Egress Doors vs Exit Doors from Ground Floor Suites

Date of Publication:  January 20, 2025 [2025.01.V-01.C]

Subject:  Egress Doors vs Exit Doors from Ground Floor Suites

2012 and 2024 Ontario Building Code Reference(s):

Article 3.3.1.5. of Div. B.

Article 3.4.2.1. of Div. B.

Incoming Request: 

A proposal has been received for a 4 storey, Part 3 sprinklered building with residential suites on the upper levels and commercial Group D suites on the ground floor, with doors directly to the exterior at grade. Some ground floor suites are small (<150m2), with only one door discharging directly to the exterior of the building at grade, which serves as both the entrance and exit. 

The question is: Are 2 exit doors required as per 3.4.2.1., regardless of the size of the suite, because the permission to allow only one exit from a floor area by sentence 3.4.2.1.(2) only applies to buildings of 2 storeys or less. 

Executive Summary:

In the scenario above, one exit door directly to grade is sufficient for suites meeting the occupant load, area and travel distance requirements of Article 3.3.1.5.

Discussion & Considerations:

Exit is defined as:

...that part of a means of egress, including doorways, that leads from the floor area it serves to a separate building, an open public thoroughfare or an exterior open space protected from fire exposure from the building and having access to an open public thoroughfare.

Floor area is defined as:

...the space on any storey of a building between exterior walls and required firewalls, including the space occupied by interior walls and partitions, but not including exits, vertical service spaces and their enclosing assemblies.

The requirements of Article 3.4.2.1. apply to floor areas, not individual suites or rooms. As noted above, floor area generally means the entire space on a storey and does not consider partitions or demising walls. Since the floor area on the ground level contains multiple suites with no access between them, each one will necessarily have at least one exterior door, thereby 

satisfying the basic requirement for the floor level to be served by more than one exit. 

However, egress requirements of Article 3.3.1.5. also need to be considered for the individual suites and any proposed rooms. Clause 3.3.1.5.(1)(d) permits a room or suite in a sprinklered building to have one egress door where the occupant load is not more than 60, the travel distance is not more than 25m and the area of the suite is not more than listed in Table 3.3.1.5.B. This would be the governing condition to permit one egress door, which, due to building configuration is also an exit door. It should be kept in mind that the use of any rooms or suite (i.e. a hazardous room) and the actual interior layout of rooms and partitions affecting travel distance may change the applicability of Clause 3.3.1.5.(1)(d). 

Risk/Benefit Analysis:

Some have argued that each suite should be considered as a separate floor area, and would therefore be subject to the minimum requirement of 2 exits as per Article 3.4.2.1. To explore this, consider hypothetically adding a public corridor in front of the suite doors, (with an exit door at each end). The floor area would then be served by two exits, and the suite doors would be considered egress doors. The suites would then be subject to the same occupant load, travel distance and area limits as the actual scenario described above.

Final Recommendation:

In the scenario above, exit doors from suites directly at grade are subject to the egress door requirements of 3.3.1.5., regardless of building height, and since suites that meet the occupant load, travel distance and area limitations are permitted to have one egress door, one exit door is sufficient. 

Recommendation to Ministry of Municipal Affairs and Housing:

None at this time. 

Referenced Documents:

2012 Ontario Building Code:

2024 Ontario Building Code:

Disclaimer:

This guidance document is intended to assist building officials by gathering relevant information to interpret the OBC Act and the prescriptive requirements of the Ontario Building Code, and is intended to be a best practice aid for building officials.

The views expressed within this guidance document should not be considered as the official interpretation of legislated requirements based on the Ontario Building Code, as the final responsibility for interpretation rests with the local Authority Having Jurisdiction. 

The views of this advisory committee should not be construed as legal advice.