Written by Jonathan Clark.
This month I thought I would share an experience that I recently had with respect to the application of the emergency escape and rescue windows. Before I get to that I want to direct you also to a previous article that Kerwin wrote for the September 2022 ArchNEWS. That article talks about more of the history of the subject and how it is changing with each code iteration.
Section 1031 of the California Building Code (CBC) is where we find all of the requirements for emergency escape and rescue windows. Aside from the very technical descriptions of what makes an emergency escape and rescue window, the more important topic is where they are required. Section 1031.2 reads in part, “In addition to the means of egress required by this chapter, emergency escape and rescue openings shall be provided in Group R occupancies. Basements and sleeping rooms below the fourth story above grade plane shall have not fewer than one emergency escape and rescue opening in accordance with this section…Such openings shall open directly into a public way or to a yard or court that opens to a public way.” (For this article we won’t be exploring the exceptions)
This seems pretty straight forward and is simplified as follows:
- In addition to mean of egress
- Required in Group R occupancies
- Required in sleeping rooms in basements and floors 1 through 3
- Opens directly to public way or a yard or court that opens to a public way
In conventional practice we are taught that you need an egress window in each bedroom in R occupancies. This is very simplified and for much of the residential work that occurs is accurate. The term emergency escape and rescue opening as defined in the code is, “An operable exterior window, door or other similar device that provides for a means of escape and access for rescue in the event of an emergency.” This definition is far more broad as to encompass not only windows, but doors, and also allows for similar devices to doors and windows. In my experience windows are used most of the time to comply with this section and occasionally doors that provide access to exterior decks or patios. I can’t think of anything similar that wasn’t really a window or door at its core. There are two requirements of emergency escape and rescue openings that sometimes get overlooked, but can cause significant issues if the enforcing agency decides to follow the letter of the law. As an aside, it is bothersome to me when enforcing agencies tend to read the code very black and white when it favors their implementation, but prefers to lean on the code intent when it doesn’t.
Open and Access to Public Way
The code is very clear that an emergency escape and rescue opening needs to open directly to the public way or to a yard or court that opens to a public way. An example of an opening to a public way would be a bedroom with a window that faces a street. An example of an opening into a yard that opens to a public way would be a bedroom on the side of a house that has a window that faces the side yard and the side yard has access to the front yard and eventually the street. These examples are typical. I recently did a project on a narrow lot that was bounded by two adjacent properties at the side with exterior decks along one side partially the depth of the lot. We initially assumed that emergency egress windows would be acceptable, but with further review we determined that we couldn’t meet the egress requirements and needed to modify how we were approaching the building design.
In Addition to Mean of Egress
Another requirement that seems to get glossed over is the requirement that the emergency escape and rescue windows are in addition to the means of egress. This is typically not an issue for most residential buildings. Means of egress access is provided front the interior of the building and emergency escape and rescue openings are provided at the exterior. In that scenario it is clear which one will serve as the means of egress and which one will serve as the emergency escape and rescue opening. I recently had a project where the front door of the small ADU unit was adjacent to front exterior windows that didn’t meet the size requirements to be egress windows. When I discussed this with the plan checker that brought it to my attention, I pointed out that the windows did not need to meet egress requirements because the door served that purpose. But I was wrong, because the front door was the means of egress and therefore could not also serve as the emergency escape and rescue opening. This was slightly frustrating since it seems to defy simple logic of how people would react in an emergency situation.
A final thought that was also reinforced in the last few months is that emergency escape and rescue openings are for both getting out of a building and getting into a building during an emergency. I think many times we are conscious of making sure people can get out in an emergency and that those people typically would be familiar with their surroundings (with respect to sleeping rooms) and act in a rational manner. This is not always the case and therefore those same openings need to provide a way for trained emergency workers to be able to assist and help those in need as much as possible.
Architect | Principal
Comments from Kerwin Lee, AIA: Escape and rescue openings are a part of an overall strategy to protect the occupants. This would include smoke alarms, to provide early warning. A building protected by an automatic sprinkler system almost eliminates the need for escape openings.
One aspect that the requirement for escape openings does not address is the special needs for people with disabilities and the elderly. To utilize an escape opening requires some physical ability. An opening above the floor or above the first story posses a problem for people with disabilities. The code is truly silent on this subject.