Appeal 24050

712.1.9 Two-Story Openings

712.1.9 Two-story openings. In other than Groups I-2 and I-3, a vertical opening that is not used as one of the applications listed in this section shall be permitted if the opening complies with all of the following items:

1. Does not connect more than two stories.
2. Does not penetrate a horizontal assembly that separates fire areas or smoke barriers that separate

smoke compartments.

1. Is not concealed within the construction of a wall or a floor/ceiling assembly.
2. Is not open to a corridor in Group I and R occupancies.
3. Is not open to a corridor on non-sprinklered floors.
4. Is separated from floor openings and air transfer openings serving other floors by construction conforming to required shaft enclosures.

Allow for a 2 story vertical opening containing an exit access stairway in accordance with section 1019 at Stair S1.

Our interpretation of the code, similar to the IBC commentary, references sections 712.1.12 and 1019.3 of the OSSC 2019. These sections of the code allow us to provide the two-story opening, between the first and second floor at Stair S1.

Section 712.1.12 Exit access stairways and ramps
Vertical openings containing exit access stairways in accordance with section 1019 shall be permitted.

Section 1019.3 Exit access stairways & ramps, occupancies other than I-2 and I-3
Exception 4: Exit access stairways & ramps in buildings equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1, where the area of the vertical opening between stories does not exceed twice the horizontal projected area of the stairway or ramp and the opening is protected by a draft curtain and closely spaced sprinklers in accordance with NFPA 13.

According to the IBC commentary, “A floor opening connecting two stories that is not covered by one of the other provisions for vertical openings in Section 712 may use this provision.” This commentary guides our interpretation to understand that Section 712.1.9 does not supersede section 712.1.12.

Stair S1 is not a path of egress in the building’s exiting strategy. Two additional staircases are provided, Stair S2 and S3, with adequate exit access travel distance. Therefore, Stair S1 qualifies as an Exit Access Stairway which is section 712.1.12. If BDS agrees with the IBC Code commentary, then 712.1.9 would not supersede 712.1.12 and a three story opening is allowed.

Reconsideration Text:
All of the Proposed Design language still applies, which the exception of Section 1019.3. We have altered the design of this stairway and will not leave the top of the stairway open to the corridor beyond on the second floor. Therefore, in lieu of a draft curtain and exception 4, we will provide a rated wall and rated door assembly that separates the stair from the second floor. To do this, we reference Exception 1.

Section 1019.3 Exit access stairways & ramps, occupancies other than I-2 and I-3
Exception 1: Exit access stairways and ramps that serve or atmospherically communicate between only two stories. Such interconnected stories shall not be open to other stories.

This alternate is required to provide:
• An open stair in the main lobby that encourages tenants to use the stairs instead of using the elevator. The stair is part of owner’s goals for providing tenants with healthy-living opportunities.
The health, accessibility, life safety and fire protection requirements are met as required with these conditions:
• Exiting provides life safety measures more than what is required by code.
• In the event of a fire, or presence of smoke, the monitored smoke detection system will immediately send an activation signal to the central monitoring system, notify the fire department and alert building occupants.
• Stair S2 and S3 are provided and more than adequately meet exit access travel distances. Stair S1 is not necessary for exiting requirements.
• Stair S1 is enclosed at the top of the second floor landing, and will protected from the corridor by a unrated wall and accessible door.

Reconsideration Text:
The health, accessibility, life safety and fire protection requirements are met as required with these conditions:
• Stair S1 is enclosed at the top of the second floor landing. The second floor corridor will be protected from the corridor by a rated wall and rated accessible door.