Exit Discharge Illumination

images3LU8KUQ0I was talking to a hospital facility manager recently and he was miffed that a surveyor cited him for not having emergency power lighting on the exit discharge outside the hospital. He has been at this hospital for nearly 30 years and takes any deficiency as a personal affront to his abilities as a facility manager. Besides, he told me, this has never been a problem before so why is it a problem now? (I hear that a lot!)

Section 7.8.1 of the 2000 Life Safety Code requires the exit discharge to be illuminated all the way to the public way. Sections 18/ requires emergency lighting in accordance with section 7.9, which requires emergency power for illumination of the exit discharge to the public way. The definition of public way is:

“A street, alley, or other similar parcel of land essentially open to the outside air deeded, dedicated, or otherwise permanently appropriated to the public for public use and having a clear width and height of not less than 10 feet.”

Under most interpretations from the accreditation organizations, the parking lot of a hospital can be considered to meet the requirements of a public way, even though it may not be “deeded to the public”. So, the path of the exit discharge to the parking lot would need to have illumination that is fed from normal power and emergency power. But the illumination for the parking lot would not have to be emergency power illumination, since the requirement is to have emergency power illumination only to the public way, not at the public way. This is a generalized interpretation, and it may or may not apply to all situations. You need to determine before your next survey if your exit discharge lighting meets this requirement.

Also, the illumination source needs to be arranged so the failure of any single lighting unit does not result in an illumination level of less than 0.2 foot-candles. This means you need two-bulb fixtures, or multiple single-bulb fixtures. The issue of LED fixtures is an interesting one. Technically, a LED fixture is comprised of many LED lamps, so I could see a single LED fixture as qualifying as a multiple lamp fixture. I haven’t heard of any authority say anything to the contrary, at least.

Changes to Unoccupied Rooms Open to Stairwells

The current edition of the Life Safety Code (2000 edition) does not allow an unoccupied room (such as a mechanical room, janitor’s closet, storage room) to have an opening (doorway) from an exit enclosure (stairwell). There have been many hospitals designed and constructed since WWII that have at least one stairwell that extends up to the mechanical room penthouse, without the proper fire rated separation. I would venture to say that nearly half of the hospitals I consulted in over the past 5 years, has this problem. I can only surmise that the Building Code that the hospitals were originally designed and constructed to, did not share this requirement.

The picture to the left was taken from the landing between the top occupied floor, and the mechanical room above it. As you can see, the top of the stairwell has a door directly into the mechanical room, which is a violation of (d) of the 2000 edition. You will also note there is a rope suspended down from the roof, in the picture. Having once worked in the construction trades, I knew what it was for, but the facility director saw me looking at it and offered his take on it: “That rope is for our Suicide Assistance Program.” (Everyone is a comedian….). I asked him to remove it.

Now, when CMS finally adopts the new 2012 edition of the Life Safety Code, there will be a change that should help those facility directors that still have this problem. Section (9)(c) of the 2012 edition has an exception to openings on exit enclosures (stairwells) that says:

“Existing openings to mechanical equipment spaces protected by approved existing fire protection-rated door assemblies shall be permitted, provided that the following criteria is met:

  • The space is used soley for non-fuel fired mechanical equipment
  • The space contains no stoarge of combustible materials
  • The building is protected through-out by an approved automatic sprinkler system.”

So, what does this mean? Well, if you have yet to resolve an existing mechanical room that opens onto an exit enclosure, and your building qualifies for this exception, then it appears to me that you will not have to resolve this problem when the new 2012 LSC is finally adopted. In the mean-time, I suggest you identify this deficiency as a PFI on your Statement of Conditions (if you are Joint Commission accredited) with an 18-month completion date. In the section of the PFI where you describe how you will resolve the problem, just say the issue will be resolved with the adoption of the new 2012 edition of the LSC.

Stairwell Closed for Construction

Q: We have a stairwell in our hospital that extends from the 8th floor to the 1st floor, where there is a door that discharges the occupants to the outdoors. We have construction in progress on the 2nd floor, which affects the stairwell and we have closed the stairwell at the 2nd floor level, however, we have allowed the stairwell to remain open from the 3rd floor to the 8th floor. Our safety officer thinks allowing people to travel from the 8th to the 3rd floors in a stairwell that is closed on the 2nd floor is not allowed, and wants to close the entire stairwell. This would be a hardship for our staff that wants to use the stairs rather than wait for an elevator. Do we have to close the stairwell entirely, or can we allow it to remain open on the upper floors?

A: Construction projects never make it easy on facility managers and safety officers, do they! My answer to your question is dependent on the precautions and alternative measures that you have implemented. First let me say that when working with something that is such an integral part of safety such as an exit stairwell, the most effective safety precautions should be taken. If it were my decision, I would agree with your safety officer and want to shut the entire stairwell down as the construction project has caused the path of egress to be obstructed.  However, there is another option. If you implemented the appropriate Interim Life Safety Measures (ILSMs) and provided adequate signage on each floor declaring the stairwell is no longer an exit, explaining that it now terminates at the 3rd floor, and if you provided adequate signage explaining where the closest alternative exit is located, then you would be able to allow the stairwell to be used for communicating purposes to get from floor to floor, and it is no longer an exit. Any ‘Exit’ signs that direct the path of egress towards and into this stairwell would have to be covered or removed and the construction in progress would have to be separated from the occupants in the stairwell with appropriately rated materials. Other ILSMs would have to be considered as well, according to your hospital’s policy. While this would not be my first choice, I agree that this modified use of the stairwell would be permitted by the NFPA 101 Life Safety Code (LSC), 2000 edition.

Are Sidewalks Required for Exit Discharge?

Q: Are hard-surface sidewalks, such as concrete, required between the exit door and the public way in order to qualify as an exit discharge? I was told that we need to have a hard-surface sidewalk in these locations.

A: The LSC does not require a hard surface sidewalk, such as a concrete walk. However, the code does have specific requirements that need to be complied with. Section 7.7 requires exits to terminate directly to the public way or to an exterior exit discharge such as a yard, court or open space. Additional requirements are found in section 7.1.6, which discusses abrupt changes in elevation in the walking surface which cannot exceed ¼ inch. This may be difficult to maintain over a grass yard or open space. Additional requirements involving stairs or ramps are found in section 7.1.7. The path of egress must be maintained free of all obstructions and impediments, including the removal of snow and ice for those institutions that are located in cold weather areas.

The requirements for a level walking surface and the removal of snow and ice are easier to comply with when there is a hard walking surface, such as a concrete sidewalk. An open space that is already a hard, level walking surface such as a paved parking lot, or a gravel access is fine as long as you meet the other requirements.

Even though the LSC does not specifically require it, most authorities having jurisdiction (AHJ) will require hard-surface sidewalk, such as concrete, to assure the organization meets the level walking surface requirement.