Handrails

Q: According to the 2012 Life Safety Code, section 7.2.2.3.5, the distance between a handrail and adjoining wall should be 2¼-inches. Does this apply to just spaces in which NFPA requires handrails such as stair and ramps, or does it apply to corridors where a handrail is not specifically required by NFPA? If so, then in areas where NFPA does not require a handrail, but one is installed such as in a corridor, can the distance between the handrail and the wall just have to comply with ADA and the building code, which is 1½-inches?

A: Section 7.2.2.4.4.5 of the 2012 LSC does require new installation of handrails on stairs and ramps to be at least 2¼ inches from the wall. Since section 7.2.2.4.5 is a sub-section of 7.2.2 “Stairs”, this 2¼ inch requirement is limited to just stairs and ramps. It does not apply to handrails on corridors.

I do not see any restrictions on clearance between a handrail and the wall in corridors, other than the CMS limitation of 4-inches maximum projection into the corridor.

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 7.1.3.2.3 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.7.1.3.2.3 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.

Stairwell Signage

Q: With the new 2012 Life Safety Code adoption, my question is around the stairwell signage and 7.2.2.5.4.1. Hospitals are confused whether they have to replace all their signs to meet this new code requirement, or if they are grandfathered-in, and not have to comply. From what I interpret from the code, this would be for new stairwells only… is this correct?

A: No… This applies to all new enclosed stairs serving three stories or more, and all existing enclosed stairs serving five stories or more. There is no ‘Grandfathering’ in the Life Safety Code. There are requirements for new construction (Chapter 18) and there are requirements for existing conditions (Chapter 19), but other than that, there is no ‘Grandfathering’.

When new editions of the Life Safety Code are adopted, facilities must comply with new requirements that apply to existing conditions. Just because the building was compliant with the Life Safety Code at the time of original construction, does not permit the building a ‘pass’ on meeting new requirements that apply to existing conditions.

 

Strange Observations – Part 44

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

I believe those electrical panels installed in this stairwell were for new access-control lock badge readers on a series of doors on the unit served by this stairwell.

Can’t do it… You cannot make new penetrations into a stairwell for anything that does not serve the function of the stairwell (with some exceptions, but this did not meet those exceptions).

As they should have done in the first place, they needed to relocate these panels to an equipment room on the unit.

Stairwell Exit Locked Door

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 19.2.2.2.4 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 (7.2.1.6.1)
  • Access-control locks (7.2.1.6.2)
  • Elevator lobby locks (7.2.1.6.3)
  • Clinical needs locks (19.2.2.2.5.1)
  • Specialized protective measure locks (19.2.2.2.5.2)

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.

Strange Observations – Part 15

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

This is an evacuation chair or sled that is hanging from a sprinkler drain pipe…

Two deficiencies with this one picture: 1) You cannot support anything off of sprinkler pipe; 2) You cannot store anything in the exit enclosure that can impede egress.

The reason why storing an evacuation chair in a stairwell landing impedes egress, is when someone goes to get the chair that person impedes egress for others using the stair.

Carpeting in Stairwells

Q: I have several hospitals that have been cited by surveyors for having carpet in the stairwells. Can you tell me if there is any code requirement that states that carpet is not allowed in the fire exit stairwell?

A: Excellent question. No… as far as I know, there is no direct standard that prohibits carpeting in exit enclosure stairwells. However, there are a few sections of the LSC that could shed light on this issue.

Section 7.1.6.4 of the 2012 LSC says walking surfaces must be slip resistant. If a surveyor believes the carpet can be slippery, then that would be a problem. Section 7.2.2.3.3.2 of the 2012 LSC says stair treads and landings must be free of projections that could trip stair users. This may be a bit of a stretch, but if the surveyor believes a carpet could become loose, it may trip the people using the stairs.

Annex section A.7.2.2.3.5 of the 2012 LSC says carpeting over the nose of a stair can create an unstable surface. “Any horizontal projections of resilient covering materials beyond the tread nosing and riser, such as carpet and underlayment, can interfere with user’s feet and thereby reduce usable tread depth.”

I think it is safe to say that carpeting is not prohibited, but in the opinion of the NFPA 101 technical committee, carpeting can interfere with the user of the stairs. If the technical committee fully believed carpeting on stairs was a serious impediment to exiting, they definitely would have banned it. It is important to understand that the Annex section is not part of the enforceable code, but rather is explanatory information provided by the technical committee for users of the Life Safety Code to understand what the technical committee was thinking when they wrote the standards.

Therefore, it is perfectly acceptable for an authority having jurisdiction (AHJ) to follow the recommendations provided in the Annex section… or not. It is just advisory information to help the AHJ interpret the LSC. The AHJ can use the information in the Annex section… or they can choose to ignore the information. I can’t say that I disagree with the surveyor… although I can’t remember the last time I saw carpeting in exit access stairwells.

 

Security Cameras in Stairwells

Q: Can I install security cameras in stairwells

A: You can…. But be prepared to remove them. Many Accreditation Organizations (AOs) and most states who survey on behalf of CMS do not allow cameras in stairwells. The reason for this is two-fold: 1) Section 7.1.3.2.1(10) of the 2012 Life Safety Code does not permit new penetrations into the exit enclosure that does not serve the exit enclosure (with some exceptions). Many AHJs believe security cameras serve the facility and not just the exit enclosure; and 2) The concept of exit enclosures is to provide a clean environment that is free of any device that does not serve the purpose of the stairwell. The purpose of the stairwell is to evacuate people from the building in the event of an emergency. The security camera does not serve that purpose… a security camera monitors the activity of the people.

Anyway… I’m in favor of security cameras in stairwells, but my opinion does not matter, and many AHJs do not permit them. So, perhaps it would be best to not install them.

Elopement Risk

Q: We have a potential elopement risk at the nursing home where I work. A patient gets into the stairwell and down to the first floor and exits the building. We have an alarm system that alerts us when any door is activated. My question is: Can we install interrupter gates on the second floor leading down to the first to deter elopement risk?

A: I’m not sure what you believe to be an interrupter gate … but they won’t do you any good in restricting egress. By definition, an interrupter gate cannot restrict egress. If you are fully sprinklered, you can install delayed egress locks that will slow down egress for 15 seconds, allowing staff to respond to the local alarm and prevent someone from leaving. For normal egress you can provide authorized people ID badges that can be swiped or read on a card reader bypassing the delayed egress locks. You may even consider specialized protective measure locks as described in section 19.2.2.2.5.2 of the 2012 LSC. They may cost you more, but they are effective for your concern.

Stairwell Fire Rating

Q:  We are being told by our local AHJ that a stairwell in a 2 story building has to be 2-hour fire resistance rated so that it meets the requirements of occupancy separation since one floor is healthcare and one floor is business. Do you agree?
A: Well…. That is a matter of interpretation, and I can understand the logic with the requirement to be 2-hour fire rated. Another way of looking at it is if a stairwell was only one hour fire rated, it would take a fire starting on the 1st floor (business occupancy) one hour to penetrate the stairwell barrier, and then it would take one more hour to penetrate the 2nd floor (healthcare occupancy) which is a total of 2 hours. Personally, I would not buy into that line of thought, and if I were an AHJ, I would not allow a 1-hour fire rated stairwell to separate a business occupancy from a healthcare occupancy. I would require it to be 2-hour rated. But, that’s me. Remember… Every AHJ has the right to interpret the Life Safety Code as they see fit.