Who knows the building code better than me? Need help with commercial egress.

I'm having trouble finding an answer to this...

I am probably asking about the NFPA, but OSHA, IBC, and others are relevant.

This is a building I am responsible for, but was not around when prior renovations were performed.  I can only guess how the renovations were made.

Here's my guess... I suspect the changes were made without the help of an architect, and without permits.   The usage of the space changed, and the occupancy increased, which created a couple problems several years ago.  I am trying to make things right.

The space is an access-controlled office environment with limited access, but occasional customer usage.  It is inside a medical facility that exceeds 100,000 SF.  It is adjacent to a storage area, and separated by a fire wall.  The entire building is protected with sprinklers. 

The area is 1456 SF, but includes 3 private offices.  So, the effective remaining space is 1072 SF of open plan cubicle office, with 17 desks and 7 guest chairs- potential 24 occupants.  It is essentially a large office, shared by up to 24 people.

There is only 1 exit door, which is not marked as an exit.  It is secured with a mag lock, with only 1 method of operation- a green "Push to Exit" button.  The door swings in (toward ingress), and the mag lock has a battery backup.  The furthest desk sits about 48' from the exit from the space (which is still 173' from the nearest buil.ding exit), and has a little circuitous route.

All of the employees who are in the space generally are familiar with it (they would know the exit route), and no customer would ever be inside without accompaniment.  

My confusion is how this would be classified, and how many exits are required.

I think the building is Institutional (some patients can not ambulate without assistance), but there are no overnights.  The actual space in question is a commercial office use, but it is inside the larger medical facility.

If it was a private office with 1 desk, the door could swing in, the exit would not need to be marked, and it would not need a 2nd exit.  But I am thinking because of the number of people, it needs a 2nd exit, and both exits need to be treated as egress routes.

Thoughts?

If I am right, then I need to:

   - Add a 2nd exit

   - Reverse the swing of the existing door to swing in the egress direction

   - Mark the exits appropriately

   - Add a 2nd method of activation for the mag lock activation from the egress side (or switch to electro-mechanical)

   - Remove the battery backup for the mag lock

   - Revise egress route signage to include this area

   - Other?

I know this is the wrong place to ask, but I am trying to address this pre-emptively.  I don't want to make waves with the fire marshal or the CEO, but I also don't want the liability.  I am willing go head-to-head with the CEO to make things right if necessary.

Thanks for your help!

I'll start by saying I'm not a fire marshal, DHEC inspector, or Joint Commission person. Your best bet is to ask them during your next inspection. A quick read gets me this.

Sounds like it would be classified as a suite.

Occupancy under 30 and exit path under 75', and sprinkled building lets you use one exit. That exit can also swing into the area as long as occupancy is less than 50. The door does need to have a lighted exit sign. 

The mag-lock should have two forms of exit. One is required to be a lighted pushbutton adjacent to the door. The other can be a PIR sensor above the door. The mag-lock should also be tied into the fire alarm system to drop the lock incase of a fire. The battery backup shouldn't be a problem.

You may want to spend some time digging through this site. https://idighardware.com/

My specific knowledge is many years out of date, not to mention Canadian, but FWIW I would definitely link the maglock to the fire alarm, even if the Code said I didn't have to.  I also get twitchy about exits that swing in, but you have to keep in mind what you're exiting into, as it were.  If it's the parking lot, go ahead and change the swing without a second thought, but OTOH if it's 300 other people's exit route, then suddenly an inward swing doesn't sound so bad.

As for asking the inspectors, that's absolutely a good idea, but I'd arm myself with what the relevant Code(s) say first.  It is not impossible for inspectors to issue infallible pronouncements from on high that actually conflict with the regulations they're supposed to be enforcing.  Ask me how I know.

Stealthtercel said:

As for asking the inspectors, that's absolutely a good idea, but I'd arm myself with what the relevant Code(s) say first.  It is not impossible for inspectors to issue infallible pronouncements from on high that actually conflict with the regulations they're supposed to be enforcing.  Ask me how I know.

This is fact. Many inspectors do not know the codes themselves and you have to deal with their "interpretation" of the code, which at times can be bizarre. This is doubly true in the case of systems that are not standard. More than once I've had to dig my books out of the truck to read relevant codes to the inspectors. 

Paul:  I am away from my references right now, but you’re probably OK with a single exit based on Business use and occupancy < 50. 

You may need an exit light as well.  These days, exit lights are typically matched with a small floodlight that goes outside the door, so that people aren't exiting into darkness.

Toyman01 said:

I'll start by saying I'm not a fire marshal, DHEC inspector, or Joint Commission person. Your best bet is to ask them during your next inspection. A quick read gets me this.

Sounds like it would be classified as a suite.

Occupancy under 30 and exit path under 75', and sprinkled building lets you use one exit. That exit can also swing into the area as long as occupancy is less than 50. The door does need to have a lighted exit sign. 

The mag-lock should have two forms of exit. One is required to be a lighted pushbutton adjacent to the door. The other can be a PIR sensor above the door. The mag-lock should also be tied into the fire alarm system to drop the lock incase of a fire. The battery backup shouldn't be a problem.

You may want to spend some time digging through this site. https://idighardware.com/

Based on this he is 98' over the limit. 

Duke said:

Paul:  I am away from my references right now, but you’re probably OK with a single exit based on Business use and occupancy < 50. 

Thank you, Duke. I was hoping you’d chime in. 

Is the usage determined by the department, or by the entire building?  If it’s the entire building, it’s Institutional (because of sometimes non-ambulatory patients). But the department in question is Billing- standard business stuff (and no patients with limited mobility). 

TenToeTurbo said:

Toyman01 said:

I'll start by saying I'm not a fire marshal, DHEC inspector, or Joint Commission person. Your best bet is to ask them during your next inspection. A quick read gets me this.

Sounds like it would be classified as a suite.

Occupancy under 30 and exit path under 75', and sprinkled building lets you use one exit. That exit can also swing into the area as long as occupancy is less than 50. The door does need to have a lighted exit sign. 

The mag-lock should have two forms of exit. One is required to be a lighted pushbutton adjacent to the door. The other can be a PIR sensor above the door. The mag-lock should also be tied into the fire alarm system to drop the lock incase of a fire. The battery backup shouldn't be a problem.

You may want to spend some time digging through this site. https://idighardware.com/

Based on this he is 98' over the limit. 

Not sure you’re right on that. 

If it’s classified as a business suite, then the maximum distance to leave the suite is 48’. It would be a suite inside an institutional space. Once you leave the space, you would be in a corridor exit access in an Institutional space. 

But I don’t think buildings can be divided up like that. 

Is the mag lock  a)"fail safe" & b) tied to fire alarm? It should be both because you can't trap occupants when power goes out. And batteries aren't perfect. 

The inswing door and number of doors has been correctly covered already. Not a problem. 

I would add an exit sign above the office suite door AND another immediately outside to point to the exit path.

Your exit path may be too long. Fully sprinklered matters, but I don't know the allowable length without a lookup...

Good on you for making sure it is safe. 

In reply to OHSCrifle :

Technically, all mag locks are fail safe. They can’t fail any other way- they are electro-magnets. 

As I understand it, batteries are technically illegal on a mag lock on an egress door- because they wouldn’t fail. 

In reply to SVreX : That all makes sense.

By my reading of the 2015 IBC:

The suite in question is classified as an unseparated Business occupancy within the larger Institutional use.  The building itself would have to meet I-whatever criteria, but this suite is an incidental Businesss use.  I assume the existing door leads into a corridor or large open-plan space, not another enclosed area.

Occupancy count will be based on 100 gross sf per person for Business.  At approximately 1500 sf, your design occupancy is 15 people.  Actual occupancy is about 25.  Both are  <=49, so you're fine with 1 egress door.

Assuming the building is fully sprinklered, the Common Path of Travel is limited to 100 feet.  That means from the most remote point in the suite, the natural egress path must reach a point where a person has more than one choice in which way to go in less than 100 feet.

Exit access travel is limited to 300 feet for the Business users in a fully sprinklered building.  Within 300 feet, the most remote person in the suite needs to be able to reach the outside, a 1-hour rated enclosure (like a stairwell), or other fire-separated area that leads to an exit.

The dead-end corridor within the suite should be less than 50 feet, for Business use in a sprinklered building.  Your minimum corridor width along this path is 36 inches.

As other have noted, the mag lock needs to be tied into the fire alarm system so it opens as soon as the alarm activates.  Or it needs to be always openable from the suite side.  It may or may not already be on the UPS system, but if it is, it definitely needs the alarm tie-in.

I agree, the egress door should have an illuminated exit sign, and you should probably add some emergency lighting to make sure that the egress path through the whole space is lighted at 1 footcandle (average) for a minimum of 90 minutes in any emergency.  I would consider adding NOT AN EXIT on the outside of the suite door, too, depending on how likely it is to be mistaken for one.

Hope this helps!

A magnetic lock that consists of 1-2 large electromagnets, usually at the top of the door, requires power to stay locked and does technically fail safe (unless it is on the UPS or a battery).

But the term 'mag lock' is sometimes used to describe an electric strike, which is built into the jamb of the door.  These are a solenoid that either throws or releases a clamp that holds the bolt on the door.  They can be configured to either fail safe, or fail secure.  If it's the fail secure type, it needs a mechanical egress device to let it be unlocked from the inside without power or keys.

In reply to Duke :

That’s perfect. Exactly what I needed. 

Thank you!

1 quick question- What’s the difference between design occupancy and actual occupancy?  Does that mean it is over-occupied, or does it basically mean that kind of stuff happens once an occupant lives in, and is therefore expected?

Design occupancy is the absolute minimum number of people the fire marshal will let you get away with claiming the space holds.  So you couldn't say that the 1500 sf suite will only have 4 people in it (3 offices and 1 for the general area).  He's going to say that 1500 sf / 100 sf per person (for Business use) means you need to be able to get no fewer than 15 people out.

There is effectively no difference in your particular case, but it does come into play with larger areas.

Actual occupancy can be whatever the space will safely hold based on how much egress capacity it has.  You're technically also limited to a minimum of 7 sf per person for standing room only.  So if it was an open space for Assembly use, your 1500 sf could hold a maximum of 214 people, which would require 2 ways out.

In reply to Duke :

Gotcha. 

Thanks for the educational lessons. 

Duke said:

A magnetic lock that consists of 1-2 large electromagnets, usually at the top of the door, requires power to stay locked and does technically fail safe (unless it is on the UPS or a battery).

But the term 'mag lock' is sometimes used to describe an electric strike, which is built into the jamb of the door.  These are a solenoid that either throws or releases a clamp that holds the bolt on the door.  They can be configured to either fail safe, or fail secure.  If it's the fail secure type, it needs a mechanical egress device to let it be unlocked from the inside without power or keys.

There are also electro-mechanical panic bars (which are also sometimes erroneously called mag locks). 

In reply to SVreX :

Any time!

We deal with mag-locks and egress all the time and have run into numerous Code officials who don't agree with the "Fail safe" bit and require egress doors to have electric strikes instead.  This becomes a real PITA in cases where the doors are part of airlocks with motorized operators and the mag-locks are used to keep the doors closed due to cascading pressurization. 

I actually have 3 sheets of interlock diagrams to sort through for this for a project that I've been working on... Fortunately, the Arch haven't really finished with the door schedule, which makes my task rather difficult to complete.  I may have to show all of the wiring for the doors, but i'm not the one specifying them.

In reply to Ian F :

They must have missed that class in 2nd grade with wire tied to a 6V battery wrapped around a nail.

In reply to Ian F :

You will run into situations where the door is required to mechanically latch due to it being in a fire or smoke wall. Fire and smoke doors aren't allowed to fail in a unlatched position. It's a common problem I run into when automating doors. 

Row row row your boat gently up 3 years.......