Access to Roof

In a 24 story R-2 (apartment) building in California, permitted under the 2001 CBC, we have a landscaped roof terrace that can hold an occupancy load of 190 persons.  It is furnished for parties with barbecues, chairs and tables.  We have three elevators and two fully compliant exit stairways up to this roof, one stair is accessed directly from the terrace, the other stair is accessed through a glass door into a small corridor that connects to the elevator lobby and the exit stair.  Residents can access the roof terrace through the glass door which is equipped with a power door opener, activated from both sides of the door, for the handicapped.  The doors to the corridor and both stairs open in the direction of egress travel (from the terrace to the stairway) and are equipped with panic exit devices.  The Owners wanted to control access to this roof amenity so they installed a card reader at the inside of the glass door with an electric strike that is automatically retracted when the fire alarm is activated.  The Fire Department will not grant a Final Occupancy Permit because they say the glass door must be unlocked for any emergency, not just a fire, quoting Section 1008.1.9 from the 2013 CBC which says that "egress doors shall be readily openable from the egress side without the use of a key or special knowledge or effort."  The comparable section of the correct 2001 CBC [1003.3.1.8] says "exit doors shall be openable from the inside without the use of a key or any special knowledge or effort."  We do not think the inspector is even aware of the unfortunate language in the 2001 code that could be construed to support his point of view, but citing the current code he seems to be fixated on the need to keep this door unlocked so occupants of the building can seek refuge on the roof if they ever want to.  He seems to regard the door as a "dual egress" function, although he has not said as much. The owner is willing to install an override switch at the door that retracts the strike whenever the switch is activated, with an alarm sounding at the security desk downstairs.  The fire inspector is not confident that this will be acceptable to the Building Department so he is asking us to prepare new drawings to be submitted to the city for permit, showing this configuration of locks, card readers, fire alarm override and manual override with alarm.  If they accept this, he says he will allow it.   Our position as the architects is that the door is code compliant now, even with a card reader.  The CBC does not appear to require that the door to the roof be unlocked nor does it forbid the door from being locked.  It only requires that it be openable in the direction of egress travel, which in this case is from outside to inside.  Is there anything in the code that I can use to convince the inspector that this is the case and we can leave the door as it is with a card reader on it, controlling access to the roof, without adding the manual override and especially not going back in for a permit revision? 

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Patrick and Laura, Thank you for your responses.  Yes, we feel the building is currently compliant, even with the card reader access the owner has added to the roof access door. This roof terrace is served by two normal exit stairways and three elevators.  It does not adjoin any other occupied spaces, so it does not constitute an area of refuge or assistive rescue.  The handicapped are instructed to go via an accessible route (through this door in the egress direction) to the elevator lobby for assistance in a fire event.  The door is still openable using the panic device from the outside going into the lobby.  The building is nearly a year after substantial completion and the owner is trying to obtain the Final Certificate of Occupancy but the Fire Dept. inspector won't grant it until the lock is removed from the door or an override button is installed along with the card reader, on the non-egress side.  He wants us to submit revised drawings to the building department showing this hardware addition to validate his decision.  The owner is asking us to help him avoid having to submit new plans for a permit revision.  The inspector says the new 2013 code requires that roofs be accessible to all occupants in an emergency, citing new concerns about terrorists chasing people around inside the building and says the code does not want them trapped at the top of the staircase.  He says they should be able to get out on the roof where the terrorist is unlikely to follow them.  He feels this overrides the 2001 CBC rules because they did not consider escape from terrorists to be a major concern.  We cannot find the 2013 section he is talking about and he will not give us a section number other than 1008.1.9 that requires doors to operate without hindrance "in the direction of egress travel."  Section 1008.1.9.8 applies to doors that need to be locked against entry but unlocked in the egress direction when necessary.  This door is always unlocked in the egress direction.  "Entry" in this case is entrance to an outside assembly space.  We are just searching for something that might convince us that OUR reasoning is wrong; what have we missed that this inspector is trying to enforce?  I think your responses assure us that that is not the case.  I know we cannot convince the inspector that he is in error.  Thank you again for your help. 

I do not have the 2001 CBC, but make sure the exterior roof is not an  area for assistive rescue (current CBC  1007.7).  If so,  the interior access to the roof would be considered an exit.  If it is not an area for assistive rescue, I would ask the building inspector for the code section that would not allow the glass door to be opened from the interior with a card reader.  Current CBC 1008.1.9.8 seems to allow it when specific criteria is followed.

You simply reply that the building is currently compliant. It is the responsibility of party seeking change, to have any changes approved by the
regulating authority. From your response You are aware of this, but just need a little assurance.
Best,
Patrick
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