Illumination of the Egress

Q: Is there a standard on lighting of offices and exam room in the ambulatory or clinics?

A: The Life Safety Code is primarily concerned about egressing the facility under emergency conditions, and only has illumination requirements for emergency egress situations. Section of the 2012 Life Safety Code says the floors and other walking surfaces within exits, and designated stairs, aisles, ramps, escalators, passageways, and exit discharges to be illuminated to 10 ft-candles for new conditions, and 1 ft-candle for existing conditions. Assembly occupancies are permitted to have 0.2 ft-candles of illumination. This applies to clinics and ambulatory healthcare occupancies. Please check with your state and local authorities to determine if they have more restrictive requirements.


Q: Are there any life safety requirements concerning courtyards? We have an outdoor courtyard, surrounded on all sides by our building, with one door entering and exiting the area. As of now, the door remains locked with “Not An Exit” sign posted on it. Our management team would like to open the area to our visitors and came to me for LS concerns. From my perspective, we would need to look at Life Safety issues involving entering the area and look at adding an ‘Exit’ sign, inside the courtyard above the door that goes back into the hospital. Is there anything else that could pose a concern?

A: Beside the ‘Exit’ sign over the door from the courtyard, the courtyard would have to have constant illumination and the door from the courtyard to the indoors must be unlocked all the time.  The walking surface in the courtyard must be level with no abrupt changes in elevation greater than ¼ inch. Also, the “Not An Exit” sign is incorrect; the sign must read “NO EXIT” with the word “NO” 2 inches tall and the word “EXIT” 1 inch tall.

Signage Inside a Stairwell

Q: Can signage, other than that specifically required for inside a fire exit stairwell according to the LSC, be placed inside a fire exit stairwell?

A: Technically… no. According to section of the 2012 LSC, it says the 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 A. says the intent is the exit enclosure essentially be ‘sterile’ with respect to safety hazards.

But, it probably depends on the signage that you want to install in the exit enclosure. If the signage is truly tight to the wall surface and cannot interfere with exiting, then most surveyors would not say anything. But if the signage was in the same style as a hanging framed picture, then that would likely be cited, since it could interfere with exiting when someone brushed their shoulder against the framed picture and it falls off the wall and becomes a trip hazard, or if it was tight to the wall, the projection of the frame could be an interference as well.

But, the Annex section says the stairwell should be sterile… so a technical interpretation could say nothing can be in the stairwell. I have seen surveyors cite organizations for painted-on signs inside stairwell walls because it would cause people to stop and read them, which, in the opinion of the surveyor, would cause a back-up of people egressing and in turn would interfere with the use of the stairwell. That sounds like an extreme interpretation, but one that the surveyor is permitted to make.

Strange Observations – Part 38

Continuing in a series of strange things that I have seen while consulting at hospitals…

This hospital wanted to ‘fence off’ access to the MRI when it was not staffed. Apparently, they did not have a side-hinged swinging door assembly available, so they went with this removable gate.

The problem is, the gate is not side-hinged, and swinging and on top of that they put a padlock on the gate so anyone left in the room would be locked in.

Their reply was, they would ensure that no one is in the MRI area when they set up the gate. Sorry, but the LSC does not allow for that. The gate had to go.

Means of Egress Illumination

Q: We have a chapel/activity room that is used for bingo and worship services. Can you please tell me what the minimum illumination of the walking surface in foot-candles is required for this area?

A: Section 7.8.1 of the 2012 Life Safety Code discusses the requirements for the illumination of the means of egress. Keep in mind that the means of egress includes aisles and is not limited to just corridors. Therefore, the aisles inside the chapel/activity room would be required to meet the minimum illumination requirements. Normally, the minimum illumination requirement at the floor level (other than stairwells) is 1-foot candle according to section (2), but a chapel/activity room would qualify as an assembly occupancy and the LSC allows less lighting levels of 0.2-foot candle during periods of performances or projections involving direct light. But 1-foot candle is not very much illumination and is about the brightness of a lit match. So, maintaining the minimum illumination requirements in the means of egress is achievable. Check with other governmental regulations to see if there are greater requirements for illumination of the means of egress. I’ve been told that OSHA requires a minimum of 5-foot candles of illumination for the means of egress.

Exiting Through a Shell Space

Q: Where in the ambulatory health care occupancy chapter of the Life Safety Code does it permit to have a means of egress from an ASC or a suite within the ASC be through a shell space or machine room? Is this allowed assuming that the proper signage and emergency lights are in place.

A: No… The path of egress cannot extend from a corridor into a room to get to an exit. Section of the 2012 Life Safety Code does not allow this. Also, section says exiting is not permitted through a hazardous room. So, if the shell space is used for storage then you cannot have a path of egress through the shell space. In ambulatory health care occupancies, any room used for storage is considered a hazardous room.

You cannot exit from a suite directly to another room. All required exits from a suite must lead to an exit access corridor, or to a horizontal exit, or to an exit stairwell, or to a direct exit.

Now, if you constructed an exit access corridor in the shell space to separate the stored items from the corridor, then that would be acceptable.

Path of Egress Through a Construction Area

Q: Are there any problems with maintaining an emergency exit for a hospital OR area that travels through an adjacent construction project? Also, can these doors be taped or sealed with a tape/barrier to limit construction dust?

A: In regards to your first question, what would your infection control practitioner say about exiting OR patients (who could possibly have open incisions) into and through a construction area? I’m sure that the IC person would have a fit about that. No… you can’t exit OR patients into and through a construction area. A construction area is typically a dirty, hazardous area depending on the level of demolition and construction. Section of the 2012 Life Safety Code does not permit exiting through a hazardous area. Taping the seams and jamb of a door to prevent dust and dirt contamination would be a good approach to prevent dust and dirt from transferring from the construction to the clean side, but you can’t tape a door closed if the Exit signs tell you that is the path of egress.

You have to close the path of egress if the path is under construction. That is what alternative life safety measures are for (aka Interim life Safety Measures, or ILSM). It is okay to close one path of egress for the needs of construction as long as you conduct an assessment to evaluate what ILSMs are to be implemented. Then you follow what your ILSM policy says regarding closed (or obstructed) exits.

But you can’t tape a door shut that is in the path of egress and expect staff to use that door in the event of an emergency. And you need to come up with alternative measures to compensate for closing that path of egress. It is my observation that project people are not all that familiar with the ILSM method. It’s okay to close an exit if you have to remodel that exit. That’s why the LSC has a standard on ILSM. Most project people don’t know this and they try to maintain what they think has to be: two forms of exiting.

Required Exit from OR

Q: Can a sterile supply corridor that feeds the back of Surgical OR’s have a corridor of less than 8′ if the patient access is from the front of the OR? This front patient access provides the required exit access for inpatients to two exits.

A: Maybe. It all depends on whether or not the sterile supply corridor that feeds the back of the Surgical ORs could in any way be considered a path of egress for the inpatients receiving treatment in the OR. Is this path marked with ‘Exit’ signs? That is usually a dead-giveaway since it marks the path of egress through the sterile corridor as a means of egress for the occupants of the ORs. But, that is not the only indication. Even if the path is not marked with an ‘Exit’ sign, it could still be considered a required path of egress from the ORs. You mentioned that the front patient access provides the required exit access for inpatients to two exits. If that is true (and I have no reason to doubt you), then that may possibly make the sterile corridor to NOT be a required means of egress, and then it would not have to comply with section (2000 edition) for 8 foot corridor widths for new construction. For existing construction, section says 4 foot width is required, but if the corridor is already constructed to a width greater than 4 feet, then you must maintain to corridor to 8 feet of width if you make any alterations or renovations. Parking equipment in a corridor would be considered an alteration.

Before you make any changes to your facility, you need to discuss this issue with the architect who designed the egress routes from the ORs, if that person is still available. It is important that any change in function be reviewed by the proper individuals, which may also include your local or state authorities.