31B-004 Code Review example Cutter
This letter is based on the 8th edition Massachusetts State Building Code (MSBC) and the International Existing
Building Code (IEBC) as amended by Massachusetts. The purpose of this letter is to outline the design team’s
proposed approach with regard to means of egress from the basement level.
MEANS OF EGRESS – CODE APPROACH
The following approach has been developed by the design team in order to provide an adequate number,
capacity, and arrangement of means of egress from the basement level of the Cutter & Ziskind Building. This
approach has been developed in order to meet the requirements of the IEBC, as adopted and amended by the
MSBC and the requirements of MAAB.
Existing Conditions
The basement level is currently served by 2 remotely located, fully enclosed means of egress stairways (Stair 5
and Stair 6 on the attached drawings). Each stairway provides a clear width of approximately 43 inches, equating
to a total exit capacity of 344 occupants; the calculated occupant load of the basement is approximately 150
persons.
Currently, Stair 5 and Stair 6 both discharge to the interior of the building on the 1st floor. Upon leaving each
stairway, occupants must travel through the adjacent lobby in order to reach exit vestibule 100 (from Stair 5) or
exit vestibule 150 (from Stair 6). Each exit path maintains a clear width of at least 4 feet, from the stairway door
to the exit vestibule. Exit access travel distance and common path of travel comply with current MSBC
requirements. It should be noted that Stair 5 and Stair 6 also meet the current MSBC requirements to be
considered as accessible means of egress.
It is our understanding that there are no existing abatement orders or citations related to Stair 5 and/or Stair 6.
Code Requirements
IEBC
The proposed project is a substantial renovation using the Work Area Method, in accordance with IEBC Section
101.5.2; the scope of work constitutes “Alterations Level 3” and as such, the project is designed to comply with
IEBC Chapters 6, 7, and 8. The means of egress provisions of IEBC Chapters 6, 7, and 8 are primarily
concerned with items such as number of exits, means of egress lighting, dead end corridors, etc. and do not
directly address exit discharge. Therefore, IEBC does not require alterations to the Stair 5 or Stair 6.
The MSBC amendments to the IEBC add Section 102.2.2.1 “Existing Non-Conforming Means of Egress”. This
section addresses 4 specific means of egress conditions that are considered to be “non-conforming”, and
mandates retroactive correction, irrespective of project scope. That said, it is the opinion of the design team that
the existing conditions of Stair 5 and Stair 6 are not in violation of the aforementioned four “non-conforming”
examples and can remain as is.
CONCLUSION
It is our opinion that the existing means of egress stairways (Stair 5 and Stair 6) serving the basement level
provide safe and adequate means of egress for the expected occupant loads; the language of the MSBC does not
require alterations to the size, location, or arrangement of Stair 5 or Stair 6. The design team respectfully
requests approval to maintain Stair 5 and Stair 6 as shown on the attached drawings.
If you have any questions or comments, please do not hesitate to contact me.
102.2.2 Existing Hazardous Conditions. This section shall apply to all existing buildings
102.2.2.1 Existing Non Conforming Means of Egress. The following conditions shall
be corrected in all existing buildings:
1. Less than the number of means of egress serving every space and/or story,
required by Chapter 10 of the International Building Code 2009 with Massachusetts
Amendments (780 CMR 10.00);