Appeal 34792

OSSC section 1016.2, item 2

1016.2 Egress through intervening spaces.
Egress through intervening spaces shall comply with this section.

1. Egress from a room or space shall not pass through adjoining or intervening rooms or areas, except where such adjoining rooms or areas and the area served are accessory to one or the other, are not a Group H occupancy and provide a discernible path of egress travel to an exit.

Exception: Means of egress are not prohibited through adjoining or intervening rooms or spaces in a Group H, S or F occupancy where the adjoining rooms or spaces are the same or a lesser hazard occupancy group.

We are requesting a modification to the exception per OSSC section 1016.2, item 2, in order to permit occupants egressing from the Primary Building (B Occupancy Group) thru the attached parking garage (Accessory S-2 Occupancy Group) along a provided and discernible path to the exit access and discharge at SW Porter Street.

The design for the Ukandu building includes the renovation of an existing two-story reinforced masonry building and the construction of a new, adjoining two-story addition with attached, secured, and accessible parking. The project is categorized as Construction Type V-B with Nonseparated Mixed Use. Its primary occupancy classification is Occupancy Group B. Occupants will egress from a higher level of protection per the "B" Occupancy thru an area of lower protection per the "S-2" Occupancy. The enclosed garage is fully sprinklered per OSSC Section 406.6.3 and NFPA 13. The parking garage has a maximum vehicular capacity of 10 vehicles (2 ADA stalls and 8 standard stalls). Access to the parking garage is available only to volunteers, staff and families seeking services provided. No obstructions to the exit path are proposed. Illumination levels (under both Normal and Emergency Power) along the proposed egress path will comply with OSSC Section 1008.1. A 20'-0" wide striped path (per OSSC 1025.2) will be provided on the garage floor leading from the designated lobby to the exit access and exit discharge. Required exit access doors from the elevator lobby to the garage and the exit discharge from the garage to SW Porter Street will be identified with illuminated exit signs and equipped with panic hardware. The overhead garage door operates with controlled access to the garage for private, authorized use and is equipped with manual override accessed from interior of garage. The proposed exit path through the parking garage is to maintain the continuation of the required second means of egress for occupants exiting the "B" Occupancy from the lobby.

Summary
Proposed building permit modifications:

1. Illuminated exit signs will also be present along the egress path. Both doors exit toward SW Porter Street.
2. Garage floor to be striped and proposed verbiage within striped area included as follows “Egress Path - Do Not Block”.
3. Vehicular Protective Barriers (Bollards) at 5'-0" OC included between vehicular areas and pedestrian areas (attached exhibit)

We are seeking an appeal for the use of the garage for exit access to accommodate approximately 47% of the occupant load (191 occupants) from the Ukandu building.
• 115 of the 191 occupants are descending from the exit access stair from level 2
• 3 of the 191 occupants are exiting from the elevator lobby in the addition
• 73 of the 191 occupants are exiting from level 1 of the existing portion of the building. NOTE: Per title 24.85.075 Egress Through Existing Buildings, occupants originating in the new portion of the proposed development are NOT allowed to egress through the existing building.

For the occupant load quantified above, we propose the second means of egress through the garage is located in the most obvious location. The proposed design provides the following: an unobstructed path leading to the exit and exit discharge, emergency egress lighting with the minimum footcandle rating at all areas of the garage and a clear and distinguishable striped exit path in the garage leading to the exit.

Reconsideration text:
We are seeking an appeal for the use of the garage for exit access (exit#3) to accommodate 128 occupants (approximately 32% of the occupant load) of the 404 total occupants of the building.

• 114 of the 128 occupants egressing at exit #3 are descending from level 2 and discharging from the garage
• 14 of the 128 occupants egressing at exit #3 are exiting from the level 1 addition, but only 3 of these occupants are originating in the B occupancy, the remaining are originating in the S2 occupancy.
• 73 of the 404 building occupants are egressing from level 1 of the existing portion of the building at exit #2. All of these occupants originate in the existing building.

NOTE: Per title 24.85.075 Egress Through Existing Buildings, occupants originating in the new portion of the proposed development are NOT allowed to egress through the existing building without seismic improvement when the addition area equals 1/3 or more of the existing building area.

For the occupant load quantified above, we propose the second means of egress through the garage is located in the most obvious location. The proposed design provides the following: an unobstructed path leading to the exit and exit discharge, emergency egress lighting with the minimum footcandle rating at all areas of the garage and a clear and distinguishable striped exit path in the garage leading to the exit.

The proposed design meets all of the requirements of the code reference for egress through the parking garage, OSSC 1016.2:
• The first requirement is that adjoining or “intervening” rooms or spaces must be accessory to one another, are not a Group H occupancy and provide a discernible path of egress travel. Our interpretation is that the private accessible parking is accessory to the Ukandu building. Per the IBC Code Commentary, the intent of this requirement is “that the spaces be interrelated so that doors between the spaces will not risk being blocked or locked.” (See also the second requirement. The parking garage is Group S-2, not H, and the garage has discernible paths of egress travel to exits.)
• The second requirement is that exit access cannot pass through a room that can be locked to prevent egress. The parking garage is not locked from the inside.
• The third requirement deals with residential occupancies and does not apply.
• The fourth requirement is that egress not pass through kitchens, storage rooms, closets or spaces used for similar purposes. Though it is an S-2 occupancy, a parking garage is not a storage room or similar space. There is no risk that items might be stored that could block egress paths. Per the IBC Code Commentary, “the concern… is that kitchens, storage rooms and similar spaces may be subject to locking or blockage of the exit access path. This is not a general provision for all Group S occupancies…” The proposed design meets the intent of code by providing an unobstructed path of travel to the exit. While the garage is technically a “Storage” use, the exit path from the building will travel along the clearly demarcated (striped) portion of the drive aisle, which acts more as circulation than storage space. In other words, the path to the exit will never be obstructed.

Portland City Code Chapter 24.85 Seismic Design Requirements for Existing Buildings 24.85.075

24.85.075 Egress through Existing Buildings
Egress through intervening spaces shall comply with this section.

The building structure and seismic resistance of an egress path through, under or over an existing building must meet the required seismic improvement standard specified in Section 24.85.040, Table 24.85-A, under any of the following conditions:

A. The egress path is from an adjacent new building or addition and the new building or addition area equals 1/3 or more of the existing building area; or,
B. The egress path is from an adjacent existing building that undergoes alterations or a change of occupancy requiring its egress path(s) meet the seismic improvement standards as required by this Chapter; or
C. The additional occupant load, as determined by the OSSC, using the egress path through the existing building is 150 people or more.

We are requesting to permit the 115 occupants to egress from the addition through the existing building despite the area of the addition being greater than 1/3 of the area of the existing building. The building design conditions per 24.85.075 are as follows:

A. The egress path is from an adjacent new building or addition and the new building or addition area equals 1/3 or more of the existing building area; or,

Area of Parking = 5,048sf
Area of Ukandu Program = 3,775sf
Area Total of addition = 8,823sf
Area of existing building = 8,447sf
Total Project Building Area = 17,270sf

B. The egress path is from an adjacent existing building that undergoes alterations or a change of occupancy requiring its egress path(s) meet the seismic improvement standards as required by this Chapter; or

This condition does not exist on this project and is not applicable

C. The additional occupant load, as determined by the OSSC, using the egress path through the existing building is 150 people or more.

Additional occupant load through the existing building is 115 occupants (see attached plan)

The design for the Ukandu building includes the renovation of an existing two-story reinforced masonry building and the construction of a new, adjoining two-story addition. The project is categorized as Construction Type V-B with Nonseparated Mixed Use. Its primary occupancy classification is Occupancy Group B. The proposed design is fully sprinklered per OSSC Section 406.6.3 and NFPA 13.

We are requesting to permit the 115 occupants to egress from the addition through the existing building despite the area of the addition being greater than 1/3 of the area of the existing building. We are requesting this code alternative due to these mitigating factors:

• The additional occupant load using the egress path through the existing building is 115 people, substantially less than the 150 occupant threshold.
• The total occupants of the building addition (discounting the separately egressed garage) is 72 which is less than a third of the 228 occupants of the existing building.
• Two points of egress are required from this building. Three points of egress are provided, two of which egress directly from the addition.
• The egress through the existing building is a clear, direct and unobstructed path to exit
• The renovation includes a partial seismic upgrade to the existing building including: adding diaphragm ties between the existing concrete and CMU walls and the floor and roof diaphragms and adding continuous cross-ties in the North/South direction along the central girder line, addressing two major deficiencies.
• The renovation includes rebuilding the wood floor and bearing walls along the egress route and adding a new steel canopy over the egress door.

The design for the Ukandu building includes the renovation of an existing two-story reinforced masonry building and the construction of a new, adjoining two-story addition. The project is categorized as Construction Type V-B with Nonseparated Mixed Use. Its primary occupancy classification is Occupancy Group B. The proposed design is fully sprinklered per OSSC Section 406.6.3 and NFPA 13.

We are requesting to permit the 115 occupants to egress from the addition through the existing building despite the area of the addition being greater than 1/3 of the area of the existing building. We are requesting this code alternative due to these mitigating factors:

• The additional occupant load using the egress path through the existing building is 115 people, substantially less than the 150 occupant threshold.
• The total occupants of the building addition (discounting the separately egressed garage) is 72 which is less than a third of the 228 occupants of the existing building.
• Two points of egress are required from this building. Three points of egress are provided, two of which egress directly from the addition.
• The egress through the existing building is a clear, direct and unobstructed path to exit
• The renovation includes a partial seismic upgrade to the existing building including: adding diaphragm ties between the existing concrete and CMU walls and the floor and roof diaphragms and adding continuous cross-ties in the North/South direction along the central girder line, addressing two major deficiencies.
• The renovation includes rebuilding the wood floor and bearing walls along the egress route and adding a new steel canopy over the egress door.