BCAB #1816

Last updated on January 3, 2019

December 20, 2018

Re: Protection of Exit Facilities

Project Description

The project is a 2 295 m2 Group F, Division 2 single-storey sprinklered warehouse. Access to the building’s main entry door incorporates an exterior stair of seven risers and an exterior access ramp. The main entry door has also been identified by the designer as one of the required exits for the floor area. There is an adjacent loading bay door within 3 m of the exterior stair.

When applied at the subject entry door, the maximum travel distance of 45 m from the furthest point in the floor area extends beyond the entry door to the base of the exterior stair. At this point the base of the exterior stair exceeds 3m horizontally to the unprotected loading bay door. The building’s floor area is considered as a single suite/single fire compartment.

Applicable Code Requirements

Sentence 3.2.3.13.(2) of Division B of the 2012 British Columbia Building Code.

3.2.3.13.(2)   If an unenclosed exterior exit stair or ramp could be exposed to fire from an opening in the exterior wall of the building it serves, the opening in the exterior wall of the building shall be protected in conformance with the requirements of Sentence (4) where the opening in the exterior wall of the building is within 3 m horizontally and

a) less than 10 m below the exit stair or ramp, or

b) less than 5 m above the exit stair or ramp.

Decision being Appealed (Local Authority’s Position)

The local authority has determined that the subject door and exterior stair are both components of one of the required exits for the building, and require protection from the adjacent openings that are within the distances described in Sentence 3.2.3.13.(2).

Appellant's Position

The appellant maintains that exposure protection is not required because the distance to the base of the exterior stairway is within the allowable travel distance to an exit. Thus the entry door should be considered to be an egress door as part of the means of egress and not an exit door.

Appeal Board Decision # 1816

It is the determination of the Board that the subject door and exterior stair are an exterior exit door and an exterior exit stair, and that the exposure protection requirements of Sentence 3.2.3.13.(2) are applicable.

Reason for Decision

The appellant has indicated the subject door is one of the required exits for the floor area and that it also serves as the principal entrance to the building. The Board considers the subject door and exterior stair to both be components of that required exit. Further, Sentence 3.4.2.6.(1) indicates “at least one door at every principal entrance to a building providing access from the exterior at ground level shall be designed in accordance with the requirements for exits.”

The Board acknowledges the concept that extending the maximum travel distance beyond the subject door to the base of the exterior stair may result in a similar or lesser exposure condition when compared where all of the maximum travel distance occurs within the floor area. However the wording of the Code’s acceptable solutions do not recognize this concept, therefore that application would need to be pursued through an alternative solution.

Lyle Kuhnert

Chair, Building Code Appeal Board