BCAB #1898

October 20, 2022

Re: Application of Intent Statements to Exit Requirements

Project Description

The subject building is a firehall, two storeys in building height. The upper storey is provided with two exits, configured as shown in the plan below. [Methods of determining travel distance are outside of the scope of this appeal.]

Applicable Code requirements: (BCBC 2018)

Div. A

1.2.1.1. Compliance with this Code

1) Compliance with this Code shall be achieved by

a) complying with the applicable acceptable solutions in Division B (see Note A-1.2.1.1.(1)(a)), or

A-1.2.1.1.(1)(a) Code Compliance via Acceptable Solutions.

If a building design (e.g. material, component, assembly or system) can be shown to meet all provisions of the applicable acceptable solutions in Division B (e.g. it complies with the applicable provisions of a referenced standard), it is deemed to have satisfied the objectives and functional statements linked to those provisions and thus to have complied with that part of the Code. In fact, if it can be determined that a design meets all the applicable acceptable.

Div. B

3.4.2.1. Minimum Number of Exits

1) Except as permitted by Sentences (2) to (4), every floor area intended for occupancy shall be served by at least 2 exits.

Intent Statements for Sentence 3.4.2.1.(1).

Intent 1:

To limit the probability that persons will not have a choice of an alternative exit in the event that one exit is blocked or obstructed in an emergency situation, which could lead to delays in the evacuation or movement of persons to a safe place, which could lead to harm to persons.

Intent 2:

To limit the probability that emergency responders will not have a choice of an alternative exit in the event that one exit is blocked or obstructed in an emergency situation, which could lead to emergency responders being delayed in gaining access to a floor area, which could lead to delays or ineffectiveness in emergency response operations, which could lead to delays in the evacuation or movement of persons to a safe place, which could lead to harm to persons.

Decision being appealed (local authority’s position)

The local authority does not consider the exiting system for the second storey to be Building Code compliant, as it does not meet the intent statements attributed to Sentence 3.4.2.1.(1). The local authority considers the interior exit stair at the second floor could be blocked by fire or other emergency, leaving no access to the second required exit.

Appellant's position

The appellant considers the subject exiting system complies with the applicable acceptable solutions of the Code.

Appeal Board decision #1898

It is the determination of the Board that the subject exiting system complies with the applicable acceptable solutions of the Code, and meets the attributed intent statements.

Reason for decision

The board considers the acceptable solutions as the usual means to meet the applicable intent statement[s]. In this case the Board considers that the intent has been satisfied by compliance with the acceptable solutions.    

Lyle Kuhnert
Chair, Building Code Appeal Board