Does Egress Apply to Car-Stacking Garage?

4/25/2023

Is there an egress requirement for a garage structure that only houses the car stacker, with 10 bays and 3 levels?

What would a code path be for or against such a requirement?

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8 Comments

Chad

4/25/2023 06:51:10 am

Its a "space" so yes.

2018IBC
1006.2 Egress from spaces. Rooms, areas or spaces, including
mezzanines, within a story or basement shall be provided
with the number of exits or access to exits in accordance with
this section.

1006.3.3 Single exits. A single exit or access to a single
exit shall be permitted from any story or occupied roof
where one of the following conditions exists:
1. The occupant load, number of dwelling units and common
path of egress travel distance do not exceed the
values in Table 1006.3.3(1) or 1006.3.3(2).
2. Rooms, areas and spaces complying with Section
1006.2.1 with exits that discharge directly to the
exterior at the level of exit discharge, are permitted
to have one exit or access to a single exit.
***3. Parking garages where vehicles are mechanically
parked shall be permitted to have one exit or access
to a single exit.****

Jesse

4/25/2023 08:10:50 am

From my time as the fire marshal for an AHJ, yes. Egress requirements always apply because its an occupiable space. Even presuming that only those with familiarity of the space will be within, a provision for their emergent egress must still be provided.

Todd E Wyatt

4/25/2023 08:45:24 am

SUMMARY
Yes, this parking garage is considered “occupied” and shall meet the Means of Egress requirements per its Occupancy Classification (OC).

EXPLANATION
Based on 2021 IBC, this Parking Garage (PG) is defined as a “MECHANICAL-ACCESS PARKING GARAGE” ... “parking garage that employs parking machines, lifts, elevators or other mechanical devices for vehicle moving from and to street level and in which public occupancy in the garage is prohibited in all areas except the vehicle access bay.”

The Occupancy Classification would be “Group S-2 Low-Hazard Storage.”

Per 406.5.7 Means of Egress, “... where persons other than parking attendants are NOT permitted, there shall be not fewer than two exit stairways. Each exit stairway shall be not less than 36 inches (914 mm) in width.”
Per 1006.3.4 Single Exits, “A single exit or access to a single exit shall be permitted from any story or occupied roof where one of the following conditions exists: 3. Parking garages where vehicles are mechanically parked shall be permitted to have one exit or access to a single exit.”

In cases where a GENERALrequirement (e.g. “parking garage ... one exit or access to a single exit ...”) conflicts with a more SPECIFIC requirement (““... where persons other than parking attendants are NOT permitted, there shall be not fewer than two exit stairways ...”), the specific requirement “shall be applicable” (see IBC 102.1 General). In this case, “406.5.7 Means of Egress” overrides “1006.3.4 Single Exits”.

The Parking Garage needs to be evaluated to determine whether it is ...

a. an “Open” or “Enclosed” Parking Garage, and
b. is the PG protected by an automatic sprinkler system (ASPS)

... since Travel Distances per “Chapter 10 Means of Egress” address these (2) parameters of Group S OCs :

1. COMMON PATH OF EGRESS TRAVEL DISTANCE (feet)
a. Group S
b. No ASPS = 100 Feet (Occupant Load <30) or 75 Feet (Occupant Load >30)
c. ASPS = 100 Feet
d. The length of common path of egress travel distance in a Group S-2 open parking garage shall be not more than 100 feet.
2. EXIT ACCESS TRAVEL DISTANCE
a. 75 Feet ... Group S (Parking Garages)
b. 100 Feet ... Group S (OPEN Parking Garages)
3. DEAD END
a. No ASPS = 20 Feet
b. ASPS = 50 Feet

Todd E Wyatt

4/25/2023 08:45:44 am

REFERENCES

2021 IBC
Chapter 1 Scope and Administration
Part 1 - Scope and Application
Section 101 Scope and General Requirements
Section 102 Applicability
102.1 General
Where there is a conflict between a general requirement and a specific requirement, the specific requirement shall be applicable. Where, in any specific case, different sections of this code specify different materials, methods of construction or other requirements, the most restrictive shall govern.

Chapter 2 Definitions
MECHANICAL-ACCESS ENCLOSED PARKING GARAGE. An enclosed parking garage that employs parking machines, lifts, elevators or other mechanical devices for vehicle moving from and to street level and in which public occupancy in the garage is prohibited in all areas except the vehicle access bay.
MECHANICAL-ACCESS OPEN PARKING GARAGES. Open parking garages employing parking machines, lifts, elevators or other mechanical devices for vehicles moving from and to street level and in which public occupancy is prohibited above the street level.
OPEN PARKING GARAGE. A structure or portion of a structure with the openings as described in Section 406.5.2 on two or more sides that is used for the parking or storage of private motor vehicles as described in Section 406.5.3.

Chapter 4 Special Detailed Requirements Based on Occupancy and Use
Section 401 Scope
401.1 Detailed Occupancy and Use Requirements
In addition to the occupancy and construction requirements in this code, the provisions of this chapter apply to the occupancies and use described herein.

Section 406 Motor-Vehicle-Related Occupancies
406.1 General
All motor-vehicle-related occupancies shall comply with Section 406.2.
Private garages and carports shall also comply with Section 406.3.
Open public parking garages shall also comply with Sections 406.4 and 406.5.
Enclosed public parking garages shall also comply with Sections 406.4 and 406.6.
Motor fuel-dispensing facilities shall also comply with Section 406.7.
Repair garages shall also comply with Section 406.8.

406.5 Open Parking Garages
406.5.7 Means of Egress
Where persons other than parking attendants are permitted, open parking garages shall meet the means of egress requirements of Chapter 10. Where persons other than parking attendants are not permitted, there shall be not fewer than two exit stairways. Each exit stairway shall be not less than 36 inches (914 mm) in width. Lifts shall be permitted to be installed for use of employees only, provided that they are completely enclosed by noncombustible materials.

Chapter 10 Means of Egress
Section 1006 Number of Exits and Exit Access Doorways
1006.3 Egress From Stories or Occupied Roofs
The means of egress system serving any story or occupied roof shall be provided with the number of separate and distinct exits or access to exits based on the aggregate occupant load served in accordance with this section.
1006.3.4 Single Exits
A single exit or access to a single exit shall be permitted from any story or occupied roof where one of the following conditions exists:
3. Parking garages where vehicles are mechanically parked shall be permitted to have one exit or access to a single exit.
TABLE 1006.3.4(2) STORIES WITH ONE EXIT OR ACCESS TO ONE EXIT FOR OTHER OCCUPANCIES
1. First story above or below grade plane ... S (Occupancy) ... MAXIMUM OCCUPANT LOAD PER STORY = 29 ... MAXIMUM EXIT ACCESS TRAVEL DISTANCE (feet) ... 75
2. Second story above grade plane ... S (Occupancy) ... MAXIMUM OCCUPANT LOAD PER STORY = 29 ... MAXIMUM EXIT ACCESS TRAVEL DISTANCE (feet) ... 75
3. Third story above grade plane and higher ... Not Permitted
4. The length of exit access travel distance in a Group S-2 open parking garage shall be not more than 100 feet.

1017.3 Measurement
Exit access travel distance shall be measured from the most remote point of each room, area or space along the natural and unobstructed path of horizontal and vertical egress travel to the entrance to an exit. Where more than one exit is required, exit access travel distance shall be measured to the nearest exit.
Exceptions:
1. In open parking garages, exit access travel distance is permitted to be measured to the closest riser of an exit access stairway or the closest slope of an exit access ramp.

1020.5 Dead Ends
Where more than one exit or exit access doorway is required, the exit access shall be arranged such that dead-end corridors do not exceed 20 feet (6096 mm) in length.
Exceptions:
1. In Group I-3, Condition 2, 3 or 4, occupancies, the dead end in a corridor shall not exceed 50 feet (15 240 mm).
2. In occupancies in Groups B, E, F, I-1, M, R-1, R-2, S and U, where the building is equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1, the length of the dead-end corridors shall not exceed 50 feet (15 240 mm).

Chad

4/25/2023 08:57:38 am

Do you really think that the true intent and spirit of the code is to require 2 exit stairways from a mechanically parked car assuming travel distances are met?

Otherwise why even add #3 to 1006.3.4?

It’s contradictory in all possible ways, totally useless. Sure they make errors but I have trouble believing that.

Todd E Wyatt

4/25/2023 09:16:24 am

Most AHJs do not consider the minimum requirements for the Means of Egress as "totally useless" and will (generally) require the "most restrictive" requirements in this case.

A Design Professional can always request an interpretation by the AHJ and the AHJ may agree that "1006.3.4 Single Exits" can be the minimum requirement.

If you continue reviewing this subsection (1006.3.4 Single Exits), TABLE 1006.3.4(2) STORIES WITH ONE EXIT, a single Exit Access is only permittable for the First and Second Stories, but not the Third Story.

Theoretically, Story 1-2 could have a single Exit Access but Story 3 would still require at least two Exit Access.

Chad

4/25/2023 09:28:19 am

Who said the bare minimum was “totally useless”? I stated a specific and contradictory section was. And called into question the intent.

The general requirement of chapter 10 you stated conflicts with the “specific requirement” of chapter 4… inferring it cannot be used.

Back to what is useless… what is the point of the general requirement allowing a single exit in a mechanically parked car space when it’s negated by the specific?

Glenn Berger

4/25/2023 09:44:23 am

Unless considered, confined space or similar, then then are egress rules to be used for all areas of all types of facilities.

Does Egress Apply to Car-Stacking Garage?

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