This article will be published in the May 2020 issue of Door Security + Safety

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If a door is part of a required means of egress, it must comply with the requirements of the adopted building code and fire code.  If a door is NOT part of an egress route defined by a facility’s life safety plans, does the opening still have to comply with the code requirements?

When discussing the code requirements for doors, it’s not uncommon for someone to justify a non-code-compliant application by suggesting that the door is not part of a means of egress and therefore does not have to comply with the adopted building code or fire code.  Recently, a question arose regarding a bank of 8 doors serving a school lobby:  Is it acceptable to install the panic hardware required by code on the 4 required exits and install deadbolts on the other 4 doors?

You’ve probably heard of the Duck Test which suggests that something can be identified by its habitual characteristics:  “If it looks like a duck, swims like a duck, and quacks like a duck, then it is probably a duck.”  This test can be applied to doors as well, and there is information in the International Building Code (IBC) and the International Fire Code (IFC) to support this interpretation.

Number of Exits

Requirements for the number of exits are found in Chapter 10 of the IBC and IFC, in a section with the fitting title: “Number of Exits and Exit Access Doorways.”  The required number of exits is determined by the calculated occupant load along with other factors like the common path of egress travel distance.  The use of the space can also affect the number of exits.  For example, boiler, incinerator, furnace, and refrigeration machinery rooms over a certain size are required to have two exits, even though the occupant load of these rooms is typically very low.

For most locations, at least two exits are required where the design occupant load or the common path of egress travel distance exceeds a specified value.  These values are listed in a table that is included in this section of the IBC and IFC.  For many use groups, the second exit is required when the design occupant load exceeds 49 people, but for some use groups, the second exit is required when the occupant load exceeds 3, 10, 20, or 29 people.  The common path of travel and the presence of a sprinkler system also affect the number of exits, so it’s important to reference the code for specifics.

When the design occupant load is 501-1,000 people – 3 exits are required, and when the occupant load is more than 1,000 people the IBC requires 4 exits.  Egress doors must be of sufficient width to accommodate the number of occupants, which is based on a calculation where the number of occupants is multiplied by an egress capacity factor.  This helps to determine the required clear width of the egress doors.

Extra Doors

Based on the previously-referenced section, the IBC and IFC would require between 1 and 4 exits or exit access doorways for an occupant load of 1 to 1,001 people.  However, it is very common to see additional egress doors over and above the minimum required by code, often provided for convenience or aesthetics.  Common sense dictates that these “extra doors” should be code-compliant, because in an emergency a building occupant would head for the nearest door or the door they used to enter the space.  It’s unlikely that they would stop to consider which doors were code-compliant exits, and which doors serve another purpose.

The common-sense approach is consistent with the IBC and IFC requirements.  Regarding doors, gates, and turnstiles, these codes state:

Means of egress doors shall meet the requirements of this section…Doors provided for egress purposes in numbers greater than required by this code shall meet the requirements of this section.

The IBC and IFC Commentary editions help to clarify this further:

A door that is intended to be used for egress purposes, even though that door may not be required by the code, is also required to meet the requirements of this section. An example may be an assembly occupancy where four doors would be required to meet the required capacity of the occupant load. But assume the designer elects to provide six doors for aesthetic reasons or occupant convenience. All six doors must comply with the requirements of this section.

The key here is that the IBC and IFC requirements apply not only to doors that are required for egress but also to doors provided for egress purposes – even if the quantity of doors exceeds the required number of exits.  Going back to the school example – if there is a bank of 8 doors, it’s safe to assume that all 8 are intended to be used for egress – that all of the doors are provided for egress purposes.  In that case, all 8 doors would have to comply with the requirements of the adopted codes, including installation of the panic hardware that is required by the IBC and IFC.  Installing deadbolts on the “extra” doors would not be code-compliant.

In a situation where some doors are provided for egress and others are not intended to be used for egress, it would be up to the code official to decide whether there is a clear difference between the egress doors and the doors that are not provided for egress purposes.  For example, an assembly space might have exterior doors that are not used for egress but will be opened for events – weather permitting – to allow circulation between the indoor and outdoor space.  In order to avoid having panic hardware on these doors in addition to the egress doors, the code official may require a compromise to ensure an acceptable level of life safety.  A different design could be used for each of the two types of doors, so the egress doors are obvious.  In some facilities, doors that are not part of the means of egress may require signage stating, “Not an Exit.”

When you encounter this situation, I would recommend using an adapted version of the Duck Test.  Does it look like a door and swing like a door?  Then the building occupants (and the code official) will probably think it’s a door, and it should operate like doors are supposed to.  Make sure doors required for egress and those provided for egress purposes are code-compliant, to provide the highest level of life safety.

Note:  NFPA 101 – Life Safety Code (LSC) includes language addressing doors that are “required” to serve as an exit.  Interpretations of the LSC and state code modifications may vary from the IBC and IFC requirements.

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