California Fire Code Exit Requirements

California Fire Code Requirements for Exits

Throughout California, the requirements for emergency exits from buildings are generally governed by a comprehensive set of fire codes. The primary intent of these requirements is to protect occupants of buildings by ensuring they have accessible and safe means of exiting in the event of an emergency, such as a fire. On the one hand, California building and residential codes serve to ensure that buildings are permanent structures, designed to last indefinitely. On the other hand, fire and life safety codes and standards are intended to ensure that those same structures are easily evacuated should something go wrong. For all types of buildings in California, manufacturers, owners and contractors are required to comply with these codes generally and with regard to exits specifically. The exact requirements for compliance vary among building types and relevant codes.
The California Building Standards Code includes requirements for exits in Chapter 10. Those requirements must be harmonized with the related requirements in the California Fire Code Chapter 10 and California’s residential code. Where the California Fire Code and California Building Code exit requirements overlap, the requirements of the Fire Code prevail. To balance potentially competing interests, the California Building Code and fire codes treat each type of exit somewhat differently. Evacuation characteristics of the occupants (i.e. mobility, senses, ability to recognize danger) are considered within this multi-pronged approach to exit requirements . The chapter requirements are complemented by the California Fire Code provisions contained in a section entitled "Means of Egress." Therein is a broad category of requirements regarding exits from buildings, including provisions for accessibility, width, capacity, location, termination points, door locations, hardware, panic hardware, latching mechanisms, and panic and deluge alarms.
Historically, codes developed from building officials concerned with preventing large-scale tragedies. From the time of the Great Fire of London in 1666 to today, codes have attempted to address the most concerning risks. In recent years, the increasing use of hazardous materials in all building sectors has significantly impacted requirements and practices. In turn, means of egress have become a higher priority. By current California Code: The California Code of Regulations Title 24 (California Fire Code) generally requires at each story a means of egress for every 75 feet of horizontal distance, and requires at least two exits if the occupancy has an occupant load of 50 or more. The means of egress must be unimpeded by furnishings or decorations that could be hazards in case of fire or panic. They must also be marked with the appropriate exit symbol as required by the California Building Code. A means of egress can be a horizontal path, a vertical path or a combination of both, including stairs, ramps and parking lot exit pathways.

Important Elements of Exits as per the Code

The California Fire Code imposes requirements upon owners of buildings and other structures to ensure that the spaces within their buildings have adequate egress in the event of an emergency, such as a fire. The key components that must be met in order to comply with the egress requirements of the California Fire Code are: exit accessibility, number of exits, door sizing and quantity, door swings, access path widths, and the stairs or ramps that function as exit paths.
Exit Accessibility
The exit path must be easily accessible to all occupants, which is why preliminary plans must take a thorough and detailed look at the configuration of an exit path, cabinet visibility in a space, and access to the exits. For instance, it is common for closets to be located adjacent to exit doors. This can cause issues if the door swings into a closet. In this situation, the intent is usually to require that the closet door be outfitted with either a pocket or bi-fold door so that when the exit door opens, it is immediately accessible without obstruction from the closet door. This is particularly important if the path of egress travels along a narrow corridor.
Number of Exits
The California Fire Code articulates minimum requirements for the number of exits required in a building or other structure. Factors which will effect the determination of the number of exits required include the number of stories in the building or structure, the occupancies involved, the square footage of the occupant space, and whether the space is equipped with sprinklers.
Exit Path Widths
The width of the exit path must be sufficient to provide for egress so that the entire population of the building can evacuate within a reasonable amount of time in case of an emergency. If parts of the exit path are too narrow, or obstructed, then the entire egress plans could be rendered useless, making the space dangerous for its occupants. It is common for the California Fire Code to require a wider exit path than what typical construction would allow for, since the typical construction will not account for possible obstructions that may be created during use. Retreating back to the example of the closet doors interfering with the exit paths, if a closet door opens into an exit path, and then the closet door obstructs the exit path, the code will require that the closet door be either a pocket or bi-fold type of door.

Requirements for Various Building Types

The California Fire Code (CFC) applies different exit requirements depending on the type of occupancy. For example, an Assembly occupancy requires two or more exits if the occupancy is located in a room with an occupant load greater than 50. The prescriptive commercial kitchens and mercantile occupancy regulations require that the exit discharge from other than one exit be directed to a public way or a parking area. In addition to those two examples, Assembly and Industrial occupancies require that exits be separated from one another and from interior spaces by 1-hour fire-resistive construction. The scope of each chapter of the California Fire reflects the unique risks posed by each occupancy as follows: In residential occupancies, each bedroom requires an outside window or door that opens directly to an unobstructed space equal to 20 inches high x 24 inches wide. Similarly, dwelling units with more than three stories require two exterior stairs, one of which be within 25 feet of the maximum travel distance to the nearest exit. In commercial kitchens, two exits are required if the area is greater than 50 square feet. Further, the exit door must swing outwards and be self-closing, thereby eliminating bottlenecks and preventing kitchen fires from extending to other parts of the building. Occupancies located indoors or away from the public right-of-way are subject to additional requirements. Some of these requirements include: directing egress toward a safe location or exterior exit location, entering into a smoke control area, coordinating crowd size with guards, and prohibiting smoking and open flames.

Provisions for Emergency Lighting and Signage

California’s exit requirements involve more considerations than merely the number of exits and the width of the doorways, although those requirements certainly demand full attention. Also important to egress design and analysis are the many emergency lighting and exit signage requirements in the California Fire Code (CFC) (most of which is based on the National Model Code). Emergency lighting and exit signage provide assistance to evacuees during an emergency. They may even prompt text messages for evacuation when the nature of an emergency is not readily apparent.
The emergency lighting requirement in CFC § 1008.2 requires illumination along required egress paths during emergencies. The emergency lighting must be provided automatically by a battery-powered electrical system that is separate from all other electrical systems. CFC § 1008.2.2 provides the minimum illumination levels (1 foot-candle measured along the path) as well as the required duration of the emergency lighting in the event of a power failure (not less than 90 minutes).
Illuminated exit signs, which are the only reliable indicator of egress paths in smoke obscured environments, are required by CFC § 1013. The brightness of an exit sign must be 5 foot-candles measured at location of exit discharge. If a sign is located less than 5 feet away from the final exit door, the sign’s brightness may be superimposed with or supplemented with, a back rechargeable battery power supply system that is permanently connected to the commercial power system. The sign must be automatically illuminated and remain illuminated during the entire time the general lighting system is interrupted. In addition, CFC § 1010 requires illuminated emergency exit signs that indicate doorways or passageways that may be used for emergency exit from any building.

Enforcement and Compliance Issues

A thorough understanding of the California fire code exit requirements is key to ensuring life safety in high-rise buildings. In addition to knowing these requirements, it is important to understand how they are enforced. This section describes the process of compliance with California fire code exit requirements, including the role of inspections, penalties for non-compliance, and resources available for building owners.
Buildings can be inspected by various entities during their lifetime. Every three years, the Fire Marshal from the local fire jurisdiction is required by the Health and Safety Code § 13146.4(a)(2) to conduct an inspection of existing high-rise buildings within its jurisdiction. In addition, the California Department of Industrial Relations, Division of Occupational Safety and Health (Cal-OSHA), conducts periodic inspections of workplace safety conditions.
Finally, the Fire Marshal can require that a qualified person or entity enter and inspect any building, structure or premises within its jurisdiction during regular working hours whenever the chief has "reasonable cause" to believe that fire, panic or related emergencies can occur. Cal. Health & Safety Code §§ 13146(b). The determination of what constitutes "reasonable cause" has been the subject of some litigation. For example, a recent case held that a "fire hazard" within Health and Safety Code sections 13114(b), 13114.5 should be defined as "an object, device or other thing which threatens, or potentially threatens, the life, health or safety of the occupants of a building" as opposed to a "physical object" that presents a threat to safety, regardless of whether there is a connection between the object and the life, health or safety of the occupants . City of Fremont v. Cal. Occupational Safety & Health Appeal Bd. 99 Cal.App.4th 1526, 1510 (Cal. 2002). Penal Code section 148.4 also provides a basis for enforcement.
Local fire jurisdictions are given the broad authority to adopt rules and regulations for their particular jurisdictions. Cal. Health & Safety Code § 13115; Cal. Health & Safety Code § 13869.5(a). Such local provisions are limited, however, by the state fire code requirements. Any provision that is less stringent or conflicts with the state provisions is void unless the local jurisdiction is specifically authorized to enact the regulation. Cal. Health & Safety Code § 13866. See also Cal. B&P Code §§ 19160, 19162. Violations of local ordinances can result in administrative citations or fines, or referral for prosecution, particularly where such violations are repeated. Cal. Gov. Code §§ 53069.4.
The state fire code requires that all high-rise buildings have mapped evacuation routes. Cal. Health & Safety Code §§ 13132.7, 13132.9, 13132.10. In addition, owners and operators of high-rise buildings have a duty to inform tenants, employees or other occupants of changes in existing access and exit procedures, or emergency response practices. Section 13869.47(b). This information must be provided at the time of occupancy and whenever the procedure is modified. Id. The Department of Housing and Community Development publishes an emergency response guide that building owners can obtain by request. They can also call the direct Emergency Response line at 1-800-300-4326.
The National Fire Protection Association (NFPA) has also published a guidebook for emergency responders that expounds on many of the issues already discussed in this article.

Recent Amendments and Future Directions

There have not been any major recent changes to the California fire code exit requirements. Installations, renovations, and retrofits, however-whether due to newly introduced technology or due to changing codes and regulations-do regularly occur. For example, manufacturers have introduced new products designed for facilities that experience high wind events. Such products include more durable doors that offer better resistance to wind and debris damage. In some cases, the energy codes also have updated provisions for egress strategies that could affect the design of exit requirements. In particular, if egress paths are also smoke compartments, additional smoke detection and alarm activiation systems are required.
We expect to see a greater number of high wind resistant products introduced in the coming years, especially in light of a major and destructive wildfire season in 2017 that affected numerous families and businesses in Northern California. Such an impact is expected to influence legislators to introduce new building standards for fire resistive doors, windows, and other active and passive fire resistive structures.
In regard to the movement of people within an assembly, the assembly occupancy exit width requirement is based on a number of variables. This means that the exit width requirement will change as occupancy density increases. Mechanical means of crowd control, whether by public agencies or private enterprises, are likely to evolve as legislators recognize the importance of moving large numbers of people efficiently and safeguarding the exit passageways against unforeseen hazards.

Best Practices for Compliance

Regular maintenance of emergency exit paths is essential to ensure compliance with the code and to ensure safe egress in emergencies. Many times owners or managers are unaware of the number of exits required because the property has been remodeled multiple times over the years without sufficient record keeping to know how many exits are required. In these instances owners can request from their local building department a questioning as to how many exits are required. In order to be sure that the building complies with any exit capacity requirements the owner should be aware of what occupancy classification the building most closely meets so that they can plan for the life safety systems needed in the future (i.e. sprinkler , fire alarm, smoke detection, panic hardware on doors, etc.). Recessed emergency lighting should be inspected during the regular overall building inspection program. Egress paths should be regularly inspected to make sure that nothing is blocking the path. Annual exit drills should be performed in the building so that staff are familiar with the proper response to an emergency where an exit may be required. Staff should be trained on monthly fire extinguisher checks, and required testing of fire alarms, panic hardware, door operation, smoke alarms, and other life safety systems.