are not optional, but are mandatory where the stairs continue more than one-half story below the level of exit discharge.


Dec 06 2012

Stairwell Identification Signs

Category: BlogBKeyes @ 6:00 am

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 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 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.

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Jun 23 2018

Interior Discharging Stairwells

Category: BlogBKeyes @ 1:05 am

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.