The Life Safety Code is not an accessibility code. Accessibility for persons with disabilities is addressed by other laws and regulations, such as the Americans with Disabilities Act. However, the Code does recognize that many buildings are designed to accommodate people with severe mobility impairments (defined by the Code as the ability to move to stairs but without the ability to use the stairs). In such buildings, the Code might require accessible means egress to be provided. Simply stated, if a building is going to be made accessible to occupants with severe mobility impairments, it might need to be provided with an accessible path(s) of travel to the public way or to a safe location within the building. Areas of refuge are sometimes used to provide such safe locations within the building.
What is an area of refuge?
Two parts of the Code tell us what an area of refuge is. The first is the definition in 3.3.22 (2015 edition):
3.3.22* Area of Refuge. An area that is either (1) a story in a building where the building is protected throughout by an approved, supervised automatic sprinkler system and has not less than two accessible rooms or spaces separated from each other by smoke-resisting partitions; or (2) a space located in a path of travel leading to a public way that is protected from the effects of fire, either by means of separation from other spaces in the same building or by virtue of location, thereby permitting a delay in egress travel from any level. (SAF-MEA)
Part (1) of the definition indicates a floor of a fully sprinklered building is an area of refuge. It is assumed that an occupant with severe mobility impairment, if unable to get to the public way on their own, can remain on the floor of fire origin during the emergency because the automatic sprinkler system will either extinguish, or at least control, the fire. The one caveat is that the occupant must have access to a room other than the room of fire origin separated by smoke-resisting partitions to get away from the immediate effects of the fire (e.g., smoke, heat, and steam from the water discharged on the fire). Part (2) of the definition refers to what has been traditionally thought of as an area of refuge. The detailed requirements for these areas of refuge are found in 7.2.12. Areas of refuge described in Part (2) can be created by horizontal exits, or they can be fire rated enclosures that provide a means to get to the public way, perhaps with assistance, using an extra-wide stair or specially protected elevator, without having to leave the area of refuge and potentially re-enter the room or area of fire origin. If the sprinkler option in Part (1) of the definition is used, standard stairs and elevators can be utilized; this might serve as an incentive for building owners to install sprinklers where they are not otherwise required. In all cases, irrespective of sprinklers, areas of refuge require two-way communications systems to allow occupants with severe mobility impairments to let emergency personnel know they are in the building and require evacuation assistance.
When are areas of refuge needed?
In the context of the Life Safety Code, areas of refuge are means of egress components in the same way that doors, stairs, and ramps are means of egress components. As such, 7.2.12 does not mandate their use; they are permitted components in all occupancies. Areas of refuge become required when they serve as the termination points of accessible means of egress, which is defined in 184.108.40.206 as:
220.127.116.11 Accessible Means of Egress. A means of egress that provides an accessible route to an area of refuge, a horizontal exit, or a public way. (SAF-MEA)
The key question then becomes, “When are accessible means of egress required?” To answer that question, we have to look at 7.5.4, which requires accessible means of egress from areas accessible to people with severe mobility impairments, other than in existing buildings. Key point here: NFPA 101 exempts existing buildings from the requirements for accessible means of egress, so areas of refuge are not required in existing buildings by the Code.
If the ground floor of a building is accessible, accessible means of egress can likely be provided via a level or ramped path of travel that complies with ICC/ANSI A117.1, Accessible and Usable Buildings and Facilities, leading out to the public way – no areas of refuge are needed. On floors accessed by occupants with severe mobility impairment via elevators, areas of refuge will likely be needed to satisfy the requirement for accessible means of egress. Again, the areas of refuge can be elevator lobbies with specially protected elevators or oversized stair landings with extra-wide stairs… or horizontal exits can be used… or the building can be sprinklered and the owner no longer needs to worry about special (read expensive) stairs and/or elevators.
NFPA’s technical committees and staff work closely with the disability community to ensure its codes and standards, including NFPA 101, work in concert with other laws and regulations affecting accessibility. A concerted effort is made to avoid conflicts with other accessibility rules. It is NFPA’s goal to develop codes that will protect the broadest population possible, from the very young to the elderly, and from fully mobile occupants to those with severe mobility impairments.
Thanks for reading, and as always, stay safe.
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