Is FA "Common Use" Any Room with Two People?

7/28/2022

I'm in Code Enforcement in New York. I've never been completely comfortable as to where strobes are required in "common use and public use" areas.

I'm not talking about the obvious locations such as open areas, corridors , restrooms, conference rooms, etc. I'm talking smaller enclosed rooms such as offices, pantries, copy rooms, file rooms etc.

The definition of "Common Use" in the New York State Building Code is "Interior or exterior circulation paths, rooms, spaces or elements that are not for public use and are made available for the shared use of two or more people".

With respect to rooms, does "shared use of two or more people" relate to stations, desks, cubicles, etc, where people normally sit and/or work?

Or does it mean any space where at least two people can be in the room at the same time for any duration?

Another example is a doctor's office that has exam rooms that is classified as a Group B occupancy. The patient and medical professional can be in the room, or the patient can be alone for a period of time.

Should we consider exam rooms as public space?

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7 Comments

Pete H

7/28/2022 07:21:10 am

"With respect to rooms, does "shared use of two or more people" relate to stations, desks, cubicles, etc, where people normally sit and/or work?"

Certainly does, in my opinion.

"Or does it mean any space where at least two people can be in the room at the same time for any duration?"

Depends. Just because two interns at a hospital might hang out in a supply closet together, the supply closet still isn't a "common use" room. However just because an office is only designed for one main work desk, the moment that they've put that second chair on the other side of the desk for someone else to sit in when talking to the person behind the desk, now it's a "common use" room. It's more is the room intended for two people, but if it is intended for two people, that intent can apply to any duration. In my opinion.

"Should we consider exam rooms as public space?"

No, as you've established in the definition of common use rooms, the words are "spaces or elements that are not for public use". While "Public Space" is not identified, "[BE] PUBLIC-USE AREAS. Interior or exterior rooms or spaces that are made available to the general public." is included in the code. Since an exam room is still a room the patient has to be admitted into or allowed within, that exam room is certainly not a public space. In my opinion.

chad

7/28/2022 08:07:56 am

I have a building code official that interprets that anywhere the public could be in a public space and we have to mandate a strobe in every office unless there is a large glass sidelight or the door is glass and a strobe is outside it.

Its a bit draconian but if you rear the definition it fits.

For your example- I see exam rooms where the use in transient as a public space. Those areas are clearly occupied by the general public at some point and it can be more than one, IE- child/parent. Despite that not being a freely accessible space you just walk into.

7/28/2022 08:33:39 am

I usually look at the occupancy loads of rooms if provided. If the room has a occupancy of 2 or more I try to provide strobe coverage. I typically see doctors offices with strobes in the exam rooms, and have done a couple of jobs where we did install strobes in those rooms. I personally feel the code isn't 100% clear on the matter, but if I provide coverage in rooms with 2 or more people in the occupancy load I feel I'm covered by the public/common use rules. I have had an AHJ require a strobe in a room with an occupancy of 1 due to the size, but that seemed to be a one time thing.

Craig

7/28/2022 09:02:54 am

When I am trying to figure this our or try to have a conversation about these "Common use areas" I like to simply lay the facts out so the person I am having a discussion with can come up with their own interpretation on this. The definition of Common Use uses the word "shared use" of two or more versus the "occupant load" of two or more. That being said I think this code is written to leave it up to the AHJ on how they want to enforce this. I have taken snips of the IFC Handbook on the code and definition to help show the intent. The "Diamonds" are the explanatory material, always use the handbooks folks! It provides very valuable information.

907.5.2.3.1Public use areas and common use areas.
Visible alarm notification appliances shall be provided in public use areas and common use areas.
Exception: Where employee work areas have audible alarm coverage, the notification appliance circuits serving the employee work areas shall be initially designed with not less than 20-percent spare capacity to account for the potential of adding visible notification appliances in the future to accommodate hearing-impaired employee(s).
❖ Visible alarm notification appliances must provide coverage in all areas open to the public (use areas) as well as all shared or common use areas (e.g., corridors, public restrooms, shared offices, classrooms, medical exam rooms, etc.). Areas where visible alarm notification appliances are not required include private offices, mechanical rooms or similar spaces. The intent with this section is to replicate the provisions included in the Americans with Disabilities Act Standards for Accessible Design.
The exception allows employee work areas to provide only for spare capacity on notification circuits to allow for those with hearing impairments to be accommodated as necessary. This spare capacity is intended to eliminate the potential for overloading notification circuits when a hearing-impaired person is hired and needs to be accommodated, but reduces the initial construction cost as such alarm notification appliances may not be necessary in every situation.

COMMON USE. Interior or exterior circulation paths, rooms, spaces or elements that are not for public use and are made available for the shared use of two or more people.
❖ Some buildings include areas that are restricted to employees only or where public access is limited. Common-use spaces may be part of employee work areas but do not include public-use spaces. Any space that is shared by two or more persons, such as copy areas, break rooms, toilet rooms or circulation paths, are common use areas. A grade school classroom would be another example of a common-use space (see also the commentaries for the definition of “Public-use areas” and “Employee work area”).

EMPLOYEE WORK AREA. All or any portion of a space used only by employees and only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.
❖ An employee work area is different in an office versus on a factory line. An employee work area will most likely expand past the station or desk where an employee performs his or her job. An employee work area could include common use spaces, but not public use spaces. Depending on the duties of the employee, it may also include copy areas, stockrooms, filing areas, an assembly line, etc. (see also the commentaries for the definitions of “Common use” and “Public-use areas”).

PUBLIC-USE AREAS. Interior or exterior rooms or spaces that are made available to the general public.
❖ This term is utilized to describe all interior and exterior spaces or rooms that may be occupied by the general public for any amount of time. Spaces that are utilized by the general public may be located in facilities that are publicly or privately owned. Examples include the lobby in an office building, a high-school gymnasium with assembly seating, an openair stadium, a multipurpose room, an exposition hall, a restaurant dining room, a health club, etc. (see also the commentaries to the definitions of “Common use” and “Employee work area”).

Manny Rios

7/28/2022 12:29:38 pm

YES.
In our jurisdiction we deal with schools and associated support buildings. In compliance with the current code requirements the designers/AHJ have determined that all occupied areas shall have a notification device. In some smaller areas that are occupied by a least one person, a device needs to installed outside the door leading to said area and the doors left open.

sean

7/29/2022 05:31:46 am

Public - store front areas, anywhere you would have people come in by invitation

Work area - think private office

common area - copier room, warehouse, corridors that are in an employee only area, etc

Cory

7/29/2022 08:27:14 pm

I do not provide a strobe in a single person office if there is a chair or 2 across from the desk as the main use is single person office and multiple people are usually there for short periods. However, if a second desk and/or computer is provided, then it becomes a 2 person office in my opinion, requiring a strobe. Just my interpretation and i have never been challenged on it. I do not base it on the size as i have seen some executive offices that are single person and large and smaller intern offices with 2+ persons in it.

Is FA "Common Use" Any Room with Two People?

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