By Gregory Havel
Fire inspectors and other building officials do not consider it appropriate when required emergency exits are chained and padlocked (photo 1), dead-bolted, or otherwise obstructed so that they cannot be used by building occupants. This is based on several paragraphs in the fire codes.
(1) Photos by author.
The following citations are from National Fire Protection Association (NFPA) 1, Fire Code, 2015 Edition. The language of the International Fire Code, a publication of the International Code Council, is similar, but not identical. Citations in brackets such as [101: A.188.8.131.52] refer to NFPA 101, Life Safety Code, 2015 edition.
Chapter 184.108.40.206 Unobstructed Egress.
220.127.116.11.1 In every occupied building or structure, means of egress from all parts of the building shall be maintained free and unobstructed.
No lock or fastening shall be permitted that prevents free escape from the inside of any building other than in health care occupancies and detention and correctional occupancies where staff are continually on duty and effective provisions are made to remove occupants in case of fire or other emergency.
Chapter 14.4 Means of Egress Reliability.
14.4.1* Maintenance. Means of egress shall be continuously maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency. [101: 18.104.22.168]
A.14.4.1 A proper means of egress allows unobstructed travel at all times. Any type of barrier including… an obstruction or impediment to full instant use of means of egress… any security device or system that emits any medium that could obscure a means of egress. It is, however, recognized that obstructions occur on a short-duration basis. In these instances, awareness training should be provided to ensure that blockages are kept to a minimum and procedures are established for the control and monitoring of the area affected. [101: A.22.214.171.124]
Chapter 126.96.36.199 Panic Hardware and Fire Exit Hardware. 188.8.131.52.3 Required panic hardware and fire exit hardware, in other than detention and correctional occupancies as otherwise provided in Chapters 22 and 23 of NFPA 101, shall not be equipped with any locking device, set screw, or other arrangement that prevents the release of the latch when pressure is applied to the releasing device. [101: 184.108.40.206.3]
Sometimes, a building addition is attached to the existing occupied building with a means of egress extending through the new addition to its new exit discharge. At times during these construction projects, it may not be feasible to use these building exits.
Photos 2 and 3 show the exteriors of blocked emergency exits that temporarily discharge into a construction job site, with deep excavations for foundations just beyond the threshold and at other locations obstructing the use of the exit as well as exposed subsoil and other construction site hazards.
In situations like these, the general contractor can request a meeting with the architect, building manager, fire inspector, and fire chief. After review of the hazards and options for risk management, it may be decided that the public’s safety is best served by temporarily closing one or more of these emergency exits, to cover the illuminated EXIT signs at those exits, to post temporary signs directing building occupants to alternate exits, to publish the revised exit plan in newsletters and by verbal announcement, and to perform a fire or evacuation drill at the time when the exits are blocked.
The authority having jurisdiction (AHJ) may approve the revised exit plan for the duration of the project. In other instances, the AHJ may approve the revised exit plan for a few weeks until excavations are complete, backfilled, and compacted to form a reasonable walking surface. At this time, the exit can be unblocked, but posted “For Emergency Use Only.” The construction workers on site can be required to participate in any alarms of fire or other emergency including fire drills with the building’s normal occupants. As a result, the hazard to building occupants who choose to exit through the construction area in an emergency is relatively small; no work would be ongoing at that time.
The AHJ can approve such short-term changes to exit plans after weighing the risks of blocking exit temporarily against the risk to building occupants attempting to cross a hazardous construction area. According to Annex A of NFPA 1 in section A.14.4.1 “A proper means of egress allows unobstructed travel at all times. Any type of barrier…is an impediment to free movement in the means of egress…. It is, however, recognized that obstructions occur on a short-duration basis. In these instances, awareness training should be provided to ensure that blockages are kept to a minimum and procedures are established for the control and monitoring of the area affected. [101: A.220.127.116.11]”
Although some states and municipalities do not incorporate the explanatory material from the code annexes and appendices into their administrative rules and codes, these explanations can indicate to the AHJ and building officials the intent of that paragraph or section of the building or fire code.
If the building managers, contractors, and the AJH confer on these issues at the beginning of a construction project, they can often arrive at a solution that protects the public from the hazards of exiting in an emergency into a construction site and, at the same time, provide a level of life safety for the building occupants while exits are temporarily obstructed.
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Gregory Havel is a member of the Town of Burlington (WI) Fire Department; retired deputy chief and training officer; and a 35-year veteran of the fire service. He is a Wisconsin-certified fire instructor II, fire officer II, and fire inspector; an adjunct instructor in fire service programs at Gateway Technical College; and safety director for Scherrer Construction Co., Inc. Havel has a bachelor’s degree from St. Norbert College; has more than 35 years of experience in facilities management and building construction; and has presented classes at FDIC.
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