Storage in Stairwells

Q: Is there any specific regulation that addresses storing items under stairwells and if so does it differentiate between public stairs and stairs which are utilized to access areas not open to the public?

A: Yes, section 7.2.2.5.3 of the 2000 edition of the Life Safety Code specifically says there must be no enclosed, usable space within an exit enclosure, including under stairs, nor shall any open space within the enclosure be used for any purpose that has the potential to interfere with egress. There is an exception that says enclosed usable space is permitted under the stairs, provided that the space is separated from the stair enclosure by the same fire resistance as the exit enclosure, and entrance to that enclosed usable space is not from within the stair enclosure. The common conclusion of this (and other sections) is general storage is prohibited in stairwells. The concept of an exit enclosure is to provide an egress environment which is sterile from safety hazards. It is recognized that general storage usually ends up (or has the potential of) being a hazardous area, and exiting through a hazardous area is not permitted. From that point of view, this makes perfect sense. However, the LSC does not prohibit safety items stored in the stairwell as long as they do not interfere with the egress. As mentioned in a posting on March 2,  evacuation chairs stored at the top of the stairwell could be considered to not interfere with egress.  Hospitals have such a difficult time finding adequate useful storage space I believe a safety item (such as patient evacuation chairs) should be permitted inside an exit enclosure provided it does not interfere with egress in any way.

Stairwell Signage

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 7.2.2.5.4:

 

  • 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.

 

Items Stored in a Stairwell

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 7.2.2.5.3 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 (7.1.3.2.3 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 7.1.3.2.3 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 7.1.3.2.3 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.

Stairwell Interruption Gates

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.

Card Readers on Door Locks

Q: During a recent survey, the surveyor said a card reader on the stairwell door cannot be located on an adjacent wall or door frame, but it must be an integral part of the lockset itself. Is this true? They were talking about card readers on the stairwell side for re-entry to a floor.

A: Did the surveyor cite you for non-compliance? If not, surveyors sometimes say things that are misunderstood, especially if there is no citation. Doors not in the path of egress are permitted to be locked, and a re-entry door from a stairwell usually is not in the path of egress. As long as the re-entry door in the stairwell is not in the path of egress then I do not see any reason that what you describe would be a problem. The Life Safety Code would allow for a card reader device to unlock a stairwell re-entry door as long as the door is not in the path of egress.  If the card reader is mounted in the stairwell on the door leading to a floor of the building (not a discharge door), then the card reader is not on the egress side of the door. There is nothing in the Life Safety Code, or in NFPA 80 Standard for Fire Doors and Fire Windows, (1999 edition) that would require the card reader to be mounted on the door leaf, rather than the on the wall near the door. Therefore, it is clear that the LSC permits card-access readers to be mounted on the wall near the door, since it is not a device or motion to operate the door. I cannot think of any situation that would require the card-access reader to be mounted on the door leaf, itself.

Evacuation Chairs

Q: Can evacuation chairs be installed in stairwells?

A: The answer is… maybe yes and maybe no. Sorry, that’s not a direct answer, so please allow me to explain. Section 7.2.2.5.3 of the 2000 edition of the Life Safety Code says: “There shall be no enclosed, usable space within an exit enclosure, including under stairs, nor shall any open space within the enclosure be used for any purpose that has the potential to interfere with egress.” So, if we take the latter half of this requirement, it says we cannot place anything in the stairwell that could interfere with egress. Would hanging an evacuation chair on the inside wall of a stairwell interfere with egress? This is a question that is not directly addressed by NFPA, so that means the authorities having jurisdiction (AHJ) get to make that interpretation. My experience with many AHJs is they do not want anything hung on the wall on the inside of a stairwell where it could be an obstruction to those individuals trying to egress down the stairs. That means to me, that you would NOT be able to hang these evacuation chairs anywhere in the path of egress inside the stairs, no matter how wide those stairs are. However, not all is lost. If there is a landing at the very top of the stairwell that is open and not used as part of the path of egress, and there is no other items on the walls around this landing, such as a fire hose cabinet or fire extinguisher, then I could see that area being used successfully to hang an evacuation chair. The downside of this is the arrangement only seems to apply to the very top of the stairwell, and if you wanted to hang evacuation chairs on every landing in the stairwell, I don’t believe you would be able. Something else to think about: Even if one AHJ says it is okay to hang evacuation chairs inside the stairwell on every landing, I strongly suggest you do not do it. You may have as many as 5 or 6 AHJs that inspect your hospital for compliance with the Life Safety Code. Just because one AHJ says it is okay that does not mean all of the other AHJs have to abide by that decision.

Stairwell Identification Signs

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 7.2.2.5.4 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 7.2.2.5.4 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.

Stairwell Re-Entry Signage

Q: In regards to stairwell signage, when you have restrictive access back into the building from a stairwell in accordance with section 7.2.1.5.2 of the NFPA 101 Life Safety Code, should the signs indicate the status of the doors (locked or unlocked) during normal building conditions or when the building is in alarm.

A: I understand your question, but I am not sure I understand your motive. Is it your position that you desire to have stairwell re-entry in your hospital, or is it your position that you do NOT want stairwell re-entry at your hospital? To answer your direct question, I would say the stairwell signage referred to in 7.2.1.5.2, Exception 1 (d) and (e) should identify the stairwell door that allows re-entry when the building fire alarm system is in alarm. But section 19.2.2.2.8 says existing hospital are exempt from complying with 7.2.1.5.2 and the Annex section of 19.2.2.2.8 says doors in the stairwell should allow re-entry at not less than every third floor.  So I see the following points made here:

  1. Doors in a stairwell serving 3 or more stories have to allow re-entry, or have automatic unlocking devices tied to the fire alarm system (7.2.1.5.2)
  2. Existing healthcare occupancies are exempt from the mandatory re-entry requirement in 7.2.1.5.2 (19.2.2.2.8), which means you can lock the doors and prevent re-entry
  3. A suggestion (recommendation) is made that if you choose not to be exempt from 7.2.1.5.2 and you want to prevent re-entry, then at the very least the stairwell door should allow re-entry at every third floor (A.19.2.2.2.8)

So, if you want to prevent re-entry, then I’d suggest you follow the recommendation in A.19.2.2.2.8 and provide automatic unlocking on the stairwell doors at every third floor .If you want to allow re-entry then I don’t see any problem to simply allow it without any locks on the stairwell doors or any automatic releasing devices.

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.

Stairwell Interruption Gates

Q: I read an article were an interruption gate is required in a stairwell to prevent people from traveling past the floor where they should exit. Is this a requirement of the Life Safety Code, and if so, do we have to install a gate, or can we install a chain across the path instead?

A: The requirement for a means to interrupt the flow of traffic in a stairwell is found in section 7.7.3 of the 2000 edition of the Life Safety Code. The code itself says stairs that continue more than ½ story beyond the level of exit discharge must have a means to interrupt the traffic flow such as a partition, door, or “other effective means”. The reason for this interruption is to prevent people from exiting further down the stairs in an emergency and missing the door to the exit discharge. Signs alone are proven not to be an effective means, but since the code is not prescriptive in saying what you must have, then the local authority having jurisdiction (AHJ) is the judge of what is allowed. Metal tube gates that swing in the direction of egress for people traveling up the stairs is the most common type of interruption device. A chain doesn’t sound like an “effective means” to me, as it may not be easily noticed by people exiting down the stairs in an emergency and may become a tripping hazard. Also, if the chain is latched then it would not open in the direction of egress for those individuals traveling up the stairs.

Whatever device you choose, have your local AHJ approve it.