I wanted to pick up on something that Kerwin brought up in his last article with his footnote relating to access to emergency escape and rescue openings (EEROs). About ten years ago or so we started getting comments back from different fire agencies about the need for “ladder pads”. I think the first comment like this came from the City of Sunnyvale in the South Bay. I had never heard of “ladder pads” before and had no understanding of what they were, how they were to be constructed, located, or why we even needed them. I don’t remember if the comment came up during the entitlement of the project or during permit plan check, but it was something that we had not expected and it wasn’t easy to satisfy the request. So if you haven’t had any experience with providing access to EEROs this article is intended to at least make you aware of what has been taking hold in the Bay Area over the last ten years or so.
The code requires that EEROs be provided for basements and sleeping rooms in R occupancies below the fourth story. So for most R buildings that means bedrooms on the first three floors need to have an EERO. This is usually accomplished by providing what is called an egress window for each of these rooms. An egress window being a window that complies with the opening requirements for an EERO. But windows aren’t the only way to comply. We often use balcony doors, sliding or french, as the EERO at balcony locations.
The idea of ladder pads arose from a very broad interpretation from the California State Fire Marshal issued December 3, 2018 (the request for interpretation was requested September 28, 2017, which is interesting that it took over a year to provide a one word response). I have included a screenshot of the document (Click here for Link).
So it is quite clear from the question and response that there is a lot of latitude given to the fire authority as to what it means to be “accessible to the fire department using ground ladders”. I have seen various fire authorities give a wide range of what they feel meets this requirement. Some are as simple as providing an area, flat and level free of landscaping a certain distance from the EERO with the ability to provide a ladder at an acceptable angle. On the other end of the spectrum I have seen a requirement for a concrete pad 72” wide by 84” deep positioned so that there is 36” clear behind where a ladder would need to be placed to access the EERO. And if you have EERO at both the second and third story that stack over each other, you would need enough concrete pad to meet those requirements for each EERO at each story.
Some fire authorities have actually published their requirements. Which is absolutely helpful than not having anything to reference at all (Click here for City of San Jose requirements). Others are not so defined and seem to be communicated to the project team during the entitlement or permit plan check phase of the project.
Over the years we have taken many different approaches to comply with this requirement. Many times during the entitlement phase of the project, the fire authority might just require that we show in plan where these ladder pads will need to be located. This seems simple enough, and we have done that. See example below of a 3-story townhome project in the City of Livermore.
Other times we are required to show compliance as part of the construction documents. This often is done by providing the ladder pad locations in plan similar to what was done during the entitlement phase of the project. We have occasionally included generalized sections of the different unit types that show compliance. See an example below for a project that we did in the City of Mountain View.
The previous example brings to light project specific particulars that are not considered when broad requirements are put into place. Many of the diagrams put out by the various fire authorities are generic buildings that have little or no architectural articulation. As such it is very simple to describe and understand the requirements. There is no awareness of planning or zoning requirements that would require a building design more than just a 3-story vertical wall plane. That simple design is just not the case for most, if not all jurisdictions in the Bay Area. What happens when a ladder can’t actually get to the sill of the third story egress window because of an architectural element? If that element can be walked on, is it okay to say that accessible access to the egress window has been provided for the fire department? I don’t know the answer to many of these questions, and in my experience not many want to actually answer them.
Fortunately the Office of the State Fire Marshal (SFM) issued a more recent code interpretation related to this subject. Kerwin referenced this in his article last month (Click here for Link). I was excited to learn of this as I hoped for better direction from the top fire official so that I could maybe use that to get more consistent application of the code, considering that the previous interpretation was hugely broad. Unfortunately, I don’t think that SFM provided anything that clarified or would be helpful to either the fire authorities or those of us trying to comply. Take a look and let me know your thoughts.
Architect | Principal
Comments from Kerwin Lee, AIA:
This particular element shows how sometimes the intent of the code is not clearly reflected or explained and how local interpretation goes beyond the original intent. Yes, the original intent was to allow for escape and rescue. Beyond that the code has not been specific on what escape and rescue means. It could be by ladder, but what kind of ladder? The bottom line is currently reflected in the State Fire Marshals interpretation that there are no specific requirements for the use of ladders. Other requirements in the code, such as requiring smoke detection and sprinklers have reduced the need for these openings.