Analysis Of The Proposed Standarts (Appendix A) - Summary Of The Major Substantive Changes Proposed For The Scoping And Technical Requirements Page 14
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63since the model fire and life safety codes, which are adopted by all the States, contain
equivalent requirements with respect to the number of accessible means of egress.
The 1991 Standards require areas of rescue assistance or horizontal exits in facilities with
levels above or below the level of exit discharge level. Areas of rescue assistance are
spaces that have direct access to an exit, stair, or enclosure where individuals who are
unable to use stairs can go to call for assistance and wait for evacuation. The proposed
standards will now incorporate the requirements established by the IBC. The IBC
requires an evacuation elevator designed with standby power and other safety features
that can be used for emergency evacuation of individuals with disabilities in facilities
with four or more stories above or below the exit discharge level, and allows exit
stairways and evacuation elevators to be used as an accessible means of egress in
conjunction with areas of refuge or horizontal exits. The proposed change is expected to
have minimal impact since the model fire and life safety codes, adopted by most States,
already contain parallel requirements with respect to evacuation elevators.
The 1991 Standards exempt facilities equipped with a supervised automatic sprinkler
system from providing areas of rescue assistance, and also exempt alterations to existing
facilities from providing an accessible means of egress. The IBC exempts buildings
equipped with a supervised automatic sprinkler system from certain technical
requirements for areas of refuge, and also exempts alterations to existing facilities from
providing an accessible means of egress.
The proposed standards will require signs that provide direction to or information about
functional spaces to meet certain technical requirements. The proposed standard at
section 216.4 addresses exit signs. This section requires exit signs at doors to be raised
with Braille characters, and also requires directional exit signs and signs at areas of
refuge to have appropriate visual characteristics. This section is consistent with the
requirements of the IBC. Signs used for means of egress are covered by this scoping
requirement. The proposed requirements specifically identify signs used for means of
egress and require the signs to meet certain technical requirements.
Standby Power for Platform Lifts. The proposed regulations at section 207.2 will require
standby power to be provided for platform lifts that are permitted to serve as part of an
accessible means of egress by the IBC. The IBC permits platform lifts to serve as part of
an accessible means of egress in a limited number of places where platform lifts are
allowed in new construction. The 1991 Standards and the proposed regulations similarly
limit the places where platform lifts are allowed in new construction. ADAAG 4.1.3 (5)
Exception 4 (a) through (d); sections 206.7.1 through 206.7.10 of the proposed
regulations.
Commenters urged the Department to reconsider provisions that would require standby
power to be provided for platform lifts. Concerns were raised that ensuring standby
power is too burdensome. The Department views this issue as a fundamental life safety
issue. Lift users face the prospect of being trapped on the lift in the event of a power
failure if stand-by power is not provided. The lack of stand-by power could be life-
14
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