Appeal 34859

1016.2.5

OSSC 1016.2 Egress Through Intervening Spaces
Egress through intervening spaces shall comply with this section…
Sec. 2 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.
Sec. 5 Egress shall not pass through kitchens, storage rooms, closets, or spaces used for similar purposes.

The request is to allow exiting from the building's main performance platform through the S-1 support spaces (designated on the egress plan as "Loading and Staging" - Rooms 119.1 and 125, and "Bike Storage" - Room 127) to either side of the platform.

Refer to included egress plan G101.

The proposed building is designed as a Major Event Entertainment venue with a raised performance platform facing audience assembly spaces. The performance platform occupies a central location on the south, central building area and is raised 60” above the main audience floor level with flanking support spaces. The building is fully sprinklered per NFPA 13.

In accordance with OSSC 508.2 all spaces within the building must be identified by the occupancy category that most closely matches the use of the space. This code section recognizes that buildings frequently contain accessory use areas that are necessary for the principal occupancy to properly function. The performance platform itself has been identified as an A-1 assembly occupancy and the associated back-of-house spaces have been identified as S-1 storage occupancies.

Although designated storage occupancies for the purposes of OSSC 508.2, the character of these support areas are not fixed storeroom spaces anticipated by the building code and, indeed, would cease to function if they were equipped with fixed storage. These spaces perform dynamic support functions and they constitute the main circulation paths to the platform and provide back-of-house access for performers, technicians, and equipment. While necessary for code compliance, classifying them as storage occupancies is an overly simplistic description of the spaces.

According to the IBC code commentary, "The concern in Item 5 [i.e. 1016.2.5] 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; therefore, it is not the intent of this provision to address the situation of egress for offices through an associated warehouse space."

Further, the commentary adds, "The intent of Item 2 [i.e. 1016.2.2] is not that the accessory space be limited to the 10-percent area in Section 508.2.3, but that the spaces be interrelated so that doors between the spaces are not at risk of being blocked or locked." This section allows adjoining spaces to be considered a part of the room or space from which egress originates, provided that there are reasonable assurances that the continuous egress path will always be available.

Taken together, the commentary recognizes that egress through secondary spaces may be required and must be understood in the context of the function of the space. In order for the performance platform to meet the operational requirements of the venue, the support spaces must remain open to allow performers and staff to support the performances taking place on the platform. In some cases, such as the scenario contemplated by OSSC 1016.2.5 - Exception 2.4, fixed barriers may be appropriate for delineating the egress path within some storage occupancies, however, in this case, the inherent flexibility needed for staging productions would be negatively impacted by such a subdivision of the space.

This project proposes to permanently mark the floor in rooms to indicate paths through the platform support spaces in which obstructions are prohibited. The perimeter of the paths are to be permanently labeled in 3” tall letters reading: “PATH TO REMAIN CLEAR AT ALL TIMES.” The paths shall provide direct access to the exterior (east side) and an exit enclosure (west side).

This code appeal addresses the requirement of OSSC 1016.2.5 which prohibits egress through storage rooms. In this case, the spaces designated as storage occupancy function holistically along with the performance platform and should (consistent with the intent of the code) be considered as an interconnected whole.

This project proposes that permanent floor markings designating reserved paths of travel to ensure the availability of unobstructed egress paths with direct access to an exit and at the same time maintain the flexibility of the space required for the primary function of the space.