ICC Code opinion confirms fire safety problems in Cornell’s Fine Arts Library

[Updated below: Feb. 27, 2019] I have just received written confirmation from a Senior Staff Architect at the International Code Council (ICC) that the unenclosed stairs in Cornell’s Fine Arts Library atrium are noncompliant with the International Building Code (IBC), and that the roof-top gallery above the atrium is also noncompliant as designed. The 2015 New York State Building Code is derived from the IBC and contains the same Code language cited in the Code opinion by ICC. Of course, this Code opinion has no legal force, but it does indicate that the fire safety problems I have identified are real and need to be addressed. Here is the written opinion in full: 


Date: Thursday, February 14, 2019 at 11:17 AM
Re:  2015 IBC Sections 404.6, 1005.3.1, 1017.3.1, 1019, 1023.1, 1023.2,
 
Question 1:  Can the path of egress travel to an exit pass through more than one adjacent story in an atrium?
 
Answer 1:  There is nothing saying someone could not follow the stairway in the atrium as a path of egress travel for as many stories as they wanted.  However, if the stairway in the atrium is a considered a required exit access stairway, the egress path for the required means of egress (i.e. number of exits off of a floor) can only go down one story till occupants could choose to move to the required exits (1006.3.1, 1017.3.1, 1019).  If the stairway in the atrium is considered a required exit stairway, while Section 1023.2 Exception 2 does allow for the atrium to meet the construction requirements for the exit stairway, the atrium must meet all the remaining provisions for an exit stairway in Section 1023, including termination at the exterior, not be used for any other purpose other than exit (e.g. no uses on the ground floor of the atrium) and no paths that go through the atrium to get to the 2nd exit.
 
Question 2:  Can an unenclosed interior exit stairway, as permitted in Section 1023.2 Exception 2, terminate in the middle of an atrium floor that is above the level of exit discharge.
 
Answer 2:  No.  Exit stairways must discharge directly to the exterior (1023.1) and cannot stop at an upper floor.  There are the options for the stairway to discharge through a lobby or vestibule (1028), however, this lobby cannot be within the stairway/atrium enclosure and it cannot be at other than the level of exit discharge.
 
Question 3:  Does an occupied roof (Group A-2 assembly) above an atrium need to be separated from the atrium with a 1-hour horizontal assembly?
 
Answer 3:  Yes, an atrium must be separated from occupied spaces.  While a roof is not a story, it is an occupied space, so it must be separated from the atrium where the floor of the occupied roof is over the atrium.  Where an occupied roof floor is around the atrium, a separation would not be required.
 
Code opinions issued by ICC staff are based on ICC-published codes and do not include local, state or federal codes, policies or amendments. This opinion is based on the information which you have provided. We have made no independent effort to verify the accuracy of this information nor have we conducted a review beyond the scope of your question. This opinion does not imply approval of an equivalency, specific product, specific design, or specific installation and cannot be published in any form implying such approval by the International Code Council. As this opinion is only advisory, the final decision is the responsibility of the designated authority charged with the administration and enforcement of this code.
 
I hope that this answers your question in full.  Please feel free to contact me again if you have any additional questions on this issue.
 
“Copyright © 2018 International Code Council, Inc. All rights reserved.”
 
Kimberly Paarlberg, RA
International Code Council
Codes and Standards, Senior Staff Architect
5332 Woodfield Drive, Carmel, IN
888-422-7233, Ext. 4306

 

[February 27, 2019 update: I just received a code interpretation from the New York State Division of Building Standards and Codes that agrees in full with the ICC answers shown above (“We reached the same conclusions as did the ICC representative, Kimberly Paarlberg”). I have forwarded their response to the City of Ithaca Director of Code Enforcement and other parties involved in this fiasco. Depending on how they react, I may well need to file a formal complaint.]

Links to all my writings on the Fine Arts Library at Cornell can be found here.

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