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Accessible Means of Egress and the ADA

Accessible Means of Egress

Accessible Means of Egress

Egress is defined as the action of going out of or leaving a place. 2010 ADA Standard 106.5, defines Accessible Means of Egress as “A continuous and unobstructed way of egress travel from any point in a building or facility that provides an accessible route to an area of refuge, a horizontal exit, or a public way.” In other words, a means of egress is an unobstructed path to leave buildings, structures, and spaces that is comprised of exit access, exit, and exit discharge. The graphic on the right is representative of an accessible means of egress.

An accessible means of egress is a critical component of any facility that requires compliance with the Americans with Disabilities Act (ADA). This article explains requirements in the 2010 ADA Standards and referenced sections of the International Building Code (IBC) for an accessible means of egress.

2010 ADA Standard 207.1, [Accessible Means of Egress] General, states, “Means of egress shall comply with section 1003.2.13 of the International Building Code (2000 edition and 2001 Supplement) or section 1007 of the International Building Code (2003 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1).” In other words, the ADA requires a means of egress because the IBC requires it. There is one exception to this Standard where an accessible means of egress is permitted to share a common path of egress travel.

2010 ADA Standard Advisory 105.2.4, ICC/IBC, states, “International Building Code (IBC)-2000 (including 2001 Supplement to the International Codes) and IBC-2003 are referenced for means of egress, areas of refuge, and railings provided on fishing piers and platforms. At least one accessible means of egress is required for every accessible space and at least two accessible means of egress are required where more than one means of egress is required. The technical criteria for accessible means of egress allow the use of exit stairways and evacuation elevators when provided in conjunction with horizontal exits or areas of refuge. While typical elevators are not designed to be used during an emergency evacuation, evacuation elevators are designed with standby power and other features according to the elevator safety standard and can be used for the evacuation of individuals with disabilities. The IBC also provides requirements for areas of refuge, which are fire-rated spaces on levels above or below the exit discharge levels where people unable to use stairs can go to register a call for assistance and wait for evacuation.”

The three (3) main parts of an accessible means of egress (exit access, exits, and exit discharge) are discussed below.

EXIT ACCESS

An exit access is a route or path that leads (provides access) to an accessible exit.

The IBC requires at least two means of egress from all spaces and buildings with few exceptions. Some spaces and buildings are allowed to have one means of egress if the travel distance to an exit is short and the occupant load is low. Occupant load is defined in the 2010 ADA Standards as “The number of persons for which the means of egress of a building or portion of a building is designed.” For example, a business occupancy with no more than 30 occupant load and a maximum exit access travel distance of 75 feet is permitted to have a single means of egress. More than two means of egress are required where the occupant load is 500 or more (at least 3) and 1,000 or more (at least 4). The IBC requirements for accessible means of egress apply to new construction; accessible means of egress are not required to be added in alterations to existing facilities.

Where more than one means of egress is required from any accessible space, each accessible portion of the space must be served by at least two accessible means of egress. Accessible spaces can be served by one accessible means of egress only where the IBC permits one means of egress. The graphic below is representative of a space that has two accessible means of egress.

Two Egress Paths from an Accessible Space

Two Egress Paths from an Accessible Space

The IBC (2003) permits one accessible means of egress from:

  • wheelchair seating in assembly areas with sloped floors where the common path of travel meets aisle requirements for assembly areas and,

  • mezzanines served by an enclosed exit stairway or elevator equipped with standby power.

In buildings with multiple floors, on floors above or below the level of exit discharge to the exterior, accessible means of egress must lead to exit stairways, horizontal exits, or to elevators equipped with standby power [IBC §1007.1 (2003), §1003.2.13 (2000)]. The graphic below is representative.

Egress from Multi-Floor Building using Stairs

Egress from Multi-Floor Building using Stairs

In buildings with four or more stories above or below the level of exit discharge, at least one accessible means of egress must be an elevator with standby power and emergency signaling devices [IBC §1007.4 (2003), §1003.2.13.3 (2000)]. The graphic below is representative.

Multi-Story Building with Egress Using Stairs and Standby Powered Elevator

Multi-Story Building with Egress Using Stairs and Standby Powered Elevator

In sprinklered buildings, an elevator with standby power is not required on floors with either a:

  • horizontal exit (excluding floors below the level of exit discharge)

  • a compliant exit access ramp

Horizontal Exit

A horizontal exit is a unique installation specifically for egress from a fire. IBC §1021 (2003), §1005.3.5 (2000) explains that a horizontal exit compartmentalizes a building allowing occupants to exit the area containing the origin of a fire into another portion of the building that is protected by fire-resistance-rated assemblies (doors, walls, ceilings, and floors). A horizontal exit separates a space into two exit access areas. IBC requirements for horizontal exits address fire-rated separation, opening protectives, capacity, and other features. The graphic below is representative of a building floor with horizontal exits.

Horizontal Exits

Horizontal Exits

Components of a space with horizontal exits includes:

  • Compliant fire wall or barrier with a 2 hour min. fire-resistance rating

  • No connecting ductwork or utilities between areas

  • Compliant opening protectives, including self-closing or automatic closing fire doors

  • No more than half the required exits can be horizontal exits.

  • At least one exit must lead directly to an exit enclosure or to the exterior

Horizontal exits can substitute for interior areas of refuge, which will be discussed below.

EXITS

The exit access routes lead us to the exits, where we may find doors to the outside, enclosed exit stairways, horizontal exits, or areas of refuge, all of which will eventually lead to the exit discharge route(s).

Egress Doors

For manual doors, the IBC covers doors and gates serving means of egress in §1008 (2003), §1003.3.1 (2000). The ADA Standards permit fire doors to have the minimum opening force specified by the applicable life safety code instead of the 5 pounds maximum otherwise specified for interior hinged doors (2010 ADA Standard 404.2.9). The graphic below is representative of a manual door.

Manual Egress Door

Manual Egress Door

For automated doors, maneuvering clearance is required on the egress side of automated doors unless they are equipped with standby power or they stay open in power-off mode (2010 ADA Standard 404.3.2). The standards also require a minimum 32 inch break out opening for doors unless equipped with standby power or a compliant manual swinging door also serves the same means of egress (2010 ADA Standard 404.3.6). The graphic below is representative of an automated door.

Automated Door with Breakout Opening

Automated Door with Breakout Opening

Stairways

Stairways and handrails that are part of a means of egress are addressed by the IBC §1009 (2003), §1003.3.3 (2000). In addition, interior and exterior stairs that are part of a means of egress must comply with requirements in 2010 ADA Standards 210 and 504.

In alterations, stairs between levels that are connected by an accessible route (e.g., ramp or elevator) are not required to meet the ADA Standards, but handrails must comply when the stairs are altered (2010 ADA Standard 210.1, Ex. 2). In other words, if you renovate or remodel a staircase, you don’t have to make the stairs compliant but you always have to make the handrails compliant. But, if you install new stairs, then the new stairs and the handrails have to be compliant.

Interior Area of Refuge

An interior area of refuge is usually found beyond the interior manual egress door discussed above and at a landing of a stair system. Areas of refuge are fire-resistance rated and smoke protected areas where those unable to use stairs can register a call for evacuation assistance and await instructions or assistance. Horizontal exits can substitute for areas of refuge.

For buildings not equipped with a supervised fire suppression sprinkler system, area(s) of refuge should be provided. These areas of refuge must provide direct access to exit stairways and can be located adjacent to stairway enclosures or on stair landings outside the minimum exit width. The graphic below shows where the interior areas of refuge can be located.

Areas of Refuge for Exit Staircases

Areas of Refuge for Exit Staircases

Components of an interior area of refuge are shown below.

Components of an Interior Area of Refuge

Components of an Interior Area of Refuge

Interior areas of refuge are not required in open parking garages, apartment buildings, detention and correctional facilities, or open exit stairways between floors in buildings with sprinkler systems meeting the NFPA 13 Standard.

EXIT DISCHARGE

In the comments above we have gone from the exit access, to the exits, and now we move outside to the exit discharge routes, the last leg in egress. An exit discharge is a path from an exit to a public way such as a street or alley.

In the first paragraph of this article Accessible Means of Egress was defined as “A continuous and unobstructed way of egress travel from any point in a building or facility that provides an accessible route to an area of refuge, a horizontal exit, or a public way”. Horizontal exits and areas of refuge were discussed above. So now we will review an exterior public way including an exterior area for assisted rescue.

Public Way

The 2010 ADA Standards defines public way as “Any street, alley or other parcel of land open to the outside air leading to a public street, which has been deeded, dedicated or otherwise permanently appropriated to the public for public use and which has a clear width and height of not less than 10 feet (3050 mm).”

An accessible means of egress must connect exits to an exit discharge at a public way. In other words, in most cases, the exit discharge cannot stop just outside the building. There should be an accessible route away from the building to an alley, walkway, vehicular way, or parking area that leads to a public street. The graphic below is representative.

Egress Exit Discharge to Public Space

Egress Exit Discharge to Public Space

Steep terrain and other constraints can make it difficult to provide an accessible means of egress from building exits to a public way. The IBC permits an exterior area for assisted rescue, a protected area immediately outside a building exit, where a connecting accessible route to a public way from the level of exit discharge is not practicable. Alternatively, an interior area of refuge can be provided at exits. When used as an alternative to an accessible route from exit discharge to a public way, they must be provided, including in buildings that are sprinklered.

Exterior Area for Assisted Rescue

An exterior area for assisted rescue is similar to an interior area of refuge with some obvious differences. An exterior area for assisted rescue is shown below at an exterior door that has a stair system in the path of travel, or egress route.

Exterior Area of Refuge

Exterior Area of Refuge

At the exterior area for assisted rescue, the following components are required:

  • Openness: The area of refuge must be at least 50% open to minimize accumulation of smoke or toxic gases.

  • Fire-rated Separation Wall: One hour min. fire-rated separation within 10’ (horizontal and vertical) of the exterior area of assisted rescue (3/4 hour rating for opening protectives within this area).

  • Exterior Exit Stairway: Clear width between handrails of 48” minimum to accommodate assisted evacuation. Handrails and stair dimensions should also be ADA compliant.

  • Wheelchair Space: Clear space (30” min. by 48” min.) for every 200 occupants or portion thereof served by the exterior area for assisted rescue. Spaces cannot reduce the required egress width and must be entered directly from an accessible route or one adjacent wheelchair space.

  • Identification: Visual and tactile sign stating “AREA OF REFUGE” with International Symbol of Accessibility located at door (interior side) leading to exterior area for assisted rescue.

Again, if possible, the exterior exit discharge should not stop just outside the building. Depending on the circumstances of the need for egress, individuals may want to move farther away from the facility to safety. Creating exterior exit discharge routes via exterior alleys, walkways, vehicular ways, or parking areas that lead to a public street will provide disabled individuals a complete accessible means of egress to safety.

Area of Refuge Sign.jpg

SIGNAGE

Incorporated in all this is a significant requirement for signage to identify the components of the accessible means of egress. The graphic on the right is representative of one sign. Signage is covered in the 2010 ADA Standard 216.4, [Signs] Means of Egress, and Standard 703. The IBC covers signage in sections 1003.2.13 of the International Building Code (2000 edition) or section 1007 of the International Building Code (2003 edition).

SUMMARY

In summary, the IBC and ADA requirements for accessible means of egress apply to new construction. Accessible means of egress are not required to be added in alterations to existing facilities. Areas of refuge are not required if the facility has a supervised fire suppression sprinkler system. These limitations do not prevent a building owner or operator from installing an accessible means of egress and areas of refuge if they prefer. If the facility does have a means of egress and/or area of refuge, they should comply with the ADA/IBC Standards.

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If you observe a facility that is not ADA compliant and you would like to know how to proceed, please see the link at What To Do When A Building Is Not ADA Compliant or Accessible.

ADA Inspections Nationwide, LLC, offers ADA/ABA/FHA accessibility compliance inspections for buildings and facilities, as applicable to the different laws, and expert witness services with respect to ADA/ABA/FHA laws for building owners, tenants and managers. Also, ADAIN offers consulting for home modifications as a CAPS consultant for people wishing to age in place in their homes. For a complete list of services please see ADAIN Services.

Thank you.