The Second Exit That Wasn't

Issue. May the department split the job?

Rule. The building official may allow phased or partial permits where local policy permits, the phase scope is clearly defined, the work can be performed independently, and the partial work will not preclude a compliant final design (IBC Sec. 105.1 and local permit policy). No certificate of occupancy issues until the whole scope is complete and inspected.

Application. Here the answer is no - or not yet. The unresolved item is egress, and the missing element is almost certainly a new exit stair. In a 1998 frame, a stair shaft drives framing, shear walls and structural layout. Allowing demolition and framing before the stair location is fixed practically guarantees a tear-out, and you will then inherit the argument that the framing is 'existing.'

If you do phase. Require: (1) an approved egress concept first, even if schematic and sealed; (2) a separate plan set for the phase; (3) a written applicant acknowledgment that later phases are not guaranteed and no CO issues until the entire scope complies; (4) a schedule for filing the full permit.

Better answer. Decline the split and offer a pre-submittal meeting on the exit design. That is faster for the tenant than a teardown.

Rule. A single means of egress is permitted only in the narrow cases in IBC Sec. 1006.2.1 and Table 1006.2.1. For Group B that is roughly 49 occupants or fewer with about 75 feet of travel; common path of egress travel is limited to about 75 feet unsprinklered. Two exits are required beyond those thresholds and must be remote from each other (Sec. 1007.1.1).

Application. 96 occupants, 165 feet travel, 100 feet common path, one stair, no sprinklers, no alarm. Every threshold is exceeded, two of them by more than double. The 'existing building' argument fails: the alteration creates the suite and its occupant load. The existing building code relaxes requirements for existing elements; it does not authorize a new 96-person assembly with one way out. Because six other suites use that stair, its capacity and clear width must also be re-evaluated, not just its presence.

Options to offer.

• Add a second exit: new exterior stair, new interior stair enclosure (separation per construction type), or a horizontal exit into an adjoining building if one exists and is properly separated.
• Reduce the occupant load by design - smaller suite, fewer exam rooms, documented program limits - then re-check travel and common path so the numbers genuinely close.
• Full sprinkler and fire alarm does not buy a single exit at 96 occupants. It changes some travel and common path allowances, not the fundamental two-exit requirement.

Conclusion. Deny the single-exit design in writing, citing the specific thresholds against the measured distances, and state what would make it approvable.

Write it down. A plan review denial should be a short letter: the code sections, the measured values against the limits, and the conditions that would make the plan approvable. Attach the marked-up plan. That letter is the record on appeal or in litigation.

Consult. Route the alternative egress concepts to the fire code official. A horizontal exit or exterior stair raises fire-code and zoning issues (setback, lot line, exiting through another owner's building) the applicant has probably not considered.

Hold the line at CO. The certificate of occupancy must state the actual approved occupant load, and the posted placard must match it. Do not issue a CO for a suite whose second exit has never been inspected, and do not accept a self-certified as-built for egress.

Process fix. For suites over about 3,000 square feet in unsprinklered buildings, add a mandatory egress check at pre-submittal. The cheapest place to fix this problem is before the architect draws the second stair.