January 23, 1990
BCAB #1102
Re: Exit Stairs - Section 3.7
With reference to your letter of October 26, 1989, regarding exit stairs, we regret the delay in dealing with this issue, but had anticipated resolution without the necessity for our involvement. As there seems to be some general confusion on this question, it may be preferable for us to give our understanding of the situation.
Section 3.7. of the B.C. Code deals with access to enable a disabled person, without assistance, to approach, enter, pass to and from, and make use of an area and its facilities. There is a distinct difference between this and the Code requirements for exits intended to provide for life safety, by means of evacuation to the outside, or to safe areas.
While the same features may provide for both, it is ideal, but not imperative, that they do so; in fact this condition is clearly recognized by the Section 3.7. requirements for areas of refuge. For the disabled, Section 3.7. provides criteria for each specific feature providing access; it does not rule out elevators for this purpose, whereas these are not recognized as contributing to required exits.
Applying the above factors to the situation under review, you must provide exit facilities in full accordance with the general requirements of the Code. You must also provide access conforming with the requirements of Section 3.7. and as indicated, suitable elevators are acceptable for this purpose. If an exit feature is intended to fill both needs, then it must also comply with Section 3.7. If you have exit facilities which are likely to be used by disabled persons, but exceed the specific requirements, as we indicated earlier, it may be ideal but is not mandatory that these be designed to Section 3.7. provisions.
Since the information supplied in your letter is limited, we are unable to give a definitive response, but trust that the above comments will provide a basis for resolving your dispute.
J.C. Currie, Chair