This post was printed in the November 2011 issue of Doors & Hardware
Updated August 2017
I continuously receive questions regarding roof doors – specifically whether free access is required from the stairwell to the roof, and whether free egress is required from the roof to the stairwell. The codes don’t address roof doors in detail so some interpretation is necessary, and in some jurisdictions the code officials have preferences that are beyond what the codes require. I have spoken to quite a few code officials about their requirements for roof doors, but it’s important to be aware of any special requirements for your project’s location.
First, the question of free access to the roof. By “free access,” I mean that any building occupant can move freely from the stairwell to the roof without a key, tool, or special knowledge or effort. Hollywood has taught us that in a fire we can just head out to the roof and wait for the helicopter to arrive, but this isn’t based on reality. Neither the International Building Code (IBC) nor the Life Safety Code (NFPA 101) typically require free access to the roof, and the false belief that building occupants can find safety by reaching the roof has lead to injury and death. There is evidence that during the events of 9/11, several hundred occupants of the World Trade Center headed for the roof and perished in the stairwells. In a 2010 fire in Boston, a resident was found on the stairwell side of the locked roof door, unable to reach fresh air and relative safety. She was resuscitated and she survived.
In the case of the Boston fire, the media focused on the fact that the roof “fire door” was locked. I spoke to several code officials in Boston and other cities around the country, and confirmed that free access to the roof is not required by code, and there are compelling reasons that free access to the roof is not desired. If building occupants are allowed free access to the roof, an increase in accidental falls, attempted suicides, and vandalism will increase. Some code officials indicated a preference for fail safe locks on the roof doors which unlock upon fire alarm to allow access to the roof, but this is not currently a requirement of the IBC or NFPA 101.
Whether a roof door is required to provide free egress from the roof depends on what the roof is used for. We can separate roofs into two general types – occupied roofs including roof gardens and rooftop assembly spaces, and unoccupied roofs which contain mechanical equipment and would be occupied at limited times for equipment maintenance and repair. The majority of roofs fall into the second category. Although the preference from a life-safety standpoint would be to always allow free egress from the roof, security concerns can sometimes drive the need to lock the door from the roof to the stairwell to prevent unauthorized access to the building. Both the IBC and NFPA 101 seem to support the option of locking these doors on the roof side:
NFPA 101 – 2006, 2009: 184.108.40.206.8; NFPA 101 – 2012, 2015: 220.127.116.11.9
If a stair enclosure allows access to the roof of the building, the door to the roof either shall be kept locked or shall allow re-entry from the roof.
IBC – 2003, 2006: 1018.1; IBC – 2009, 2012: 1021.1
… For the purposes of this chapter, occupied roofs shall be provided with exits as required for stories. The required number of exits from any story, basement or individual space shall be maintained until arrival at grade or the public way.
IBC – 2015: 1006.3
Egress from stories or occupied roofs. The means of egress system serving any story or occupied roof shall be provided with the number of exits or access to exits based on the aggregate occupant load served in accordance with this section.
Paragraph 18.104.22.168.8/9 from NFPA 101 says that roof doors have to EITHER allow free egress from the roof, OR be kept locked. I interpret this to mean that if the door is locked on the stair side preventing free access to the roof, it does not need to provide free egress from the roof. The IBC addresses occupied roofs, requiring the doors to meet the same requirements as other egress doors, but does not address unoccupied roofs. This is typically interpreted to mean that the door to an unoccupied roof can be locked on both sides. If acceptable to the code official, I recommend a double-cylinder deadbolt for this application, so the door doesn’t automatically lock behind the technician as he or she gains access to the roof.
As stated above, the IBC requires occupied roofs to be “provided with exits as required for stories.” For example, if a roof deck is classified as an Assembly use group, the same quantity of exits and the same hardware must be provided as if the space was not located on the roof but elsewhere in the building. This would obviously require free egress from the occupied roof, including panic hardware if the occupant load was more than 50 or 100 depending on which code was in use. The photo above is a rooftop garden in a hospital (my daughter is the tiny person in red), which had two egress doors providing free egress from the roof into the building. If greater security is needed for occupied roof doors, it would have to be provided by the use of alarms, or delayed egress locks if allowed by code (Note: The IBC does not allow delayed egress on Assembly occupancies).
In summary, free access to the roof from the stairwell is not required by the IBC or NFPA 101, but may be required or preferred by the local code official. Free egress from the roof to the stairwell is required for occupied roofs, but is not mandated by the IBC or NFPA 101 for unoccupied roofs. There may, however, be a local requirement for free egress from unoccupied roofs so it’s best to check with the local code official. For locking an unoccupied roof door when acceptable to the code official, a double cylinder deadbolt can avoid accidental lockouts. If the door to the unoccupied roof is fire rated, a passage latch is required in addition to the deadbolt, and can be combined into one mortise lockset. This is a good compromise between life safety and security that is also code-compliant, unless prohibited by the local code official. If the code official requires fail safe locking to allow egress and/or access during an emergency, a fail safe electrified lockset with remote release can be used.