From the Chief’s Corner: Inside the Stairway, Allowed or Not...

Posted on June 17, 2020

AHJs and integrators often ask me what seems like a really simple question: “Can I put antennas, or even the backbone cable, within a rated exit stairway?” To answer that question let’s start with the word “intent.” “Intent” is a noun that comes from the verb "intend." It means to have something in mind as a plan or purpose. So, what is the plan or purpose of an in-building emergency responder communications enhancement system (ERCES)? Quite simply: It is to provide communications capabilities for the first responders.

Within IBC Section 1023.5, Exception #4 and #5 specifically spell out that penetrations into the interior exit stairway for two-way communications systems and electrical raceways for fire department communications systems are permitted.

The events of 9-11 at the World Trade Center have certainly guided many changes within the fire service. Most important to many of us are the requirements related to in-building communications. To help illustrate the purpose of the ERCES, I reflect on the morning of September 11, 2001. One name that comes to my mind is that of Battalion Chief Orio Palmer. Palmer led the team of firefighters that reached the 78th floor of the South Tower – the floor where the planes had struck the building on that fateful morning. Chief Palmer, who perished inside the South Tower, was one of the most knowledgeable people in the department about radio communication in high-rise fires, and he authored training materials on how to use repeaters to boost radio reception during emergencies. 

The book, 102 Minutes – The Untold Story of the Fight to Survive Inside the Twin Towers states: “The repeater, which had previously worked so well, did not seem to be working properly. Palmer went outside to a Battalion car and turned on a portable repeater. It did not seem to work either”. The chiefs concluded they would have to muddle through the best they could. It has been documented that, while making their way to the 78th floor, Palmer and his team encountered numerous communications failures as did many other firefighters as they transcended the many stairways inside the buildings.

As you can see from the events of 9-11 and many others, the stairway is a critical area for emergency responders operating within a building. Hence the reason the IFC and NFPA codes/standards require 99% coverage within them for the ERCES. I often hear AHJs say: “An interior exit stairway shall not be used for any purpose other than as a means of egress.” And yes, the International Building Code (IBC) Section 1023.1 does state that. But as the conservative talk radio pioneer Paul Harvey would often say: “and now the Rest of the Story.”

It’s important to also take a look at IBC Section 1023.5 Penetrations. It reads as follows;

Penetration into or through interior exit stairways and ramps are prohibited except for the following:

1. Equipment and ductwork necessary for independent ventilation or pressurization.
2. Fire protection systems
3. Security systems.
4. Two-way communications systems.
5. Electrical raceway for fire department communications systems.
6. Electrical raceway serving the interior exit stairway and ramp and terminating at a steel box not exceeding 16 square inches.

Such penetrations shall be protected in accordance with Section 714. There shall not be penetrations or communications openings, whether protected or not, between adjacent interior exit stairways and ramps.

So, let’s unpack Section 1023.5 from a common-sense standpoint. Emergency responders utilize the interior exit stairways to perform many of their emergency operations that are critical to saving lives and property. Without communications capabilities in these stairways, the safety of our emergency responders who are there to serve the public, are most certainly at risk. In addition to their safety, the lack of communications impacts operational effectiveness and efficiency. 

Within Section 1023.5, Exception #4 and #5 specifically spell out that penetrations into the interior exit stairway for two-way communications systems and electrical raceways for fire department communications systems are permitted. Therefore, if one of these exceptions can penetrate the space it would make sense that the purpose is to serve the space, i.e., communications coverage in the stairway.  

When you think about the intent of the code section on interior exit stairways, it is to provide a safe harbor and means of egress for both the public and the public safety responders. One must ask: “Would placing service antennas (smaller than an exit sign) or allowing a cable within a metallic raceway into the exit stairway interfere with the intent of the exit stairway or help with the overall intent of an interior exit stairway?”  I believe Chief Palmer, who had a keen interest in in-building communications and the many others that responded and lost their lives in the Twin Towers, would say that the latter is the better view. 

What do the requirements really need to be? How do we make sure that the requirements are what they need to be, no more – no less? These questions are best answered when all stakeholders as it relates to the installation of an ERCES have dialogue. These discussions are currently taking place in both the International Code Council and National Fire Protection Associations codes and standards development processes. Getting involved in the Safer Buildings Coalitions workgroups is a pathway to the table on these discussions.