 Comparison of 2006 The International Fire Code (IFC) and OSHA Subpart E
(Means of Egress)

The purpose of this comparison is to determine if the 2006 edition of
The IFC provides employee protection equivalent to the Subpart E exit
route provisions, and is therefore able to serve as a compliance option
in addition to the NFPA Life Safety Code currently allowed by §1910.35.
The following analysis compares §1910.34, §1910.36, and §1910.37 to
the corresponding sections of the IFC. Portions of The IFC with no
relevant counterparts in these three sections of Subpart E are excluded.

The subpart E provisions (see first column) are very general in nature,
mostly performance oriented, and not intended to specifically cover
every specific situation in the infinite array of new and existing
buildings. The IFC is much more specific, containing very detailed
requirements (see portions in second column) tailored to 10 different
occupancy use groups. Subpart E comprises less than six pages of the
Code of Federal Regulations, while The IFC is a 408 page document. Many
features covered by the IFC are not addressed at all in Subpart E.

The third column addresses the similarities and differences between the
OSHA and the IFC, and each row contains a determination of the
suitability of the IFC–2006 to serve as an alternative compliance
option as discussed above. In many cases, the level of employee
protection provided by The IFC is equivalent to or exceeds the OSHA
standard. In some cases, commensurate protection is provided by The IFC.


To elaborate on the meaning of commensurate protection, the IFC contains
many provisions which are more detailed for the various occupancies and
use conditions. In a few cases, specific requirements in the IFC are
less stringent than the corresponding general Subpart E provisions, but
cover specific situations where the level of safety would be equivalent
to the general provision for one or more reasons, such as:

Occupancy type and/or occupant load is limited

Compensatory protection feature(s) are provided

Contemporary technology is available

The provisions are more detailed & comprehensive

The corresponding OSHA provision is optional

When a specific IFC provision is less stringent than subpart E but the
level of safety is equivalent, that particular provision is noted to be
commensurate. In the cases where the IFC is deemed to have commensurate
protection, it is suitable as a compliance alternative to Subpart E.
Stated differently, if a building was built and operated in compliance
with the IFC -2006, it would provide employee protection equal to or
greater than §1910.34, §1910.36, and §1910.37.

The 2006 edition of the International Building Code (IBC) was also
analyzed, and the means of egress requirements for new buildings were
found to be nearly identical to the IFC. The technical requirements in
the IBC means of egress chapter are repeated in the IFC means of egress
chapter. In addition, the IFC contains sections entitled “Means of
Egress for Existing Buildings” and “Maintenance of the Means of
Egress”, as well as references to the IBC for sections in other
chapters which are not duplicated in the IFC. The IFC provisions for
maintenance and existing buildings are necessary to achieve equivalency
with §1910.37. Therefore, it was determined that, with these
maintenance and existing building provisions, the IFC alone could
substitute for the Subpart E provisions, while the IBC could not.
Additionally, referencing a package of both the IBC and IFC as one
compliance option would not be necessary.

To summarize, this analysis has identified no instance where the
IFC-2006 provides a lower level of employee protection than Subpart E.
All corresponding provisions are deemed to provide employee protection
in excess of, equivalent with, or commensurate to the features of
Subpart E. Therefore, this analysis shows the IFC-2006 can be recognized
as a compliance alternative.

Subpart E	IFC (2006)	Comments

1910.34(a) 

Every employer is covered. 

Sections 1910.34 through 1910.39 apply to workplaces in general industry
except mobile workplaces such as vehicles or vessels.

	101.2 Scope. 

This code establishes regulations affecting or relating to structures,
processes, premises and safeguards regarding: 

1.     The hazard of fire and explosion arising from the storage,
handling or use of structures, materials or devices; 

2.     Conditions hazardous to life, property or public welfare in
the occupancy of structures or premises; 

3.     Fire hazards in the structure or on the premises from
occupancy or operation; 

4.     Matters related to the construction, extension, repair,
alteration or removal of fire suppression or alarm systems. 

1001.1 General. 

Buildings or portions thereof shall be provided with a means of egress
system as required by this chapter. The provisions of this chapter shall
control the design, construction and arrangement of means of egress
components required to provide an approved means of egress from
structures and portions thereof. Sections   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
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eld%20folio-destination-name:'IFC20061003'%5d$xhitlist_md=target-id=0-0-
0-2921" \t "main"  1003  through   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061026'%5d$xhitlist_md=target-id=0-0-
0-2923" \t "main"  1026  shall apply to new construction. Sections  
HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061027'%5d$xhitlist_md=target-id=0-0-
0-2925" \t "main"  1027  and   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061028'%5d$xhitlist_md=target-id=0-0-
0-2927" \t "main"  1028  shall apply to existing buildings. 	Both cover
new and existing buildings.

1910.38 and 1910.39 are not part of this analysis.

IFC protection is equivalent to Subpart E

1910.34(b) 

Exits routes are covered. 

The rules in §§ 1910.34 through 1910.39 cover the minimum requirements
for exit routes that employers must provide in their workplace so that
employees may evacuate the workplace safely during an emergency.
Sections 1910.34 through 1910.39 also cover the minimum requirements for
emergency action plans and fire prevention plans.

	101.3 Intent. 

The purpose of this code is to establish the minimum requirements
consistent with nationally recognized good practice for providing a
reasonable level of life safety and property protection from the hazards
of fire, explosion or dangerous conditions in new and existing
buildings, structures and premises and to provide safety to fire
fighters and emergency responders during emergency operations. 

	Both cover fire and other emergencies, however IFC coverage extends to
features other than exit routes. It also provides protection for
emergency response workers. The IFC is therefore more comprehensive than
E

1910.38 and 1910.39 are not part of this analysis.

E does not mention accessible means of egress implicitly. The IFC covers
this in Section 1007.

IFC protection exceeds Subpart E

1910.34(c) 

Definitions.	SECTION 1002 DEFINITIONS

SECTION 202 GENERAL DEFINITIONS	IFC definitions that follow are from
Sec. 1002 U.N.O.

Electroluminescent means a light-emitting capacitor. Alternating current
excites phosphor atoms when placed between the electrically conductive
surfaces to produce light. This light source is typically contained
inside the device.

  

Term not defined or used in IFC. However, there is no impact on employee
protection because E allows this device as an option – see discussion
under  1910.37(b)(6).

IFC is commensurate with Subpart E

Exit means that portion of an exit route that is generally separated
from other areas to provide a protected way of travel to the exit
discharge. An example of an exit is a two-hour fire resistance-rated
enclosed stairway that leads from the fifth floor of an office building
to the outside of the building. 

	EXIT. That portion of a means of egress system which is separated from
other interior spaces of a building or structure by
fire-resistance-rated construction and opening protectives as required
to provide a protected path of egress travel between the exit access and
the exit discharge. Exits include exterior exit doors at ground level,
exit enclosures, exit passageways, exterior exit stairs, exterior exit
ramps and horizontal exits.	IFC does not use the vague, undefined, and
hard to enforce term “generally”.

IFC definition is equivalent to Subpart E

Exit access means that portion of an exit route that leads to an exit.
An example of an exit access is a corridor on the fifth floor of an
office building that leads to a two-hour fire resistance-rated enclosed
stairway (the Exit). 

	EXIT ACCESS. That portion of a means of egress system that leads from
any occupied portion of a building or structure to an exit. 	

IFC definition is equivalent to Subpart E



Exit discharge means the part of the exit route that leads directly
outside or to a street, walkway, refuge area, public way, or open space
with access to the outside. An example of an exit discharge is a door at
the bottom of a two-hour fire resistance-rated enclosed stairway that
discharges to a place of safety outside the building. 	EXIT DISCHARGE.
That portion of a means of egress system between the termination of an
exit and a public way.	IFC only allows exit discharge to end at public
way or safe dispersal area (1024.6), and is therefore more protective.

Literal application of the OSHA definition allows an exit route to end
in a walkway, courtyard, or refuge area even if employees cannot get
from there to a public way.

IFC protection exceeds Subpart E

Exit route means a continuous and unobstructed path of exit travel from
any point within a workplace to a place of safety (including refuge
areas). An exit route consists of three parts: The exit access; the
exit; and, the exit discharge. (An exit route includes all vertical and
horizontal areas along the route.)	MEANS OF EGRESS. A continuous and
unobstructed path of vertical and horizontal egress travel from any
occupied portion of a building or structure to a public way. A means of
egress consists of three separate and distinct parts: the exit access,
the exit and the exit discharge.	OSHA changed the term MOE to Exit
Routes in 2002 plain language update. 

IFC is more protective by virtue of the difference in definition of the
exit discharge component (see above).

IFC protection exceeds Subpart E

High hazard area means an area inside a workplace in which operations
include high hazard materials, processes, or contents.

	202   High-hazard Group H. High-hazard Group H occupancy includes,
among others, the use of a building or structure, or a portion thereof,
that involves the manufacturing, processing, generation or storage of
materials that constitute a physical or health hazard in quantities in
excess of quantities allowed in control areas constructed and located as
required in Section   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
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eld%20folio-destination-name:'IFC20062703.8.3'%5d$xhitlist_md=target-id=
0-0-0-579" \t "main"  2703.8.3  . Hazardous uses are classified in
Groups H-1, H-2, H-3, H-4 and H-5 and shall be in accordance with this
code and the requirements of Section 415 of the International Building
Code . 

Exceptions: The following shall not be classified in Group H, but shall
be classified in the occupancy that they most nearly resemble . . .

	IFC contains a list of 15 threshold exceptions (not reproduced here),
and specifies hazardous material quantity thresholds in table
2703.8.3.2, rather than E’s performance language.

IFC definition is commensurate with Subpart E

Occupant load means the total number of persons that may occupy a
workplace or portion of a workplace at any one time. The occupant load
of a workplace is calculated by dividing the gross floor area of the
workplace or portion of a workplace by the occupant load factor for that
particular type of workplace occupancy. Information regarding "Occupant
load" is located in NFPA 101-2000, Life Safety Code. 	OCCUPANT LOAD. The
number of persons for which the means of egress of a building or portion
thereof is designed. 

1004.1 Design occupant load. 

In determining means of egress requirements, the number of occupants for
whom means of egress facilities shall be provided shall be determined in
accordance with this section. Where occupants from accessory areas
egress through a primary space, the calculated occupant load for the
primary space shall include the total occupant load of the primary space
plus the number of occupants egressing through it from the accessory
area. 

1004.1.1 Areas without fixed seating. 

The number of occupants shall be computed at the rate of one occupant
per unit of area as prescribed in Table   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
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eld%20folio-destination-name:'IFC2006T1004.1.1'%5d$xhitlist_md=target-id
=0-0-0-2973" \t "main"  1004.1.1  . For areas without fixed seating, the
occupant load shall not be less than that number determined by dividing
the floor area under consideration by the occupant per unit of area
factor assigned to the occupancy as set forth in Table   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006T1004.1.1'%5d$xhitlist_md=target-id
=0-0-0-2973" \t "main"  1004.1.1  . Where an intended use is not listed
in Table   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006T1004.1.1'%5d$xhitlist_md=target-id
=0-0-0-2973" \t "main"  1004.1.1  , the building official shall
establish a use based on a listed use that most nearly resembles the
intended use. 

	OSHA’s definition combines IFC Sec 1002 definition and Sec 1004
requirement.

IFC uses net instead of gross factors for educational & assembly
occupancies, which would yield lower occupant load and smaller exits.
However, 1910.36(f) would limit the occupant load proportionally.

The table of occupant load factors vs. function of space is not
reproduced here – all occupancies are covered.

IFC definition is commensurate with Subpart E



Refuge area means either:

(1) A space along an exit route that is protected from the effects of
fire by separation from other spaces within the building by a barrier
with at least a one-hour fire resistance-rating; or 

(2) A floor with at least two spaces, separated from each other by
smoke-resistant partitions, in a building protected throughout by an
automatic sprinkler system that complies with § 1910.159 of this part.
AREA OF REFUGE. An area where persons unable to use stairways can remain
temporarily to await instructions or assistance during emergency
evacuation. 

1007.6.2 Separation. 

Each area of refuge shall be separated from the remainder of the story
by a smoke barrier complying with Section 709 of the International
Building Code or a horizontal exit complying with Section   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
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eld%20folio-destination-name:'IFC20061022'%5d$xhitlist_md=target-id=0-0-
0-3031" \t "main"  1022  . Each area of refuge shall be designed to
minimize the intrusion of smoke. 

Exception: Areas of refuge located within a vertical exit enclosure. 

	OSHA’s definition combines IFC Sec 1002 definition and Sec 1007
requirement.

IBC Section 709 requires 1-hour rating of the smoke barrier, making it
equivalent to option (1) in E.

IFC does not have a sprinkler protection option equivalent to (2) in E,
however there is no impact on employee protection without this option.
Also, an area of refuge is not required by OSHA, but rather it is one of
the options for termination of exit discharge.

IFC definition is commensurate with Subpart E

Self-luminous means a light source that is illuminated by a
self-contained power source (e.g., tritium) and that operates
independently from external power sources. Batteries are not acceptable
self-contained power sources. The light source is typically contained
inside the device.

Term not defined or used in IFC because their use is limited to existing
devices. Even if the definition was different, there would be no impact
on employee protection because E allows this device as an option – see
discussion under 1910.37(b)(6).

IFC is commensurate with Subpart E



1910.36(a) 

Basic requirements. Exit routes must meet the following design and
construction requirements:

	 1001.1 General. 

Buildings or portions thereof shall be provided with a means of egress
system as required by this chapter. The provisions of this chapter shall
control the design, construction and arrangement of means of egress
components required to provide an approved means of egress from
structures and portions thereof. Sections   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061003'%5d$xhitlist_md=target-id=0-0-
0-2921" \t "main"  1003  through   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061026'%5d$xhitlist_md=target-id=0-0-
0-2923" \t "main"  1026  shall apply to new construction. Sections  
HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
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eld%20folio-destination-name:'IFC20061027'%5d$xhitlist_md=target-id=0-0-
0-2925" \t "main"  1027  and   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061028'%5d$xhitlist_md=target-id=0-0-
0-2927" \t "main"  1028  shall apply to existing buildings. 

	

IFC is equivalent to Subpart E

1910.36(a)(1) 

An exit route must be permanent. Each exit route must be a permanent
part of the workplace.

	1001.2 Minimum requirements. 

It shall be unlawful to alter a building or structure in a manner that
will reduce the number of exits or the capacity of the means of egress
to less than required by this code.. 

1028.1 General. 

The means of egress for buildings or portions thereof shall be
maintained in accordance with this section. 

	OSHA does not define permanent.

IFC does not use the word permanent, however all requirements dictate
built-in construction features as well as requiring that they be
maintained in place.

IFC is equivalent to Subpart E

1910.36(a)(2) 

An exit must be separated by fire resistant materials. Construction
materials used to separate an exit from other parts of the workplace
must have a one-hour fire resistance-rating if the exit connects three
or fewer stories and a two-hour fire resistance-rating if the exit
connects four or more stories.

	1020.1 Enclosures required. 

Interior exit stairways and interior exit ramps shall be enclosed with
fire barriers constructed in accordance with Section 706 of the
International Building Code or horizontal assemblies constructed in
accordance with Section 711 of the International Building Code, or both.
Exit enclosures shall have a fire-resistance rating of not less than 2
hours where connecting four stories or more and not less than 1 hour
where connecting less than four stories. The number of stories connected
by the exit enclosure shall include any basements but not any
mezzanines. An exit enclosure shall not be used for any purpose other
than means of egress. 

Exceptions . . . 

	

The nine exceptions to IFC 1020.1 either have compensatory features such
as sprinkler protection, use limitations, or size limitations, or they
apply to open buildings (or portions thereof) where the enclosure would
not be needed for protection.  

Additionally, IFC addresses the enclosure of vertical openings that are
not exits (704) and rating of exit access corridors (1017).

IFC protection is commensurate with Subpart E



1910.36(a)(3) 

Openings into an exit must be limited. An exit is permitted to have only
those openings necessary to allow access to the exit from occupied areas
of the workplace, or to the exit discharge. 

An opening into an exit must be protected by a self-closing fire door
that remains closed or automatically closes in an emergency 

upon the sounding of a fire alarm or employee alarm system. 

Each fire door, including its frame and hardware, must be listed or
approved by a nationally recognized testing laboratory. Section
1910.155(c)(3)(iv)(A) of this part defines "listed" and § 1910.7 of
this part defines a "nationally recognized testing laboratory."

	1020.1.1 Openings and penetrations. 

Exit enclosure opening protectives shall be in accordance with the
requirements of Section 715 of the International Building Code . 

Except as permitted in Section 402.4.6 of the International Building
Code , openings in exit enclosures other than unprotected exterior
openings shall be limited to those necessary for exit access to the
enclosure from normally occupied spaces and for egress from the
enclosure. 

Where interior exit enclosures are extended to the exterior of a
building by an exit passageway, the door assembly from the exit
enclosure to the exit passageway shall be protected by a fire door
assembly conforming to the requirements in Section 715.4 of the
International Building Code . Fire door assemblies in exit enclosures
shall comply with Section 715.4.4 of the International Building Code . 

Elevators shall not open into an exit enclosure. 

	

IBC 715 (mandatory ref. in IFC) also allows equivalently rated glazing,
shutters.

IBC 712 also allows equivalently rated penetration seals.

The IBC 402.4.6 exception covers service areas fronting on exit
passageways – a feature that is not explicitly covered by E.

IBC 715.4 covers the rating of doors in exit enclosures, while E is
silent on rating.

IBC 715.4.7 requires doors to be self- or automatic closing. 

IBC 715.4.7.3 requires smoke detection activation for most doors, while
E allows any fire alarm activation (could be manual, heat, or
sprinkler).

IBC 715.4 covers listing and test methods. Additionally, it goes on to
require labeling.

IFC protection is commensurate with or exceeds Subpart E

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(b)"  1910.36(b)  

The number of exit routes must be adequate.

	1001.1 General. 

Buildings or portions thereof shall be provided with a means of egress
system as required by this chapter. The provisions of this chapter shall
control the design, construction and arrangement of means of egress
components required to provide an approved means of egress from
structures and portions thereof. Sections   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
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eld%20folio-destination-name:'IFC20061003'%5d$xhitlist_md=target-id=0-0-
0-2921" \t "main"  1003  through   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061026'%5d$xhitlist_md=target-id=0-0-
0-2923" \t "main"  1026  shall apply to new construction. Sections  
HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
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eld%20folio-destination-name:'IFC20061027'%5d$xhitlist_md=target-id=0-0-
0-2925" \t "main"  1027  and   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061028'%5d$xhitlist_md=target-id=0-0-
0-2927" \t "main"  1028  shall apply to existing buildings. 

	

IFC protection is equivalent to Subpart E, in conjunction with sections
below

1910.36(b)(1) 

Two exit routes. At least two exit routes must be available in a
workplace to permit prompt evacuation of employees and other building
occupants during an emergency, except as allowed in paragraph (b)(3) of
this section. 

The exit routes must be located as far away as practical from each other
so that if one exit route is blocked by fire or smoke, employees can
evacuate using the second exit route.

	1019.1 Minimum number of exits. 

All rooms and spaces within each story shall be provided with and have
access to the minimum number of approved independent exits required by
Table   HYPERLINK
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ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006T1019.1'%5d$xhitlist_md=target-id=0
-0-0-3343" \t "main"  1019.1  based on the occupant load of the story,
except as modified in Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061015.1'%5d$xhitlist_md=target-id=0-
0-0-3017" \t "main"  1015.1  or   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061019.2'%5d$xhitlist_md=target-id=0-
0-0-3317" \t "main"  1019.2  . For the purposes of this chapter,
occupied roofs shall be provided with exits as required for stories. The
required number of exits from any story, basement or individual space
shall be maintained until arrival at grade or the public way. 

1014.3 Common path of egress travel. 

In occupancies other than Groups H-1, H-2 and H-3, the common path of
egress travel shall not exceed 75 feet (22 860 mm). In Group H-1, H-2
and H-3 occupancies, the common path of egress travel shall not exceed
25 feet (7620 mm). For common path of egress travel in Group A
occupancies having fixed seating, see Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061025.8'%5d$xhitlist_md=target-id=0-
0-0-3023" \t "main"  1025.8  . 

Exceptions: 

1.     The length of a common path of egress travel in Group B, F and
S occupancies shall not be more than 100 feet (30 480 mm), provided that
the building is equipped throughout with an automatic sprinkler system
installed in accordance with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006903.3.1.1'%5d$xhitlist_md=target-id
=0-0-0-663" \t "main"  903.3.1.1  . 

2.     Where a tenant space in Group B, S and U occupancies has an
occupant load of not more than 30, the length of a common path of egress
travel shall not be more than 100 feet (30 480 mm). 

3.     The length of a common path of egress travel in a Group I-3
occupancy shall not be more than 100 feet (30 480 mm). 

4.     The length of a common path of egress travel in a Group R-2
occupancy shall not be more than 125 feet (38 100 mm), provided that the
building is protected throughout with an approved automatic sprinkler
system in accordance with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006903.3.1.1'%5d$xhitlist_md=target-id
=0-0-0-663" \t "main"  903.3.1.1  . 

1015.2.1 Two exits or exit access doorways. 

Where two exits or exit access doorways are required from any portion of
the exit access, the exit doors or exit access doorways shall be placed
a distance apart equal to not less than one-half of the length of the
maximum overall diagonal dimension of the building or area to be served
measured in a straight line between exit doors or exit access doorways.
Interlocking or scissor stairs shall be counted as one exit stairway. 

Exceptions: 

1.     Where exit enclosures are provided as a portion of the
required exit and are interconnected by a 1-hour fire-resistance-rated
corridor conforming to the requirements of Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061017'%5d$xhitlist_md=target-id=0-0-
0-3263" \t "main"  1017  , the required exit separation shall be
measured along the shortest direct line of travel within the corridor. 

2.     Where a building is equipped throughout with an automatic
sprinkler system in accordance with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006903.3.1.1'%5d$xhitlist_md=target-id
=0-0-0-663" \t "main"  903.3.1.1  or   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006903.3.1.2'%5d$xhitlist_md=target-id
=0-0-0-665" \t "main"  903.3.1.2  , the separation distance of the exit
doors or exit access doorways shall not be less than one-third of the
length of the maximum overall diagonal dimension of the area served. 

	This one paragraph of E combines three concepts: number of exits,
common path of exit access, and remoteness of exits.

Table 1019.1 provides for 2 exits from 1-500 occupants, 3 for 501-1000
and 4 for more than 1000.

Additionally, Table 1027.17.2 specifies common path limits for each
existing occupancy type, rather that the performance language in E

Exception 1 to 1014.3 specifies measurement method. 

Exception 2 contains compensatory sprinkler protection. 

Exception 3 applies only to institutional. 

Exception 4 applies to residential. 

Exception 1 to 1015.2.1 specifies measurement method.  

Exception 2 reduces the distance to one-third with compensatory
sprinkler protection.

Additionally, the IFC addresses travel distance in Section 1016, while E
is silent on this concept.

IFC protection is commensurate with or exceeds Subpart E



1910.36(b)(2) 

More than two exit routes. More than two exit routes must be available
in a workplace if the number of employees, the size of the building, its
occupancy, or the arrangement of the workplace is such that all
employees would not be able to evacuate safely during an emergency.
1015.1.1 Three or more exits. 

Access to three or more exits shall be provided from a floor area where
required by Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061019.1'%5d$xhitlist_md=target-id=0-
0-0-3019" \t "main"  1019.1  . 

1019.1 Minimum number of exits. 

All rooms and spaces within each story shall be provided with and have
access to the minimum number of approved independent exits required by
Table   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006T1019.1'%5d$xhitlist_md=target-id=0
-0-0-3343" \t "main"  1019.1  based on the occupant load of the story,
except as modified in Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061015.1'%5d$xhitlist_md=target-id=0-
0-0-3017" \t "main"  1015.1  or   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061019.2'%5d$xhitlist_md=target-id=0-
0-0-3317" \t "main"  1019.2  . For the purposes of this chapter,
occupied roofs shall be provided with exits as required for stories. The
required number of exits from any story, basement or individual space
shall be maintained until arrival at grade or the public way. 

	IFC table 1019.1 specifies 3 exits for 501-1000 occupants and 4 for
more than 1000, while E uses performance language.

IFC protection is commensurate with Subpart E

1910.36(b)(3) 

A single exit route. A single exit route is permitted where the number
of employees, the size of the building, its occupancy, or the
arrangement of the workplace is such that all employees would be able to
evacuate safely during an emergency. 

Note to paragraph 1910.36(b): For assistance in determining the number
of exit routes necessary for your workplace, consult NFPA 101-2000, Life
Safety Code.

	1019.2 Buildings with one exit. 

Only one exit shall be required in buildings as described below: 

1.     Buildings described in Table   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006T1019.2'%5d$xhitlist_md=target-id=0
-0-0-3349" \t "main"  1019.2  , provided that the building has not more
than one level below the first story above grade plane. 

2.     Buildings of Group R-3 occupancy. 

3.     Single-level buildings with the occupied space at the level of
exit discharge provided that the story or space complies with Section  
HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061015.1'%5d$xhitlist_md=target-id=0-
0-0-3017" \t "main"  1015.1  as a space with one means of egress. 

	

Table 1019.2 (not reproduced here) gives specific thresholds (number of
stories, number of occupants, and maximum travel distance) for various
occupancy types, rather than the performance language in E

Exception 2 is for residential.

Exception 3 is redundant with portions of table 1019.2.

IFC protection is commensurate with Subpart E

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(b)"  1910.36(c)  

Exit discharge.

Title only – requirements follow



  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(c)(1)" 
1910.36(c)(1)  

Each exit discharge must lead directly outside or to a street, walkway,
refuge area, public way, or open space with access to the outside.

	1024.1 General. 

Exits shall discharge directly to the exterior of the building. The exit
discharge shall be at grade or shall provide direct access to grade. The
exit discharge shall not reenter a building. 

Exceptions: 

1.     A maximum of 50 percent of the number and capacity of the exit
enclosures is permitted to egress through areas on the level of
discharge provided all of the following are met . . .  

2.     A maximum of 50 percent of the number and capacity of the exit
enclosures is permitted to egress through a vestibule provided all of
the following are met . . .

3.     Stairways in open parking garages complying with Section  
HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061020.1'%5d$xhitlist_md=target-id=0-
0-0-3039" \t "main"  1020.1  , Exception 5, are permitted to egress
through the open parking garage at the level of exit discharge. 

	

IFC Exceptions 1 & 2 address discharge through level of exit discharge
or through vestibules, with compensatory protection such as sprinkler
protection or fire resistance rating. Exception 3 is for open-air
parking garages which are not prone to containing heat or smoke. Literal
application of E would not allow these commonly used options for
discharge…. And would allow an exit route to end in a walkway,
courtyard, or refuge area even if employees cannot get from there to a
public way.

IFC protection is commensurate with Subpart E

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(c)(2)" 
1910.36(c)(2)  

The street, walkway, refuge area, public way, or open space to which an
exit discharge leads must be large enough to accommodate the building
occupants likely to use the exit route.

	1024.2 Exit discharge capacity. 

The capacity of the exit discharge shall be not less than the required
discharge capacity of the exits being served. 

1024.6 Access to a public way. 

The exit discharge shall provide a direct and unobstructed access to a
public way. 

Exception: Where access to a public way cannot be provided, a safe
dispersal area shall be provided where all of the following are met: 

1.     The area shall be of a size to accommodate at least 5 square
feet (0.28 m 2 ) for each person. 

2.     The area shall be located on the same lot at least 50 feet (15
240 mm) away from the building requiring egress. 

3.     The area shall be permanently maintained and identified as a
safe dispersal area. 

4.     The area shall be provided with a safe and unobstructed path
of travel from the building. 

	IFC requires access to a public way or safe dispersal per 1024.6
(including specific size & location requirements in the exception),
rather that the performance language in E.

 

E does not define “large enough” or “likely”.

IFC protection is commensurate with Subpart E

1910.36(c)(3) 

Exit stairs that continue beyond the level on which the exit discharge
is located must be interrupted at that level by doors, partitions, or
other effective means that clearly indicate the direction of travel
leading to the exit discharge. 	1020.1.5 Discharge identification
barrier. 

A stairway in an exit enclosure shall not continue below the level of
exit discharge unless an approved barrier is provided at the level of
exit discharge to prevent persons from unintentionally continuing into
levels below. Directional exit signs shall be provided as specified in
Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061011'%5d$xhitlist_md=target-id=0-0-
0-3215" \t "main"  1011  . 

1027.18 Stairway discharge identification. 

A stairway in an exit enclosure which continues below the level of exit
discharge shall be arranged and marked to make the direction of egress
to a public way readily identifiable. 

Exception: Stairs that continue one-half story beyond the level of exit
discharge need not be provided with barriers where the exit discharge is
obvious. 

	UFC requires both the interruption barrier and the directional exit
signs.

IFC gives the threshold at which the interruption barrier is required,
while E uses performance language.

IFC protection exceeds Subpart E



  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(d)"  1910.36(d)  

An exit door must be unlocked.

Title only – requirements follow

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(d)(1)" 
1910.36(d)(1)  

Employees must be able to open an exit route door from the inside at all
times without keys, tools, or special knowledge. A device such as a
panic bar that locks only from the outside is permitted on exit
discharge doors.	1008.1.8 Door operations. 

Except as specifically permitted by this section egress doors shall be
readily openable from the egress side without the use of a key or
special knowledge or effort. 

1008.1.9 Panic and fire exit hardware. 

Each door in a means of egress from a Group A or E occupancy having an
occupant load of 50 or more and any Group H occupancy shall not be
provided with a latch or lock unless it is panic hardware or fire exit
hardware. 

Exception: A main exit of a Group A occupancy in compliance with Section
  HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061008.1.8.3'%5d$xhitlist_md=target-i
d=0-0-0-3103" \t "main"  1008.1.8.3  , Item 2. 

Electrical rooms with equipment rated 1,200 amperes or more and over 6
feet (1829 mm) wide that contain overcurrent devices, switching devices
or control devices with exit access doors must be equipped with panic
hardware and doors must swing in the direction of egress. 

	The IFC wording “egress side” is more protective than OSHA’s
“inside” for courtyard situations.

Panic hardware is required by IFC in high-risk occupancies, while E only
allows its use.

IFC protection exceeds Subpart E



  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(d)(2)" 
1910.36(d)(2)  

Exit route doors must be free of any device or alarm that could restrict
emergency use of the exit route if the device or alarm fails.	

1008.1.3.2 Power-operated doors. 

1008.1.3.4 Access-controlled egress doors.

1008.1.3.5 Security grilles.

1008.1.8.4 Bolt locks.

1008.1.8.6 Delayed egress locks.	These IFC sections give detailed
requirements for these commonly used features, rather than the
performance language in E.

IFC protection is commensurate with Subpart E

1910.36(d)(3) 

An exit route door may be locked from the inside only in mental, penal,
or correctional facilities and then only if supervisory personnel are
continuously on duty and the employer has a plan to remove occupants
from the facility during an emergency.

	1008.1.8.3 Locks and latches. 

Locks and latches shall be permitted to prevent operation of doors where
any of the following exists: 

1.     Places of detention or restraint. 

2.     In buildings in occupancy Group A having an occupant load of
300 or less, Groups B, F, M and S, and in places of religious worship,
the main exterior door or doors are permitted to be equipped with
key-operated locking devices from the egress side provided: 

2.1.     The locking device is readily distinguishable as locked, 

2.2.     A readily visible durable sign is posted on the egress side
on or adjacent to the door stating: THIS DOOR TO REMAIN UNLOCKED WHEN
BUILDING IS OCCUPIED. The sign shall be in letters 1 inch (25 mm) high
on a contrasting background, 

2.3.     The use of the key-operated locking device is revokable by
the fire code official for due cause. 

3.     Where egress doors are used in pairs, approved automatic flush
bolts shall be permitted to be used, provided that the door leaf having
the automatic flush bolts has no doorknob or surface-mounted hardware. 

4.     Doors from individual dwelling or sleeping units of Group R
occupancies having an occupant load of 10 or less are permitted to be
equipped with a night latch, dead bolt or security chain, provided such
devices are openable from the inside without the use of a key or tool. 	

IFC exception 1 is equivalent to E wording. 

Other exceptions have compensatory protection features, or apply only to
residential.

Additionally, IFC goes on to address stair re-entry in 1008.8.7.

IFC protection is commensurate with Subpart E

1910.36(e) 

A side-hinged exit door must be used.



Title only – requirements follow

1910.36(e)(1) 

A side-hinged door must be used to connect any room to an exit route.

	1008.1.2 Door swing. 

Egress doors shall be side-hinged swinging. 

Exceptions: 

1.     Private garages, office areas, factory and storage areas with
an occupant load of 10 or less. 

2.     Group I-3 occupancies used as a place of detention. 

3.     Critical or intensive care patient rooms within suites of
health care facilities. 

4.     Doors within or serving a single dwelling unit in Groups R-2
and R-3. 

5.     In other than Group H occupancies, revolving doors complying
with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061008.1.3.1'%5d$xhitlist_md=target-i
d=0-0-0-3073" \t "main"  1008.1.3.1  . 

6.     In other than Group H occupancies, horizontal sliding doors
complying with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061008.1.3.3'%5d$xhitlist_md=target-i
d=0-0-0-1311" \t "main"  1008.1.3.3  are permitted in a means of egress.


7.     Power-operated doors in accordance with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061008.1.3.2'%5d$xhitlist_md=target-i
d=0-0-0-3077" \t "main"  1008.1.3.2  . 

8.     Doors serving a bathroom within an individual sleeping unit in
Group R-1. 

	

The 8 IFC exceptions have compensatory features such as limited occupant
load, staff procedures, apply only to residential, or apply to commonly
used features such as revolving doors, sliding doors, and power operated
doors (which would be precluded by literal application of E).

IFC protection is commensurate with Subpart E

1910.36(e)(2) 

The door that connects any room to an exit route must swing out in the
direction of exit travel if the room is designed to be occupied by more
than 50 people or if the room is a high hazard area (i.e., contains
contents that are likely to burn with extreme rapidity or explode).
1008.1.2 Door swing. 

 

Doors shall swing in the direction of egress travel where serving an
occupant load of 50 or more persons or a Group H occupancy. 

Doors shall swing in the direction of egress travel where serving an
occupant load of 50 or more persons or a Group H occupancy.	

IFC is slightly more protective (when the occupant load is exactly 50).

Additionally, IFC goes on to address door force limits at the end of
section 1008.1.2.

IFC protection exceeds Subpart E

1910.36(f) 

The capacity of an exit route must be adequate.



Title only – requirements follow

1910.36(f)(1) 

Exit routes must support the maximum permitted occupant load for each
floor served.

	1005.1 Minimum required egress width. 

The means of egress width shall not be less than required by this
section. The total width of means of egress in inches (mm) shall not be
less than the total occupant load served by the means of egress
multiplied by the factors in Table   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006T1005.1'%5d$xhitlist_md=target-id=0
-0-0-2995" \t "main"  1005.1  and not less than specified elsewhere in
this code. Multiple means of egress shall be sized such that the loss of
any one means of egress shall not reduce the available capacity to less
than 50 percent of the required capacity. The maximum capacity required
from any story of a building shall be maintained to the termination of
the means of egress. 

	IFC table 1005.1 gives specific egress width factors depending on
occupancy types and sprinkler protection.

IFC is more stringent on the distribution of the egress capacity when
multiple exits are required.

IFC protection exceeds Subpart E

1910.36(f)(2) 

The capacity of an exit route may not decrease in the direction of exit
route travel to the exit discharge. 

Note to paragraph 1910.36(f): Information regarding "Occupant load" is
located in NFPA 101-2000, Life Safety Code.

	1003.6 Means of egress continuity. 

The path of egress travel along a means of egress shall not be
interrupted by any building element other than a means of egress
component as specified in this chapter. Obstructions shall not be placed
in the required width of a means of egress except projections permitted
by this chapter. The required capacity of a means of egress system shall
not be diminished along the path of egress travel. 

	

IFC protection is equivalent to Subpart E



1910.36(g) 

An exit route must meet minimum height and width requirements.

Title only – requirements follow

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(g)(1)" 
1910.36(g)(1)  

The ceiling of an exit route must be at least seven feet six inches (2.3
m) high. 

Any projection from the ceiling must not reach a point less than six
feet eight inches (2.0 m) from the floor.

	1003.2 Ceiling height. 

The means of egress shall have a ceiling height of not less than 7 feet
6 inches (2286 mm). 

Exceptions: 

1.     Sloped ceilings in accordance with Section 1208.2 of the
International Building Code . 

2.     Ceilings of dwelling units and sleeping units within
residential occupancies in accordance with Section 1208.2 of the
International Building Code . 

3.     Allowable projections in accordance with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061003.3'%5d$xhitlist_md=target-id=0-
0-0-2937" \t "main"  1003.3  . 

4.     Stair headroom in accordance with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061009.2'%5d$xhitlist_md=target-id=0-
0-0-2939" \t "main"  1009.2  . 

5.     Door height in accordance with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061008.1.1'%5d$xhitlist_md=target-id=
0-0-0-2941" \t "main"  1008.1.1  . 

1003.3 Protruding objects. 

Protruding objects shall comply with the requirements of Sections  
HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061003.3.1'%5d$xhitlist_md=target-id=
0-0-0-2943" \t "main"  1003.3.1  through   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061003.3.4'%5d$xhitlist_md=target-id=
0-0-0-2945" \t "main"  1003.3.4  . 

1003.3.1 Headroom. 

Protruding objects are permitted to extend below the minimum ceiling
height required by Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061003.2'%5d$xhitlist_md=target-id=0-
0-0-2935" \t "main"  1003.2  provided a minimum headroom of 80 inches
(2032 mm) shall be provided for any walking surface, including walks,
corridors, aisles and passageways. Not more than 50 percent of the
ceiling area of a means of egress shall be reduced in height by
protruding objects. 

Exception: Door closers and stops shall not reduce headroom to less than
78 inches (1981 mm). 

    A barrier shall be provided where the vertical clearance is less
than 80 inches (2032 mm) high. The leading edge of such a barrier shall
be located 27 inches (686 mm) maximum above the floor. 

	

IFC has specific, less stringent provisions for headroom & projections
for sloped ceilings, residential occupancies, door closers, and door
stops. Literal application of E would preclude these common features.

Additionally, IFC goes on to address free-standing objects in 1003.3.2.

IFC protection is commensurate with Subpart E

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(g)(2)" 
1910.36(g)(2)  

An exit access must be at least 28 inches (71.1 cm) wide at all points. 

Where there is only one exit access leading to an exit or exit
discharge, the width of the exit and exit discharge must be at least
equal to the width of the exit access.

	1005.1 Minimum required egress width. 

The means of egress width shall not be less than required by this
section. The total width of means of egress in inches (mm) shall not be
less than the total occupant load served by the means of egress
multiplied by the factors in Table   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006T1005.1'%5d$xhitlist_md=target-id=0
-0-0-2995" \t "main"  1005.1  and not less than specified elsewhere in
this code. . . .

1017.2 Corridor width. 

The minimum corridor width shall be as determined in Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061005.1'%5d$xhitlist_md=target-id=0-
0-0-2993" \t "main"  1005.1  , but not less than 44 inches (1118 mm). 

Exceptions: 

1.     Twenty-four inches (610 mm)—For access to and utilization of
electrical, mechanical or plumbing systems or equipment. 

2.     Thirty-six inches (914 mm)—With a required occupant capacity
of less than 50. 

3.     Thirty-six inches (914 mm)—Within a dwelling unit. 

4.     Seventy-two inches (1829 mm)—In Group E with a corridor
having a required capacity of 100 or more. 

5.     Seventy-two inches (1829 mm)—In corridors serving surgical
Group I, health care centers for ambulatory patients receiving
outpatient medical care, which causes the patient to be not capable of
self-preservation. 

6.     Ninety-six inches (2438 mm)—In Group I-2 in areas where
required for bed movement. 

1003.6 Means of egress continuity. 

The path of egress travel along a means of egress shall not be
interrupted by any building element other than a means of egress
component as specified in this chapter. Obstructions shall not be placed
in the required width of a means of egress except projections permitted
by this chapter. The required capacity of a means of egress system shall
not be diminished along the path of egress travel. 

	IFC width is primarily driven by capacity.

IFC 1017.2 requires a minimum 44 inch corridor width with reduction to
36 inches where the occupant capacity is not more than 50 (exception 2).
 

Exception 1 is less stringent than E but applies in situations for
access to equipment by a few persons -  a situation not directly
addressed by E.

IFC is far more stringent in educational and health care occupancies.

IFC protection exceeds or is commensurate with Subpart E

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0036&src_anchor_name=1910.36(g)(2)" 
1910.36(g)(3)  

The width of an exit route must be sufficient to accommodate the maximum
permitted occupant load of each floor served by the exit route.	1004.4
Exiting from multiple levels. 

Where exits serve more than one floor, only the occupant load of each
floor considered individually shall be used in computing the required
capacity of the exits at that floor, provided that the exit capacity
shall not decrease in the direction of egress travel. 

1004.5 Egress convergence. 

Where means of egress from floors above and below converge at an
intermediate level, the capacity of the means of egress from the point
of convergence shall not be less than the sum of the two floors. 

	

IFC is more stringent in situations with convergence at intermediate
levels.

IFC protection exceeds with Subpart E

1910.36(g)(4) 

Objects that project into the exit route must not reduce the width of
the exit route to less than the minimum width requirements for exit
routes.

	1003.3.3 Horizontal projections. 

Structural elements, fixtures or furnishings shall not project
horizontally from either side more than 4 inches (102 mm) over any
walking surface between the heights of 27 inches (686 mm) and 80 inches
(2032 mm) above the walking surface. 

Exception: Handrails serving stairs and ramps are permitted to protrude
4.5 inches (114 mm) from the wall. 

1003.3.4 Clear width. 

Protruding objects shall not reduce the minimum clear width of
accessible routes as required in Section 1104 of the International
Building Code . 

1008.1.1.1 Projections into clear width. [doors]

There shall not be projections into the required clear width lower than
34 inches (864 mm) above the floor or ground. Projections into the clear
opening width between 34 inches (864 mm) and 80 inches (2032 mm) above
the floor or ground shall not exceed 4 inches (102 mm). 

	IFC contains allowances for knobs, handrails, door closers, etc., while
E is silent. However, the basic IFC corridor width requirements in
1017.2 are more stringent than E and would result in wider corridors
even with these allowances.

IFC protection is commensurate with Subpart E

1910.36(h) 

An outdoor exit route is permitted. Each outdoor exit route must meet
the minimum height and width requirements for indoor exit routes and
must also meet the following requirements:

	1014.5 Egress balconies. 

Balconies used for egress purposes shall conform to the same
requirements as corridors for width, headroom, dead ends and
projections. 

SECTION 1023 

EXTERIOR EXIT RAMPS AND STAIRWAYS 	Height & width of balconies is
covered by IFC the same as interior, plus section 1023 gives ramp and
stair details.

IFC protection exceeds Subpart E

1910.36(h)(1) 

The outdoor exit route must have guardrails to protect unenclosed sides
if a fall hazard exists.	1013.1 Where required. 

Guards shall be located along open-sided walking surfaces, mezzanines,
industrial equipment platforms, stairways, ramps and landings that are
located more than 30 inches (762 mm) above the floor or grade below. . .
.

	IFC requires guards for both indoor and outdoor exit routes.

IFC protection exceeds Subpart E

1910.36(h)(2) 

The outdoor exit route must be covered if snow or ice is likely to
accumulate along the route, unless the employer can demonstrate that any
snow or ice accumulation will be removed before it presents a slipping
hazard.

	1028.3 Obstructions. 

A means of egress shall be free from obstructions that would prevent its
use, including the accumulation of snow and ice. 

1009.5.2 Outdoor conditions. 

Outdoor stairways and outdoor approaches to stairways shall be designed
so that water will not accumulate on walking surfaces. 

	Both IFC end E take a performance oriented approach to snow & ice
protection. 

Additionally, the IFC goes on to regulate the design of stairs & their
approaches for water runoff.

IFC protection exceeds Subpart E

1910.36(h)(3) 

The outdoor exit route must be reasonably straight and have smooth,
solid, substantially level walkways.

	1003.4 Floor surface. Walking surfaces of the means of egress shall
have a slip-resistant surface and be securely attached.	IFC does not use
the vague, undefined, and hard to enforce terms “reasonably” and
“substantially”. E does not define these terms. 

IFC provision applies indoors & outdoors.

IFC protection exceeds Subpart E

1910.36(h)(4) 

The outdoor exit route must not have a dead-end that is longer than 20
feet (6.2 m).

	1017.3 Dead ends. 

Where more than one exit or exit access doorway is required, the exit
access shall be arranged such that there are no dead ends in corridors
more than 20 feet (6096 mm) in length. 

Exceptions: 

1.     In occupancies in Group I-3 of Occupancy Condition 2, 3 or 4
(see Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006202'%5d$xhitlist_md=target-id=0-0-0
-513" \t "main"  202  ), the dead end in a corridor shall not exceed 50
feet (15 240 mm). 

2.     In occupancies in Groups B and F where the building is
equipped throughout with an automatic sprinkler system in accordance
with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006903.3.1.1'%5d$xhitlist_md=target-id
=0-0-0-663" \t "main"  903.3.1.1  , the length of dead-end corridors
shall not exceed 50 feet (15 240 mm). 

3.     A dead-end corridor shall not be limited in length where the
length of the dead-end corridor is less than 2.5 times the least width
of the dead-end corridor. 

	IFC addresses both indoor and outdoor dead ends. 

Exceptions have compensatory features such as sprinkler protection,
staff procedures, and extra width.

IFC table 1027 contains the maximum allowed dead end lengths for each
occupancy type.

IFC protection exceeds or is commensurate with Subpart E

1910.37(a) 

The danger to employees must be minimized.

Title only – requirements follow

1910.37(a)(1) 

Exit routes must be kept free of explosive or highly flammable
furnishings or other decorations.

	801.1 Scope. 

The provisions of this chapter shall govern interior finish, interior
trim, furniture, furnishings, decorative materials and decorative
vegetation in buildings. . . .

	IFC covers much more than furnishings – most notably interior finish.

IFC protection exceeds Subpart E

1910.37(a)(2) 

Exit routes must be arranged so that employees will not have to travel
toward a high hazard area, unless the path of travel is effectively
shielded from the high hazard area by suitable partitions or other
physical barriers.

	1014.2 Egress through intervening spaces. 

Egress through intervening spaces shall comply with this section. 

1.     Egress from a room or space shall not pass through adjoining
or intervening rooms or areas, except where such adjoining rooms or
areas are accessory to the area served, are not a high-hazard occupancy
and provide a discernible path of egress travel to an exit. 

Exception: Means of egress are not prohibited through adjoining or
intervening rooms or spaces in a Group H, S or F occupancy when the
adjoining or intervening rooms or spaces are the same or a lesser hazard
occupancy group. 

	IFC does not use the vague and hard to enforce terms ‘effectively”
or “suitable”. E does not define these terms.

Item 2 under IFC 1014.2 corresponds to 1910.37(a)(3) – see below.

IFC protection is commensurate with Subpart E

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0037&src_anchor_name=1910.37(a)(3)" 
1910.37(a)(3)  

Exit routes must be free and unobstructed. No materials or equipment may
be placed, either permanently or temporarily, within the exit route. 

The exit access must not go through a room that can be locked, such as a
bathroom, to reach an exit or exit discharge, nor may it lead into a
dead-end corridor. 

Stairs or a ramp must be provided where the exit route is not
substantially level.

	1028.1 General. 

The means of egress for buildings or portions thereof shall be
maintained in accordance with this section. 

1028.2 Reliability. 

Required exit accesses, exits or exit discharges shall be continuously
maintained free from obstructions or impediments to full instant use in
the case of fire or other emergency when the areas served by such exits
are occupied. Security devices affecting means of egress shall be
subject to approval of the fire code official. 

315.2.2 Means of egress. 

Combustible materials shall not be stored in exits or exit enclosures. 

1014.2 Egress through intervening spaces.

2.     Egress shall not pass through kitchens, storage rooms, closets
or spaces used for similar purposes. 

Exceptions: 

1.     Means of egress are not prohibited through a kitchen area
serving adjoining rooms constituting part of the same dwelling unit or
sleeping unit. 

2.     Means of egress are not prohibited through stockrooms in Group
M occupancies when all of the following are met: 

2.1.     The stock is of the same hazard classification as that found
in the main retail area; 

2.2.     Not more than 50 percent of the exit access is through the
stockroom; 

2.3.     The stockroom is not subject to locking from the egress
side; and 

2.4.     There is a demarcated, minimum 44-inch-wide (1118 mm) aisle
defined by full or partial height fixed walls or similar construction
that will maintain the required width and lead directly from the retail
area to the exit without obstructions. 

3.     An exit access shall not pass through a room that can be
locked to prevent egress. 

4.     Means of egress from dwelling units or sleeping areas shall
not lead through other sleeping areas, toilet rooms or bathrooms. 

1003.5 Elevation change. 

Where changes in elevation of less than 12 inches (305 mm) exist in the
means of egress, sloped surfaces shall be used. Where the slope is
greater than one unit vertical in 20 units horizontal (5-percent slope),
ramps complying with Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061010'%5d$xhitlist_md=target-id=0-0-
0-1921" \t "main"  1010  shall be used. Where the difference in
elevation is 6 inches (152 mm) or less, the ramp shall be equipped with
either handrails or floor finish materials that contrast with adjacent
floor finish materials. 	

Item 1 under IFC 1014.2 corresponds to 1910.37(a)(2) – see above.

Exception 1 for residential.

Exception 2 allows for egress through mercantile storage rooms, with
compensatory features.

Exception 3 addresses locking.

Exception 4 is for residential.

IFC does not allow single or double step stairs in most cases, which is
more protective.

IFC protection is commensurate with or exceeds Subpart E

1910.37(a)(4) 

Safeguards designed to protect employees during an emergency (e.g.,
sprinkler systems, alarm systems, fire doors, exit lighting) must be in
proper working order at all times.

	107.1 Maintenance of safeguards. 

Whenever or wherever any device, equipment, system, condition,
arrangement, level of protection, or any other feature is required for
compliance with the provisions of this code, or otherwise installed,
such device, equipment, system, condition, arrangement, level of
protection, or other feature shall thereafter be continuously maintained
in accordance with this code and applicable referenced standards. 

107.4 Rendering equipment inoperable. 

Portable or fixed fire-extinguishing systems or devices and fire-warning
systems shall not be rendered inoperative or inaccessible except as
necessary during emergencies, maintenance, repairs, alterations, drills
or prescribed testing.

	

Additionally, IFC goes on to address system testing.

IFC allows for necessary outages. Literal application of E precludes
this.

IFC protection is equivalent to Subpart E



  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0037&src_anchor_name=1910.37(b)"  1910.37(b)  

Lighting and marking must be adequate and appropriate.



Title only – requirements follow

1910.37(b)(1) 

Each exit route must be adequately lighted so that an employee with
normal vision can see along the exit route.

	1006.1 Illumination required. 

The means of egress, including the exit discharge, shall be illuminated
at all times the building space served by the means of egress is
occupied. 

Exceptions: 

1.     Occupancies in Group U. 

2.     Aisle accessways in Group A. 

3.     Dwelling units and sleeping units in Groups R-1, R-2 and R-3. 

4.     Sleeping units of Group I occupancies. 

1006.2 Illumination level. 

The means of egress illumination level shall not be less than 1
foot-candle (11 lux) at the walking surface level. 

Exception: For auditoriums, theaters, concert or opera halls and similar
assembly occupancies, the illumination at the walking surface level is
permitted to be reduced during performances to not less than 0.2
foot-candle (2.15 lux), provided that the required illumination is
automatically restored upon activation of a premises’ fire alarm
system where such system is provided. 

	IFC does not use the vague and hard to enforce term “adequately”,
which is not defined by E.

IFC specifies the minimum illumination levels, rather than the
performance language in E.

Additionally, IFC goes on to address emergency lighting (1006.3) in
addition to ordinary illumination.

IFC protection exceeds Subpart E



1910.37(b)(2) 

Each exit must be clearly visible and marked by a sign reading "Exit."

	1011.1 Where required. 

Exits and exit access doors shall be marked by an approved exit sign
readily visible from any direction of egress travel. Access to exits
shall be marked by readily visible exit signs in cases where the exit or
the path of egress travel is not immediately visible to the occupants.
Exit sign placement shall be such that no point in a corridor is more
than 100 feet (30 480 mm) or the listed viewing distance for the sign,
whichever is less, from the nearest visible exit sign. 

Exceptions: 

1.     Exit signs are not required in rooms or areas that require
only one exit or exit access. 

2.     Main exterior exit doors or gates that are obviously and
clearly identifiable as exits need not have exit signs where approved by
the fire code official. 

3.     Exit signs are not required in occupancies in Group U and
individual sleeping units or dwelling units in Group R-1, R-2 or R-3. 

4.     Exit signs are not required in sleeping areas in occupancies
in Group I-3. 

5.     In occupancies in Groups A-4 and A-5, exit signs are not
required on the seating side of vomitories or openings into seating
areas where exit signs are provided in the concourse that are readily
apparent from the vomitories. Egress lighting is provided to identify
each vomitory or opening within the seating area in an emergency. 

	

See discussion of graphics under 1910.37 (b)(7).

The IFC exceptions specify thresholds below which exit marking would not
effect life safety, rather than the performance language in E.

IFC protection exceeds or is commensurate with Subpart E



1910.37(b)(3) 

Each exit route door must be free of decorations or signs that obscure
the visibility of the exit route door.

	1028.4 Exit signs. 

Exit signs shall be installed and maintained in accordance with Section 
 HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC20061011'%5d$xhitlist_md=target-id=0-0-
0-3215" \t "main"  1011  . Decorations, furnishings, equipment or
adjacent signage that impairs the visibility of exit signs, creates
confusion or prevents identification of the exit shall not be allowed. 

1028.5 Furnishings and decorations. 

Furnishings, decorations or other objects shall not be placed so as to
obstruct exits, access thereto, egress therefrom, or visibility thereof.
Hangings and draperies shall not be placed over exit doors or otherwise
be located to conceal or obstruct an exit. Mirrors shall not be placed
on exit doors. Mirrors shall not be placed in or adjacent to any exit in
such a manner as to confuse the direction of exit. 	IFC provisions apply
to egress components other than doors, and also require exit signs to
remain unobstructed.

IFC protection exceeds Subpart E

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0037&src_anchor_name=1910.37(b)(4)" 
1910.37(b)(4)  

If the direction of travel to the exit or exit discharge is not
immediately apparent, signs must be posted along the exit access
indicating the direction of travel to the nearest exit and exit
discharge. Additionally, the line-of-sight to an exit sign must clearly
be visible at all times.

	1011.1 Where required. 

 Access to exits shall be marked by readily visible exit signs in cases
where the exit or the path of egress travel is not immediately visible
to the occupants. 

 	

IFC protection is equivalent to Subpart E



1910.37(b)(5) 

Each doorway or passage along an exit access that could be mistaken for
an exit must be marked "Not an Exit" or similar designation, or be
identified by a sign indicating its actual use (e.g., closet).

	

SECTION 1011 - EXIT SIGNS 

1011.1 Where required. 

Exits and exit access doors shall be marked by an approved exit sign
readily visible from any direction of egress travel. Access to exits
shall be marked by readily visible exit signs in cases where the exit or
the path of egress travel is not immediately visible to the occupants.
Exit sign placement shall be such that no point in a corridor is more
than 100 feet (30 480 mm) or the listed viewing distance for the sign,
whichever is less, from the nearest visible exit sign. 

1011.5.3 Power source. 

Exit signs shall be illuminated at all times. To ensure continued
illumination for a duration of not less than 90 minutes in case of
primary power loss, the sign illumination means shall be connected to an
emergency power system provided from storage batteries, unit equipment
or an on-site generator. The installation of the emergency power system
shall be in accordance with Section 2702 of the International Building
Code . 

Exception: Approved exit sign illumination means that provide continuous
illumination independent of external power sources for a duration of not
less than 90 minutes, in case of primary power loss, are not required to
be connected to an emergency electrical system. 

1008.1 Doors.  

Means of egress doors shall be readily distinguishable from the adjacent
construction and finishes such that the doors are easily recognizable as
doors. Mirrors or similar reflecting materials shall not be used on
means of egress doors. Means of egress doors shall not be concealed by
curtains, drapes, decorations or similar materials. 

SECTION 404 - FIRE SAFETY AND EVACUATION PLANS

SECTION 405 - EMERGENCY EVACUATION DRILLS

SECTION 406 -  EMPLOYEE TRAINING AND RESPONSE PROCEDURES

	The IFC has detailed requirements & prohibitions to help identify and
distinguish means of egress doors. Many of these exceed E requirements
and include:

Max. 100’ between exit signs in 1011.1.

90 minutes of emergency power in 1011.5.3.

Distinguishable doors in 1008.1

Prohibition against mirror, curtains, decorations, etc. on doors in
1008.1

Evacuation plans for many occupancies in 404.

Drills for many occupancies to familiarize employees with exits in 405.

Employee evacuation training for many occupancies in 406.

The E requirements for Emergency Action Plans are only invoked in
limited occupancies when referenced by another standard. 

The additional IFC requirements address the hazard of mistaking exits
without the extra signage required by E. Both methods achieve the same
level of safety.

IFC protection is commensurate with Subpart E



  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0037&src_anchor_name=1910.37(b)(6)" 
1910.37(b)(6)  

Each exit sign must be illuminated to a surface value of at least five
foot-candles (54 lux) by a reliable light source and be distinctive in
color. 

Self-luminous or electroluminescent signs that have a minimum luminance
surface value of at least .06 footlamberts (0.21 cd/m2) are permitted.

	1011.4 Internally illuminated exit signs. 

Internally illuminated exit signs shall be listed and labeled and shall
be installed in accordance with the manufacturer’s instructions and
Section 2702 of the International Building Code . Exit signs shall be
illuminated at all times. 

1011.5 Externally illuminated exit signs.

1011.5.2 Exit sign illumination. 

The face of an exit sign illuminated from an external source shall have
an intensity of not less than 5 foot-candles (54 lux). 

1027.3 Exit sign illumination. 

Exception: Approved self-luminous signs that provide evenly illuminated
letters shall have a minimum luminance of 0.06 foot-lamberts (0.21 cd/m
2 ). 

	Light level of internally illuminated signs is addressed by IFC through
their listing.

E allows self-luminous devices as an option.

IFC allows self-luminous signs in existing buildings.

IFC protection is equivalent to Subpart E



  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0037&src_anchor_name=1910.37(b)(7)" 
1910.37(b)(7)  

Each exit sign must have the word "Exit" in plainly legible letters not
less than six inches (15.2 cm) high, with the principal strokes of the
letters in the word "Exit" not less than three-fourths of an inch (1.9
cm) wide.	1011.5 Externally illuminated exit signs.

1011.5.1 Graphics. 

Every exit sign and directional exit sign shall have plainly legible
letters not less than 6 inches (152 mm) high with the principal strokes
of the letters not less than 0.75 inch (19.1 mm) wide. The word
“EXIT” shall have letters having a width not less than 2 inches (51
mm) wide, except the letter “I,” and the minimum spacing between
letters shall not be less than 0.375 inch (9.5 mm). Signs larger than
the minimum established in this section shall have letter widths,
strokes and spacing in proportion to their height. . . .

	Graphics of internally illuminated signs are addressed by IFC through
their listing (see 1011.4 above).

IFC protection is commensurate with Subpart E



1910.37(c) 

The fire retardant properties of paints or solutions must be maintained.
Fire retardant paints or solutions must be renewed as often as necessary
to maintain their fire retardant properties.

	803.4 Fire-retardant coatings. 

The required flame spread or smoke-developed index of surfaces in
existing buildings shall be allowed to be achieved by application of
approved fire-retardant coatings, paints or solutions to surfaces having
a flame spread index exceeding that allowed. Such applications shall
comply with NFPA 703 and the required fire-retardant properties shall be
maintained or renewed in accordance with the manufacturer’s
instructions. 

	

E does not require FR paint (or otherwise regulate interior finish), yet
requires the FR paint properties to be maintained.

IFC protection exceeds Subpart E

1910.37(d) 

Exit routes must be maintained during construction, repairs, or
alterations.



Title only – requirements follow

1910.37(d)(1) 

During new construction, employees must not occupy a workplace until the
exit routes required by this subpart are completed and ready for
employee use for the portion of the workplace they occupy.

	1411.1 Stairways required. 

Where a building has been constructed to a height greater than 50 feet
(15 240 mm) or four stories, or where an existing building exceeding 50
feet (15 240 mm) in height is altered, at least one temporary lighted
stairway shall be provided unless one or more of the permanent stairways
are erected as the construction progresses. 

1411.2 Maintenance. 

Required means of egress shall be maintained during construction and
demolition, remodeling or alterations and additions to any building. 

Exception: Approved temporary means of egress systems and facilities. 

	IFC establishes a threshold for stairs, while E uses performance
language.

IFC protection is equivalent to Subpart E



1910.37(d)(2) 

During repairs or alterations, employees must not occupy a workplace
unless the exit routes required by this subpart are available and
existing fire protections are maintained, or until alternate fire
protection is furnished that provides an equivalent level of safety.

	1411.2 Maintenance. 

Required means of egress shall be maintained during construction and
demolition, remodeling or alterations and additions to any building. 

Exception: Approved temporary means of egress systems and facilities. 

	IFC extends further than E to cover demolition, remodeling, and
additions.

IFC protection exceeds Subpart E



1910.37(d)(3) 

Employees must not be exposed to hazards of flammable or explosive
substances or equipment used during construction, repairs, or
alterations, that are beyond the normal permissible conditions in the
workplace, or that would impede exiting the workplace.	1403 TEMPORARY
HEATING EQUIPMENT

1404 PRECAUTIONS AGAINST FIRE

1405 FLAMMABLE AND COMBUSTIBLE LIQUIDS.

1406 FLAMMABLE GASES

1407 EXPLOSIVE MATERIALS	These IFC sections go into much more detail
than the performance language in E.

IFC protection is equivalent to Subpart E



  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDA
RDS&src_unique_file=1910_0037&src_anchor_name=1910.37(e)"  1910.37(e)  

An employee alarm system must be operable. Employers must install and
maintain an operable employee alarm system that has a distinctive signal
to warn employees of fire or other emergencies, unless employees can
promptly see or smell a fire or other hazard in time to provide adequate
warning to them. The employee alarm system must comply with § 1910.165.
901.1 Scope. 

The provisions of this chapter shall specify where fire protection
systems are required and shall apply to the design, installation,
inspection, operation, testing and maintenance of all fire protection
systems. 

907.1 General. 

This section covers the application, installation, performance and
maintenance of fire alarm systems and their components in new and
existing buildings and structures. The requirements of Section  
HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.2'%5d$xhitlist_md=target-id=0-0
-0-1571" \t "main"  907.2  are applicable to new buildings and
structures. The requirements of Section   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.3'%5d$xhitlist_md=target-id=0-0
-0-2361" \t "main"  907.3  are applicable to existing buildings and
structures. 

907.2 Where required—new buildings and structures. 

An approved manual, automatic or manual and automatic fire alarm system
installed in accordance with the provisions of this code and NFPA 72
shall be provided in new buildings and structures in accordance with
Sections   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.2.1'%5d$xhitlist_md=target-id=0
-0-0-2367" \t "main"  907.2.1  through   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.2.23'%5d$xhitlist_md=target-id=
0-0-0-2369" \t "main"  907.2.23   . . .

907.3 Where required—retroactive in existing buildings and structures.


An approved manual, automatic or manual and automatic fire alarm system
shall be installed in existing buildings and structures in accordance
with Sections   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.3.1'%5d$xhitlist_md=target-id=0
-0-0-2491" \t "main"  907.3.1  through   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.3.1.8'%5d$xhitlist_md=target-id
=0-0-0-2493" \t "main"  907.3.1.8  . . . . 

	

Subsections   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.2.1'%5d$xhitlist_md=target-id=0
-0-0-2367" \t "main"  907.2.1  through   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.2.23'%5d$xhitlist_md=target-id=
0-0-0-2369" \t "main"  907.2.23  indicate which new occupancies require
alarm systems (based on size, number of stories, or occupant load),
rather than the performance language in E.

Subsections   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.3.1'%5d$xhitlist_md=target-id=0
-0-0-2491" \t "main"  907.3.1  through   HYPERLINK
"http://ecodes.iccsafe.org/icce/gateway.dll?f=xhitlist$xhitlist_x=Advanc
ed$xhitlist_vpc=first$xhitlist_xsl=querylink.xsl$xhitlist_sel=title;path
;content-type;home-title$xhitlist_d=ICodes2006(IFC2006)$xhitlist_q=%5bfi
eld%20folio-destination-name:'IFC2006907.3.1.8'%5d$xhitlist_md=target-id
=0-0-0-2493" \t "main"  907.3.1.8  indicate which existing occupancies
require alarm systems (based on size, number of stories, or occupant
load), rather than the performance language in E.

IFC protection is commensurate with Subpart E





NOTE: This comparison and its conclusions apply only to the unamended
IFC. It is recognized that some local or State jurisdictions throughout
the country have adopted The IFC with amendments. OSHA is unable to
evaluate all the possible amendment scenarios. Amended codes may still
provide equal or greater employee protection, however this must be
established on a case by case basis. 

 PAGE   

 PAGE   28 

