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.

Interior Stairwell Discharge

Q: In my hospital, I have an exit stairwell that does not discharge to the outside of the building, but rather it terminates in a corridor inside the building. Is this permitted? Are the corridor walls required to meet a certain fire rating from the stairs to the outside of the building?

A: The answer depends on certain design and construction requirements of your building.  Section 7.7.2 of the Life Safety Code (LSC) allows for a stairwell to terminate inside the building, as long as it meets certain requirements. Not more than 50% of the required number of exits, and not more than 50% of the required egress capacity is allowed to discharge on the level of exit discharge. The interior stairwell discharge must lead to a free and unobstructed way to the exterior of the building. The corridor wall construction does not have to meet any special fire rating other than that which would be considered normal for the corridor. The path to the exterior must be readily visible and identifiable from the discharge of the interior stairwell. The level of discharge must be protected by automatic sprinklers, or the portion of the level of discharge used for exiting must be protected with automatic sprinklers and be separated from the rest of the non-sprinklered portion of the level by wall construction having the same fire rating as the stairwell. The entire area on the level of discharge must be separated from the level below with fire rating equal to that required for the exit enclosure. This is a tricky one. The organization needs to know what their Construction Type and fire rating is in order to be sure the fire rating of the floor assembly on the level of discharge meets or exceeds the fire rating for the stair enclosure. Another option is the stairwell is permitted to discharge into a 10 foot x 30 foot vestibule as long as the vestibule is separated from the rest of the building by smoke resistant construction. There are other exceptions listed under section 7.7.2 that you may want to review to see if you qualify for them.

If the interior stairwell cannot meet the requirements outlined above, then an exit passageway may be an option, although it is a bit more restrictive. Section 7.2.6 of the LSC explains the requirements for an exit passageway, which is a horizontal means of travel that is protected from fire in a manner similar to an enclosed exit stair. An exit passageway is in fact an exit: It’s just a continuation of the stairwell to the exterior discharge of the building. In order to utilize the exit passageway, the wall construction must meet the same fire rating as the stairwell it serves. All openings (doors) in the passageway must meet the same requirements as that of the stairwell it serves. Door hold-open devices are permitted as long as they all release on a fire alarm signal. The width of the exit passageway must be adequate to accommodate the aggregate required capacity of all exits that discharge through it.

These are the two most common options for a stairwell that has its discharge on the interior of the hospital. The fire rating on the corridor walls is dependent on which option you comply with.

Time Clock in an Exit Stairwell

Q: Is it permitted to have a time clock in an exit stairwell of a hospital? My VP of Operations wants to install time recording stations in stairwells where employees will have to record their time. Our hospital is over 30 years old and is fully sprinklered.

A: Section 19.2.1 of the Life Safety Code (LSC) 2000 edition refers to Chapter 7 for means of egress requirements. Section 7.1.3.2.1(e) prohibits penetrations and opening into an exit enclosure (stairwell) unless it serves the stairwell. The addition of new time clocks would not meet the definition of “serving the stairwell”.  If electrical cable, wires or conduit is needed to operate the time clock, then this section alones prohibits you from installing it in the stairwell.

If the time clock is a wire-less device then section 7.2.2.5.3 states that no open space within the stair enclosure may be used for any purpose that has the potential to interfere with egress. The annex section of the LSC explains an example of interference with egress is storage. Here is one way to look at this: If a person is inside the stairwell and standing in front of the time clock attempting to “punch” in or out, and it interferes with another person trying to exit, then that interferes with egress, and the time clock would not be permitted. This is basically a judgment call as to whether or not the time clock is interfering with egress, but the Authority Having Jurisdiction (AHJ) is ultimately the one who makes this decision. I suggest that you take a conservative approach on this issue. Discuss it with your local AHJ and your safety committee for their opinions.

Interior Discharging Stairwells

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.