BCAB #1878

February 17, 2022

Re: Exposure Protection for Required Egress Door Exterior Path of Travel

Project description

The project is a sprinklered four storey building of non-combustible construction on a basement storage garage. The first storey contains four commercial suites, a residential lobby, and refuse storage rooms. The second to fourth storeys contain residential suites. The first storey floor area is served by multiple exits.

A commercial suite on the first storey, which is the subject of appeal, has a floor area of approximately 175 m². The suite is provided with two doors which are remote from each other, both of which provide required egress to the exterior, one at the front of the suite and one at the rear. The required exterior door at the front of the suite discharges onto a sidewalk area adjacent a public roadway. The required exterior egress door at the rear of the suite discharges onto an exterior walkway which only allows pedestrians to travel directly past the unprotected window/door openings of an adjacent commercial suite. Exit signs are provided at both doors.

Applicable Code requirements:

The definitions of ‘exit’ and ‘means of egress’ in Sentence 1.4.1.2.(1) of Division A and Sentences 3.2.3.13.(2), 3.3.1.3.(11), and 3.3.1.5.(1) of Division B of the British Columbia Building Code 2018.

Exit means that part of a means of egress, including doorways, that leads from the floor area it serves to a separate building, an open public thoroughfare, or an exterior open space protected from fire exposure from the building and having access to an open public thoroughfare. (See Note A-1.4.1.2.(1).)

Means of egress means a continuous path of travel provided for the escape of persons from any point in a building or contained open space to a separate building, an open public thoroughfare, or an exterior open space protected from fire exposure from the building and having access to an open public thoroughfare. Means of egress includes exits and access to exits.

3.2.3.13.(2) If an unenclosed exterior exit stair or ramp could be exposed to fire from an opening in the exterior wall of the building it serves, the opening in the exterior wall of the building shall be protected in conformance with the requirements of Sentence (4) where the opening in the exterior wall of the building is within 3 m horizontally and

a) less than 10 m below the exit stair or ramp, or

b) less than 5 m above the exit stair or ramp.

3.3.1.3.(11) Except as permitted by Sentences 3.3.4.4.(5) and (6), each suite in a floor area that contains more than one suite shall have

 a) an exterior exit doorway, or

 b) a doorway

 i) into a public corridor, or

 ii) to an exterior passageway.

3.3.1.5.(1) Except for dwelling units, a minimum of 2 egress doorways located so that one doorway could provide egress from the room or suite as required by Article 3.3.1.3. if the other doorway becomes inaccessible to the occupants due to a fire which originates in the room or suite, shall be provided for every room and every suite

a) that is used for a high-hazard industrial occupancy and whose area is more than 15 m²,

b) intended for an occupant load more than 60,

c) in a floor area that is not sprinklered throughout, and

i) the area of a room or suite is more than the value in Table 3.3.1.5.-A, or

ii) the travel distance within the room or suite to the nearest egress doorway is more than the value in Table 3.3.1.5.-A, or

d) in a floor area that is sprinklered throughout and does not contain a high-hazard industrial occupancy and

i) the travel distance to an egress doorway is more than 25 m, or

ii) the area of the room or suite is more than the value in Table 3.3.1.5.-B.

Decision being appealed (local authority’s position)

The local authority has determined the rear exterior egress door serves as also an exit which must include a safe path of travel to a public thoroughfare. This would necessitate protection of the unprotected opening in the adjacent suite which the exit path directly passes by.

Since both exterior doors are provided with exit signage, the local authority considers that in the event of a fire, occupants could use the rear door and may not be able to proceed beyond the unprotected opening of the adjacent suite if the fire were to originate in the adjacent suite.

Appellant's position

The appellant does not consider the egress door required at the rear of the suite to be an exit doorway as required by Sentence 3.3.1.3.(11) and is not subject to the protection requirements of exterior exit facilities as described in Sentence 3.3.1.13.(2).

Rather, the appellant considers the rear egress door is provided to address the specific conditions of Sentence 3.3.1.5.(1).

Appeal Board decision #1878

It is the determination of the Board that the required rear exterior door provided to meet the requirements of Sentence 3.3.1.5.(1) is part of a means of egress which is required to be protected from fire exposure from the building, which includes the unprotected window/door openings of the adjacent commercial suite.

Reason for decision

The door and walkway are part of the required means of egress which provide a continuous path of travel for the escape of persons from any point in the building to an exterior open space protected from fire exposure from the building and having access to an open public thoroughfare.

Doug Vance

Chair (Acting), Building Code Appeal Board