BCAB #1421 - Egress from Garage, Sentence 126.96.36.199.(4)
July 17, 1996
Re: Egress from Garage, Sentence 188.8.131.52.(4)
The project is a three storey residential building containing four dwelling units. The first storey consists of four single car garages while the second and third storeys contain two dwellings each. There is a common area in front of the garages that is covered by the storey above and could be considered a four car carport. The garages are separated from each other and there is no internal access between the garages and the dwelling units. Due to site conditions three of the garages have only the overhead vehicle entry door and no man door at the rear.
Reason for Appeal
Article 184.108.40.206. requires egress doors from every room in a building and with one exception Article 220.127.116.11. requires such doors to swing on a vertical axis.
The appellant contends that Sentence 18.104.22.168.(4) applies because each garage serves "not more than one dwelling unit." Therefore, the single egress door permitted by Sentence 22.214.171.124.(1) is exempted from the requirement to swing on a vertical axis.
Building Official's Position
The building official maintains that Sentence 126.96.36.199.(2) applies and requires the exit door to swing on a vertical axis in the direction of exit travel. The garages are not interconnected to the residential suites so the exemption from swinging on a vertical axis provided by Sentence 188.8.131.52.(4) does not apply. Also, if the horizontally hung garage doors were considered exit doors they would lead to a path of travel through the covered parking area and this is considered an obstructed means of egress.
Appeal Board Decision #1421
It is the determination of the Board that each individual garage serves not more than one dwelling unit and Sentence 184.108.40.206.(4) is applicable. The code does not require the garage to be attached to the dwelling it serves and does not require internal access between the garage and the dwelling.
George R. Humphrey, Chair