Q: Is it permitted to have a time clock in an exit stairwell of a hospital? My VP of Operations wants to install time recording stations in stairwells where employees will have to record their time. Our hospital is over 30 years old and is fully sprinklered.

A: Section 19.2.1 of the Life Safety Code (LSC) 2000 edition refers to Chapter 7 for means of egress requirements. Section 7.1.3.2.1(e) prohibits penetrations and opening into an exit enclosure (stairwell) unless it serves the stairwell. The addition of new time clocks would not meet the definition of “serving the stairwell”.  If electrical cable, wires or conduit is needed to operate the time clock, then this section alones prohibits you from installing it in the stairwell.

If the time clock is a wire-less device then section 7.2.2.5.3 states that no open space within the stair enclosure may be used for any purpose that has the potential to interfere with egress. The annex section of the LSC explains an example of interference with egress is storage. Here is one way to look at this: If a person is inside the stairwell and standing in front of the time clock attempting to “punch” in or out, and it interferes with another person trying to exit, then that interferes with egress, and the time clock would not be permitted. This is basically a judgment call as to whether or not the time clock is interfering with egress, but the Authority Having Jurisdiction (AHJ) is ultimately the one who makes this decision. I suggest that you take a conservative approach on this issue. Discuss it with your local AHJ and your safety committee for their opinions.

Q: In my hospital, I have an exit stairwell that does not discharge to the outside of the building, but rather it terminates in a corridor inside the building. Is this permitted? Are the corridor walls required to meet a certain fire rating from the stairs to the outside of the building?

A: The answer depends on certain design and construction requirements of your building.  Section 7.7.2 of the Life Safety Code (LSC) allows for a stairwell to terminate inside the building, as long as it meets certain requirements. Not more than 50% of the required number of exits, and not more than 50% of the required egress capacity is allowed to discharge on the level of exit discharge. The interior stairwell discharge must lead to a free and unobstructed way to the exterior of the building. The corridor wall construction does not have to meet any special fire rating other than that which would be considered normal for the corridor. The path to the exterior must be readily visible and identifiable from the discharge of the interior stairwell. The level of discharge must be protected by automatic sprinklers, or the portion of the level of discharge used for exiting must be protected with automatic sprinklers and be separated from the rest of the non-sprinklered portion of the level by wall construction having the same fire rating as the stairwell. The entire area on the level of discharge must be separated from the level below with fire rating equal to that required for the exit enclosure. This is a tricky one. The organization needs to know what their Construction Type and fire rating is in order to be sure the fire rating of the floor assembly on the level of discharge meets or exceeds the fire rating for the stair enclosure. Another option is the stairwell is permitted to discharge into a 10 foot x 30 foot vestibule as long as the vestibule is separated from the rest of the building by smoke resistant construction. There are other exceptions listed under section 7.7.2 that you may want to review to see if you qualify for them.

If the interior stairwell cannot meet the requirements outlined above, then an exit passageway may be an option, although it is a bit more restrictive. Section 7.2.6 of the LSC explains the requirements for an exit passageway, which is a horizontal means of travel that is protected from fire in a manner similar to an enclosed exit stair. An exit passageway is in fact an exit: It’s just a continuation of the stairwell to the exterior discharge of the building. In order to utilize the exit passageway, the wall construction must meet the same fire rating as the stairwell it serves. All openings (doors) in the passageway must meet the same requirements as that of the stairwell it serves. Door hold-open devices are permitted as long as they all release on a fire alarm signal. The width of the exit passageway must be adequate to accommodate the aggregate required capacity of all exits that discharge through it.

These are the two most common options for a stairwell that has its discharge on the interior of the hospital. The fire rating on the corridor walls is dependent on which option you comply with.

Q: I read an article were an interruption gate is required in a stairwell to prevent people from traveling past the floor where they should exit. Is this a requirement of the Life Safety Code, and if so, do we have to install a gate, or can we install a chain across the path instead?

A: The requirement for a means to interrupt the flow of traffic in a stairwell is found in section 7.7.3 of the 2000 edition of the Life Safety Code. The code itself says stairs that continue more than ½ story beyond the level of exit discharge must have a means to interrupt the traffic flow such as a partition, door, or “other effective means”. The reason for this interruption is to prevent people from exiting further down the stairs in an emergency and missing the door to the exit discharge. Signs alone are proven not to be an effective means, but since the code is not prescriptive in saying what you must have, then the local authority having jurisdiction (AHJ) is the judge of what is allowed. Metal tube gates that swing in the direction of egress for people traveling up the stairs is the most common type of interruption device. A chain doesn’t sound like an “effective means” to me, as it may not be easily noticed by people exiting down the stairs in an emergency and may become a tripping hazard. Also, if the chain is latched then it would not open in the direction of egress for those individuals traveling up the stairs.

Whatever device you choose, have your local AHJ approve it.

Q: We have a stairwell in our hospital that extends from the 8^th floor to the 1^st floor, where there is a door that discharges the occupants to the outdoors. We have construction in progress on the 2^nd floor, which affects the stairwell and we have closed the stairwell at the 2^nd floor level, however, we have allowed the stairwell to remain open from the 3^rd floor to the 8^th floor. Our safety officer thinks allowing people to travel from the 8^th to the 3^rd floors in a stairwell that is closed on the 2^nd floor is not allowed, and wants to close the entire stairwell. This would be a hardship for our staff that wants to use the stairs rather than wait for an elevator. Do we have to close the stairwell entirely, or can we allow it to remain open on the upper floors?

A: Construction projects never make it easy on facility managers and safety officers, do they! My answer to your question is dependent on the precautions and alternative measures that you have implemented. First let me say that when working with something that is such an integral part of safety such as an exit stairwell, the most effective safety precautions should be taken. If it were my decision, I would agree with your safety officer and want to shut the entire stairwell down as the construction project has caused the path of egress to be obstructed.  However, there is another option. If you implemented the appropriate Interim Life Safety Measures (ILSMs) and provided adequate signage on each floor declaring the stairwell is no longer an exit, explaining that it now terminates at the 3^rd floor, and if you provided adequate signage explaining where the closest alternative exit is located, then you would be able to allow the stairwell to be used for communicating purposes to get from floor to floor, and it is no longer an exit. Any ‘Exit’ signs that direct the path of egress towards and into this stairwell would have to be covered or removed and the construction in progress would have to be separated from the occupants in the stairwell with appropriately rated materials. Other ILSMs would have to be considered as well, according to your hospital’s policy. While this would not be my first choice, I agree that this modified use of the stairwell would be permitted by the NFPA 101 Life Safety Code (LSC), 2000 edition.

Q: In regards to stairwell signage, when you have restrictive access back into the building from a stairwell in accordance with section 7.2.1.5.2 of the NFPA 101 Life Safety Code, should the signs indicate the status of the doors (locked or unlocked) during normal building conditions or when the building is in alarm.

A: I understand your question, but I am not sure I understand your motive. Is it your position that you desire to have stairwell re-entry in your hospital, or is it your position that you do NOT want stairwell re-entry at your hospital? To answer your direct question, I would say the stairwell signage referred to in 7.2.1.5.2, Exception 1 (d) and (e) should identify the stairwell door that allows re-entry when the building fire alarm system is in alarm. But section 19.2.2.2.8 says existing hospital are exempt from complying with 7.2.1.5.2 and the Annex section of 19.2.2.2.8 says doors in the stairwell should allow re-entry at not less than every third floor.  So I see the following points made here:

1. Doors in a stairwell serving 3 or more stories have to allow re-entry, or have automatic unlocking devices tied to the fire alarm system (7.2.1.5.2)
2. Existing healthcare occupancies are exempt from the mandatory re-entry requirement in 7.2.1.5.2 (19.2.2.2.8), which means you can lock the doors and prevent re-entry
3. A suggestion (recommendation) is made that if you choose not to be exempt from 7.2.1.5.2 and you want to prevent re-entry, then at the very least the stairwell door should allow re-entry at every third floor (A.19.2.2.2.8)

So, if you want to prevent re-entry, then I’d suggest you follow the recommendation in A.19.2.2.2.8 and provide automatic unlocking on the stairwell doors at every third floor .If you want to allow re-entry then I don’t see any problem to simply allow it without any locks on the stairwell doors or any automatic releasing devices.

Q: Can evacuation chairs be installed in stairwells?

A: The answer is… maybe yes and maybe no. Sorry, that’s not a direct answer, so please allow me to explain. Section 7.2.2.5.3 of the 2000 edition of the Life Safety Code says: “There shall be no enclosed, usable space within an exit enclosure, including under stairs, nor shall any open space within the enclosure be used for any purpose that has the potential to interfere with egress.” So, if we take the latter half of this requirement, it says we cannot place anything in the stairwell that could interfere with egress. Would hanging an evacuation chair on the inside wall of a stairwell interfere with egress? This is a question that is not directly addressed by NFPA, so that means the authorities having jurisdiction (AHJ) get to make that interpretation. My experience with many AHJs is they do not want anything hung on the wall on the inside of a stairwell where it could be an obstruction to those individuals trying to egress down the stairs. That means to me, that you would NOT be able to hang these evacuation chairs anywhere in the path of egress inside the stairs, no matter how wide those stairs are. However, not all is lost. If there is a landing at the very top of the stairwell that is open and not used as part of the path of egress, and there is no other items on the walls around this landing, such as a fire hose cabinet or fire extinguisher, then I could see that area being used successfully to hang an evacuation chair. The downside of this is the arrangement only seems to apply to the very top of the stairwell, and if you wanted to hang evacuation chairs on every landing in the stairwell, I don’t believe you would be able. Something else to think about: Even if one AHJ says it is okay to hang evacuation chairs inside the stairwell on every landing, I strongly suggest you do not do it. You may have as many as 5 or 6 AHJs that inspect your hospital for compliance with the Life Safety Code. Just because one AHJ says it is okay that does not mean all of the other AHJs have to abide by that decision.

Q: During a recent survey, the surveyor said a card reader on the stairwell door cannot be located on an adjacent wall or door frame, but it must be an integral part of the lockset itself. Is this true? They were talking about card readers on the stairwell side for re-entry to a floor.

A: Did the surveyor cite you for non-compliance? If not, surveyors sometimes say things that are misunderstood, especially if there is no citation. Doors not in the path of egress are permitted to be locked, and a re-entry door from a stairwell usually is not in the path of egress. As long as the re-entry door in the stairwell is not in the path of egress then I do not see any reason that what you describe would be a problem. The Life Safety Code would allow for a card reader device to unlock a stairwell re-entry door as long as the door is not in the path of egress.  If the card reader is mounted in the stairwell on the door leading to a floor of the building (not a discharge door), then the card reader is not on the egress side of the door. There is nothing in the Life Safety Code, or in NFPA 80 Standard for Fire Doors and Fire Windows, (1999 edition) that would require the card reader to be mounted on the door leaf, rather than the on the wall near the door. Therefore, it is clear that the LSC permits card-access readers to be mounted on the wall near the door, since it is not a device or motion to operate the door. I cannot think of any situation that would require the card-access reader to be mounted on the door leaf, itself.

Q: Is there any specific regulation that addresses storing items under stairwells and if so does it differentiate between public stairs and stairs which are utilized to access areas not open to the public?

A: Yes, section 7.2.2.5.3 of the 2000 edition of the Life Safety Code specifically says there must be no enclosed, usable space within an exit enclosure, including under stairs, nor shall any open space within the enclosure be used for any purpose that has the potential to interfere with egress. There is an exception that says enclosed usable space is permitted under the stairs, provided that the space is separated from the stair enclosure by the same fire resistance as the exit enclosure, and entrance to that enclosed usable space is not from within the stair enclosure. The common conclusion of this (and other sections) is general storage is prohibited in stairwells. The concept of an exit enclosure is to provide an egress environment which is sterile from safety hazards. It is recognized that general storage usually ends up (or has the potential of) being a hazardous area, and exiting through a hazardous area is not permitted. From that point of view, this makes perfect sense. However, the LSC does not prohibit safety items stored in the stairwell as long as they do not interfere with the egress. As mentioned in a posting on March 2,  evacuation chairs stored at the top of the stairwell could be considered to not interfere with egress.  Hospitals have such a difficult time finding adequate useful storage space I believe a safety item (such as patient evacuation chairs) should be permitted inside an exit enclosure provided it does not interfere with egress in any way.

Q: I am looking for a code reference which specifies the installation height for stairwell signage. It appears that NFPA 101 indicates 5 feet above the stairwell landing but does not indicate whether it is to the top or bottom of the sign. Can you provide guidance?

A: If you are referring to the wall-mounted stair identification signs mounted within the enclosure on each landing in stairs serving five or more stories, then the mounting height is ‘approximately’ 5 feet above the floor landing, according to 7.2.2.5.4 of the 2000 Life Safety Code. The NFPA 101 Handbook has a picture showing the 5 foot measurement is between the bottom of the sign and the floor. Since the official code language says ‘approximate’, then the 5 foot distance can be interpreted to be to the top, the center or the bottom of the sign. You should be safe with any of those measurements.

Q: Can a chair lift device be installed in an exit stairwell? What are the regulations?

A: The Life Safety Code and the local building codes set minimum widths of the required exit stairwells, pertaining to the required doors to the exit stairwells, and they set a minimum number of exit stairwells the hospital must have. These are all calculated by the architect who designed the facility to accommodate people exiting the building during an emergency. To install a chair-lift device in a stairwell would violate these conditions and would cause the building to be non-compliant with the Life Safety Code.

The following sections of the 2012 Life Safety Code set the requirements for minimum widths of required egress components:

• 7.2.2.2.1.1(b)   36 inches clear width for existing stairs
• 7.2.2.2.1.2(A)  36 inches clear width for new stairs serving less than 50 occupants
• 7.2.2.2.1.2(B)  44 inches clear width for new stairs serving 50 to less than 2000 occupants
• 7.2.2.2.1.2(B)  56 inches clear width for new stairs serving 2000 or more occupants
• 19.2.3.6           The minimum clear width of doors in existing healthcare occupancies is 32 inches
• 19.2.3.7           The minimum clear width of doors in existing healthcare occupancies is 28 inches where evacuation by bed, gurney or wheelchair is required

These are minimum width requirements, and actual widths would have to increase based on the number of occupants calculated to use these components.

Section 7.2.2.5.3.1 of the 2012 LSC says nothing may be installed in exit enclosures that could interfere with egress. I suspect a chair-lift would interfere with egress.

If you have a stairwell that is not an exit stairwell, then the possibility may be that a chair-lift could be installed as long as minimum aisle widths (36 inches) are met. Check with your design professional and your state and local AHJs to determine if that is possible.

I’m also told that the ADA requirements do not allow chair lifts in exit stairwells, and check with your state department of hospital licensing to see if they have any additional restrictions.

Q: I understand it would be best to not place something affixed to the walls of the exit stairwell that protrudes in to the path of egress, which in turn, may interfere with egress. But we have two sets of stairwells, that in the middle of each floor, is a landing which has about a 7’ alcove going away from the path of egress on the landing, and the path of egress does not use this alcove.

So my question is, can we store evacuation chairs in these alcoves? I can understand affixing these items in the path of egress within the stairwell, can interfere with egress, but these alcoves are clearly out of the way and not in the path of egress.

A: To answer your question, let’s first take a look at section 7.2.2.5.3 of the 2012 Life Safety Code (LSC), which says there shall be no enclosed, usable space within an exit enclosure, including under the stairs, nor shall any open space within the enclosure be used for any purpose that has the potential to interfere with egress.

What this section appears to say is you may store your evacuation chairs in the alcove of your stairwell since the alcove is not part of the egress, and the stored evacuation chairs would not interfere with egress. But there are surveyors and AHJs that take a much more severe look at this issue, based on section 7.1.3.2.3 of the 2012 LSC, which says an exit enclosure shall not be used for any purpose that has the potential to interfere with its use as an exit and, if so designated, as an area of refuge.

Some AHJs take a very strong stand against anything being stored in the stairwells, but the Annex section of 7.1.3.2.3 explains this requirement a bit further, and says the provision prohibits the use of exit enclosures for storage or for installation of equipment not necessary for safety. Occupancy is prohibited other than for egress, refuge, and access. The intent is that the exit enclosure essentially be ‘sterile’ with respect to fire safety hazards.

The above reference is in the Annex section of the LSC which means it is not part of the enforceable section of the code, but it is an explanatory section to help authorities understand the intent of the technical committee who wrote the code. Most AHJs follow what the Annex section says, although they do not have to. The Annex section for 7.1.3.2.3 does prohibit storage in the stairwell that is “not necessary for safety”, but one could make the point that evacuation chairs are necessary for safety and therefore are permitted to be stored in the stairwell, as long as they do not interfere with egress.

The bottom line is it is apparent to me that the Life Safety Code does permit the storage of evacuation chairs in an exit stairwell, as long as the chairs are stored in such a way as to not interfere with egress. However, not all AHJs actually agree with this and some do cite hospitals if they have anything stored in the stairwells. If you want to pursue this and store the evacuation chairs in the alcove of your stairwells, I suggest you document these sections of the Life Safety Code and show them to any surveyor who questions the practice. It may prevent you from having a citation, or it may not.

Q: I have a question about putting pictures up in stairwells. Someone in our administration department at our hospital wants to put pictures up in a stairwell. We have already received a citation for having a camera in a stairwell so I am almost certain we would get one for this also. I want to quote this section: A 7.1.3.2.3 from the NFPA 101 Life Safety Code as I cannot find any other section on it but want to make sure there is nothing I missed since it is an executive asking to do this and I want to make sure I have every angle covered.

A: You’re correct…. AHJs can be very tough on anything placed in a stairwell that does not serve the function of the stairwell. Under previous editions of the Life Safety Code, a camera would not be permitted because it was not considered to serve the stairwell. But in the Annex section A.7.1.3.2.1(10)(b) of the 2012 Life Safety Code, penetrations for electrical wiring for security cameras would be permitted as long as the AHJ approves. You would have to ask all of your AHJs for approval. Pictures would not serve the function of the stairwell and likely would be cited by AHJs. Section 7.1.3.2.3 of the 2012 Life Safety Code says the exit enclosure (i.e. stairwell) cannot be used for any other purpose that has the potential to interfere with the use of the exit enclosure. A picture hanging on the wall could interfere with individuals exiting the facility. The intent is to prohibit any equipment (i.e. pictures) not necessary for safety. The Life Safety Code intends for the exit enclosure to essentially be “sterile” with respect to safety hazards.

Q: We are being told that section 7.2.2.5.4.3 of the 2012 Life Safety Code requires us to install paint on the nose tread on stairs in existing egress stairways as a requirement. I read it as if you want to install a paint stripe, here is what you need to do. Who is correct?

A: Section 7.2.2.5.4.3 in the 2012 LSC is very clear: Where new contrasting marking is applied to stairs, there are four (4) criterions to follow. It does not say all stairs must have contrasting markings applied to the stairs. This section only applies if you decide to apply contrasting markings to the stairs. Also, section 7.2.2.5.5 says exit stair path markings are only required if the occupancy chapter requires them. Healthcare occupancy does not require them.

Q: I just got cited by the Joint Commission for having evacuation chairs at tops of our stairwells. The chairs were not causing any egress issues in my opinion, but the surveyor did not care that state fire marshal gave his blessing 8 years ago to have chairs at tops of stairwell and during the previous two Joint Commission surveys the chairs were not an issue. Your thoughts on this would be greatly appreciated.

A: First of all, it doesn’t matter what a state or local inspector or fire marshal says. Joint Commission and/or CMS does not have to comply with what a state or local authority says on an issue, and often does not care. All authorities having jurisdiction (AHJ) are equal, but separate. To have the permission or interpretation of one authority does not provide you with any leverage or influence with any other authority. Often times the authorities simply do not care what the other authorities say.

The Life Safety Code is not entirely clear on the subject of evacuation chairs mounted in stairwells. At one point (section 7.2.2.5.3 of the 2012 Life Safety Code) the code says no space in the exit enclosure may be used for any purpose that has the potential to interfere with egress. One may conclude that if the evacuation chairs are mounted off to the side of the top landing where there is no possibility of egress interference, then you can mount an evacuation chair there. But the code does not specifically say that and it would have to be an interpretation by the authority to allow it.

But section 7.1.3.2.3 also says an exit enclosure cannot be used for any purpose that has the potential to interfere with its use as an exit. According to the Annex section, the intent of this standard is the exit enclosure should be sterile with respect for fire safety hazards. The authorities can interpret this any way they want since the code is not clear.

Apparently, the Joint Commission (through the surveyor) is saying they will not allow it, and it is well within their right to say so. I have been in conferences where representatives from the Joint Commission engineering department say they do not allow stairwell evacuation chairs to be stored inside the stairwell.

Q: What is the Life Safety Code ruling on cameras and speakers in stairwells? Joint Commission was in and cited us on having cameras in the stairwells. We were told by the surveyor that they don’t pertain to the stairwells.

A: The Life Safety Code does not specifically address cameras in the stairwells, but section 7.1.3.2.1(10) of the 2012 LSC does limit what penetrations are permitted into an exit enclosure. Conduit is permitted as long as the conduit serves the stairway. This seems to be an interpretation issue, and apparently, the surveyor decided the use of cameras does not fit the description in 7.1.3.2.1(10). To me, a camera focused on people using the stairway seems to fit the description of “serving the stairway”, but it really doesn’t matter what I think.

If you can prove the camera installation qualifies as ‘existing’ conditions, then it should be accepted by the accreditor. The definition of ‘exiting’ conditions is any design, construction, or governmental approval that was in existence prior to July 5, 2016 (the date the 2012 LSC was adopted). However, since the 2000 LSC also prohibited new penetrations in stairwells for cameras, it is likely that a surveyor will hold you accountable to what the 2000 LSC required when you were supposed to comply with that edition, and that edition was adopted March 11, 2003. So, if the camera was installed in the stairwell since March 11, 2003, I can see that the surveyor would have a legitimate finding.

Q: With the elimination of the CMS Waivers, I was trying to clarify what now applies for mechanical room combustibles storage (i.e. mechanical areas with only stairway and elevator access vs. hallway access and stairway access, or just hallway access). Does it mean no combustible storage without a “buffer room” to a stairway still applies as described in the old waiver? I was confused with NFPA 101-2012, Separation of Occupancies in Healthcare (Table 6.1.14.4.1) which appears to show 2-hour separation for all Storage, normal to hazardous. Confused with their footnote: ‡The 1-hour reduction due to the presence of sprinklers in accordance with the single-dagger footnote is not permitted.

A: Let me clear up some of the issues that may be confusing you. First of all, CMS did not eliminate any waivers. Healthcare organizations may still submit waiver requests provided the non-compliance that is being requested to be waived has been cited first during an accreditation survey or state survey on behalf of CMS. Since CMS adopted the 2012 Life Safety Code all of the Categorical Waivers that they issued over the past few years have not been eliminated, but rather they have been completed. The Categorical Waivers (for the most part) allowed healthcare facilities to use certain sections of the 2012 LSC early, before CMS formally adopted the 2012 Life Safety Code. Since CMS did adopt the 2012 LSC on May 4, 2016, with an effective date of July 5, 2016, there is no need for the Categorical Waivers. They were not eliminated or deleted; they just were completed.

Under the 2000 Life Safety Code, openings in exit enclosures (i.e. stairwells) were limited from normally occupied spaces and corridors. This means unoccupied mechanical rooms that had their only access through a stairwell were non-compliant with the 2000 Life Safety Code. The Life Safety Code Technical Committee recognized that was a problem in many hospitals, so they changed the code in the 2012 edition, to allow existing openings into exit enclosures from mechanical equipment spaces to remain, provided the following conditions occur [see section 7.1.3.2.1(9)(c)]:

• The door assemblies between the exit enclosure and the mechanical space are properly rated
• The space is used for non-fuel-fired equipment
• The space contains no storage of combustible materials
• The building is fully protected by automatic sprinklers

So… if you are attempting to use the above section for mechanical rooms that open onto a stairwell, then you are not permitted to have any combustibles stored in the mechanical space. This means no boxes of filters; no cardboard boxes containing repair parts; no storage of anything that could burn. And the entire building has to be protected with sprinklers. However, if you do have a vestibule separating the mechanical space from the stairwell, then you do not have to comply with the above requirements since you are compliant with section 7.1.3.2.1.

Table 6.1.14.4.1 that you referenced is a table to identify the separation between differing occupancies… not a separation involving storage rooms within the same occupancy. There are many different occupancies that a healthcare facility may have: Healthcare occupancy, business occupancy, and even a storage occupancy are just a few. Anytime there are different occupancies that are contiguous and one of the occupancies is a healthcare occupancy, then the barrier separating the two occupancies must be 2-hour fire rated. This table has nothing to do with the separation required around a storage room inside a healthcare occupancy.

Q:  We are being told by our local AHJ that a stairwell in a 2 story building has to be 2-hour fire resistance rated so that it meets the requirements of occupancy separation since one floor is healthcare and one floor is business. Do you agree?
A: Well…. That is a matter of interpretation, and I can understand the logic with the requirement to be 2-hour fire rated. Another way of looking at it is if a stairwell was only one hour fire rated, it would take a fire starting on the 1^st floor (business occupancy) one hour to penetrate the stairwell barrier, and then it would take one more hour to penetrate the 2^nd floor (healthcare occupancy) which is a total of 2 hours. Personally, I would not buy into that line of thought, and if I were an AHJ, I would not allow a 1-hour fire rated stairwell to separate a business occupancy from a healthcare occupancy. I would require it to be 2-hour rated. But, that’s me. Remember… Every AHJ has the right to interpret the Life Safety Code as they see fit.

Q: We have a potential elopement risk at the nursing home where I work. A patient gets into the stairwell and down to the first floor and exits the building. We have an alarm system that alerts us when any door is activated. My question is: Can we install interrupter gates on the second floor leading down to the first to deter elopement risk?

A: I’m not sure what you believe to be an interrupter gate … but they won’t do you any good in restricting egress. By definition, an interrupter gate cannot restrict egress. If you are fully sprinklered, you can install delayed egress locks that will slow down egress for 15 seconds, allowing staff to respond to the local alarm and prevent someone from leaving. For normal egress you can provide authorized people ID badges that can be swiped or read on a card reader bypassing the delayed egress locks. You may even consider specialized protective measure locks as described in section 19.2.2.2.5.2 of the 2012 LSC. They may cost you more, but they are effective for your concern.

Q: Can I install security cameras in stairwells

A: You can…. But be prepared to remove them. Many Accreditation Organizations (AOs) and most states who survey on behalf of CMS do not allow cameras in stairwells. The reason for this is two-fold: 1) Section 7.1.3.2.1(10) of the 2012 Life Safety Code does not permit new penetrations into the exit enclosure that does not serve the exit enclosure (with some exceptions). Many AHJs believe security cameras serve the facility and not just the exit enclosure; and 2) The concept of exit enclosures is to provide a clean environment that is free of any device that does not serve the purpose of the stairwell. The purpose of the stairwell is to evacuate people from the building in the event of an emergency. The security camera does not serve that purpose… a security camera monitors the activity of the people.

Anyway… I’m in favor of security cameras in stairwells, but my opinion does not matter, and many AHJs do not permit them. So, perhaps it would be best to not install them.

Q: I have several hospitals that have been cited by surveyors for having carpet in the stairwells. Can you tell me if there is any code requirement that states that carpet is not allowed in the fire exit stairwell?

A: Excellent question. No… as far as I know, there is no direct standard that prohibits carpeting in exit enclosure stairwells. However, there are a few sections of the LSC that could shed light on this issue.

Section 7.1.6.4 of the 2012 LSC says walking surfaces must be slip resistant. If a surveyor believes the carpet can be slippery, then that would be a problem. Section 7.2.2.3.3.2 of the 2012 LSC says stair treads and landings must be free of projections that could trip stair users. This may be a bit of a stretch, but if the surveyor believes a carpet could become loose, it may trip the people using the stairs.

Annex section A.7.2.2.3.5 of the 2012 LSC says carpeting over the nose of a stair can create an unstable surface. “Any horizontal projections of resilient covering materials beyond the tread nosing and riser, such as carpet and underlayment, can interfere with user’s feet and thereby reduce usable tread depth.”

I think it is safe to say that carpeting is not prohibited, but in the opinion of the NFPA 101 technical committee, carpeting can interfere with the user of the stairs. If the technical committee fully believed carpeting on stairs was a serious impediment to exiting, they definitely would have banned it. It is important to understand that the Annex section is not part of the enforceable code, but rather is explanatory information provided by the technical committee for users of the Life Safety Code to understand what the technical committee was thinking when they wrote the standards.

Therefore, it is perfectly acceptable for an authority having jurisdiction (AHJ) to follow the recommendations provided in the Annex section… or not. It is just advisory information to help the AHJ interpret the LSC. The AHJ can use the information in the Annex section… or they can choose to ignore the information. I can’t say that I disagree with the surveyor… although I can’t remember the last time I saw carpeting in exit access stairwells.