Who Evaluates Means of Egress?
Who evaluates “means of egress?”
So far in this series we’ve talked about what a means of egress is, why it’s important, and what the components that make up egress are.
But who cares?
That’s what we’re covering here in the segment.
Or, more specifically, who evaluates means of egress? Architects? Engineers? Building Owners? Landlords? Plan Reviewers? Fire Marshals? Let’s dive in.
BASICS OF ROLES AROUND EGRESS
First, let’s set some ground rules.
#1: There are many roles and responsibilities on a project with respect to means of egress. What follows are general guidelines but specific project circumstances, jurisdictional requirements and other factors could influence this.
#2: Generally speaking, the architect is the captain for the project. They are the point-person, the go-to, the manager for a smooth construction experience who is supposed to manage the design team and the owner’s expectations. They are often the party responsible for making sure egress components meet the building code. For most projects, this will be the case.
#3: Consultants can, and often do, help with egress. When there are novel, complex or unique situations, experts in this area can and do provide options for architects and building owners to navigate the intent of the building code and offer options for compliance.
A code consultant might establish the parameters for code compliance for means of egress at the schematic design level, they might review plans developed by the architect during design development and provide recommendations to comply with code, they may answer the architect’s questions about how to apply code to an unusual situations, and they may speak on behalf of the design team when meeting with code officials (since they can “speak code”), and they may develop code modification requests when required.
#4: If the AHJ doesn’t comment on it then I don’t have to follow code, right? Not at all. You can’t ignore a code requirement because it’s expensive, would ruin the design aesthetic, or because you simply disagree with it.
Furthermore, the AHJ review is more of a third-party check. They are not professionally responsible or liable or for ensuring buildings meet code. It is the design professional (typically the architect and their firm) that is held liable in situations where a building does not meet code.
DESIGN & CONSTRUCTION
Now, let’s differentiate between (1) the design and construction process, and (2) the much-longer lifetime of the building. What are the roles that impact means of egress?
Let’s start with the design and construction phase of a project.
DESIGN TEAM ROLES
For the design team on a construction project:
An architect is usually locating, sizing, and evaluating components of a building system for compliance. Especially if a project is small or simple. Typically, the architect as the registered design professional will seal the construction documents containing the means of egress design.
A code consultant (or “life safety specialist” or “fire protection engineer”) if present, could be a resource to answer a few questions on the project or they could take on much greater responsibilities. They could create plans, code summaries, and perform means of egress analysis. However, generally the code consultant does not seal construction documents for permit, even if they had a substantial role in developing them.
The contractual, professional, and ethical responsibilities between the architect and code consultant can vary by project and situation. Legally, you’d have to ask a lawyer to break this down for you. At the very least, an architect is responsible for the plans in which they prepare, and the consultant is responsible for the input they provide.
PLAN REVIEW ROLES
Plan review during the design phase:
…is often performed by a plan reviewer, building official, or fire marshal. They are responsible for reviewing construction documents, approving acceptable code modifications, and issuing permits for construction. Generally, this review is to ensure the building is safe to construct, safe to occupy, and has the required features for a fire department to effectively fight a fire. However, this review should be considered a “check.” It is still ultimately the responsibility of the Architect or other design professional to ensure buildings are designed to code or provide an equivalent level of safety.
Inspection is often by:
An inspector on behalf of the building department or the fire marshal. Like plan review, this can vary substantially. Some might perform a cursory review and check for unsafe conditions. Some might perform numerous exhaustive inspections and witness testing of all fire protection and life safety systems.
If a condition does not meet the approved plans or the inspector/fire marshal’s interpretation and enforcement of the code, a violation will be issued, and certificate of occupancy will not be granted until this is resolved.
Like plan review, this can be thought of as a third-party check. The inspector and fire marshal are not responsible for catching all code violations and are not held liable if they miss something.
If a building is not built to code exactly, who is responsible can get pretty murky, but it is not the inspector or fire marshal.
AFTER OCCUPANCY; BUILDING OWNER’S ROLE
Now, what about after a building gets a Certificate of Occupancy. Who’s responsible for egress over the life of the building?
That’s the building owner. Both IFC and NFPA 101 have requirements that buildings must be maintained in a safe manner. This includes ensuring means of egress are reliable, meaning they cannot be locked, blocked or otherwise rendered unusable by occupants.
This also includes using the building in a manner for which it isn’t designed, such as storing combustible or flammable materials in a manner that the building wasn’t designed for, which could impact the ability of occupants to evacuate safely.
Who checks up on egress over the life of a building?
Generally, an inspector or fire marshal will perform regular (usually annual) inspections. Like previously stated, the scope and frequency can vary substantially. These individuals are a supplement to achieve fire safety, not the responsible person. It is the owner who is responsible for maintaining the building in a safe manner and they are held legally responsible if the building is not.
So, who’s responsible for evaluating means of egress?
Primarily, it is the responsibility of the Architect (perhaps with input from a code/life safety consultant) to design a building with adequate means of egress. While plan reviewers and inspectors serve a role in ensuring buildings were designed to code, it is ultimately the responsibility of the Architect. Once a building is occupied, it is owner’s responsibility to continue to maintain the means of egress in a safe and reliable manner.
In our next segment, we’ll talk about what information is contained in a life safety plan.
I’m Steven Barrett, this is MeyerFire University.
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