Intervening Rooms and Spaces
NFPA Journal®, November/December 2007
NFPA 101®, Life Safety Code® addresses intervening rooms and spaces in sections 184.108.40.206 and 220.127.116.11. These two sections allow occupants to egress through adjoining rooms with no limit on the number of rooms. However, some occupancy chapters do limit egress through one or two rooms maximum. For example, Health Care (Chapters 18 and 19) and Educational (Chapters 14 and 15) have restrictions on the number of intervening rooms in Section – 2.5 of the applicable occupancy chapter. Also, sections 18.104.22.168 and 22.214.171.124 have several other restrictions.
For example, Section 126.96.36.199 states: “Exit access from rooms or spaces shall be permitted to be through adjoining or intervening rooms or areas, provided that such rooms or areas are accessory to the area served. Foyers, lobbies, and reception rooms constructed as required for corridors shall not be construed as intervening rooms. Exit access shall be arranged so that it is not necessary to pass through any area identified under Protection from Hazards in Chapter 11 through Chapter 42.”
The rooms have to be “accessory”. This term is not defined in Chapter 3 so one must use the common definition in the dictionary. That definition is “a subordinate or supplementary part”. In other words, the intervening rooms are part of the primary use, are probably present the same hazard, and probably are under the same management and control.
The code goes on to prohibit egress through areas identified under “Protection from Hazards” in the occupancy chapters. Section – 3.2 of each occupancy chapter addresses those rooms or spaces that are considered hazardous, not necessarily High Hazard as defined in 6.2.2 “Classification of Hazard of Contents”. Hazardous means the fire hazard is somewhat higher than what is normally expected in that occupancy. For example, in an existing office building, Section 39.3.2 lists “...general storage, boiler and furnace rooms, and maintenance shops. ...” as areas under the Protection from Hazards category. Therefore, egress from an office area is not permitted through the furnace room to get to an exit in an office occupancy.
Section 188.8.131.52 goes onto to prohibit egress through kitchens and storerooms, except as permitted in Chapters 36 and 37. These chapters address new and existing Mercantile Occupancies. Sections 36/184.108.40.206 do permit egress through storerooms if they meet the conditions listed. However, this is an inspection burden as the storerooms of most mercantile occupancies become a storage problem beginning in about August with back-to-school merchandise, then Halloween, then Thanksgiving, then of course Christmas.
When the delivery truck pulls up, the pallets and boxes of merchandise usually go wherever they can fit, and keeping the egress aisle clear is not necessarily a priority.
Section 220.127.116.11 also restricts egress through restrooms, closets, bedrooms, and rooms subject to locking. The term “subject to locking” is interesting. I have always interpreted that to mean if there is an operable lock on the door, then that door is subject to locking. Even if the owner/occupant says that they never lock that door or don’t even know where the key is. If there is an operable lock on the door, chances are that our old friend “Murphy” will find it some time and lock that door!
Earlier it was noted that the Life Safety Code does not have a restriction on the number of rooms one may egress through, except for a couple of occupancies. The Code does limit common path of travel. Common path of travel is the distance one must travel from the most remote occupiable point to an imaginary point where they suddenly have a choice of two directions to reach two different exits. The common path of travel rule is one of the rules that requires when two exit access doors or two exits are required. Common path of travel will be addressed in another column.
Egress through one or more rooms to the corridor may well be permitted. First confirm that the occupancy chapter does not restrict it, and then conform to all the restrictions in Life Safety Code 18.104.22.168 and 22.214.171.124.
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