Issue DS 2018-016. The petitioner Angela Petrakis of Diversified Window Solutions is seeking a declaratory statement on whether Hazardous location apply to Exterior Doors only adjacent to Exterior windows or does this condition apply to Interior Doors as well adjacent to Exterior Windows?
Background:
Diversified Windows, supplies and installs windows throughout the State of
Florida, we hold a contractors license as well our glass & glazing license with the state. They have been in business since 2001, working on Apartments, Condos, and Assisted Living Facilities for numerous Contractors. They successfully complete 15-20 multifamily projects a year, and are very hands on with numerous architects and contractors at the beginning stages of these multifamily projects. They strive to understand the latest codes pertaining to their products and are one of the largest turnkey suppliers/installers in the state. The owners review every bid, submittal and are present in the field on these jobs.
Specifically, the code we are requesting clarification on has not appeared to change through many building codes. We are working closely with Richard Jones Architecture, 10 SE 1st Ave, Delray Beach, FL 3344 on the designs of this building type. Our interpretation of the code would exclude any Interior Doors adjacent to the windows, excluding those windows to be in a hazardous location.
Situation:
Please see unit plans attached for an apartment project that is not under permit or jurisdiction in Orlando. FL. Project does consist of interior doors adjacent to exterior windows and for example, only an exterior door at an uncovered balcony adjacent to exterior windows. The projects typically consist of 3-4 stories high-buildings ranging from 15-20 units per Bldg.
See attached.
2017 Florida Building
Code 6th Edition
2406.4.2 Glazing adjacent to doors.
Glazing in an
individual fixed or operable panel adjacent to a door where the nearest edge
vertical edge of the glazing is within a 24-inch (610 arc) ARC of either
vertical edge of door in a closed position and where the bottom exposed edge of
the glazing is less than 60 inches above the walking surface shall be considered
a hazardous location.
Exceptions:
1.Decorative
glazing.
2.Where there is an
intervening wall or other permanent barrier between the door and glazing.
3.Where access
through the door is to a closet or storage area 3 feet (914 mm) or less in
depth. Glazing in this application shall comply with Section 2406.4.3.
4.Glazing
in walls on the latch side of and perpendicular to the plane of the door in a
closed position in one- and two-family dwellings or within dwelling units in
Group R-2.
310.4 Residential Group R-2.
Residential Group
R-2 occupancies containing sleeping units or more than two dwelling units where
the occupants are primarily permanent in nature, including:
Apartment houses
Boarding houses
(nontransient) with more than 16 occupants
Congregate living
facilities (nontransient) with more than 16 occupants
Convents
Dormitories
Fraternities and
sororities
Hotels
(nontransient)
Live/work units
Monasteries
Motels
(nontransient)
Vacation timeshare
properties
Staff Analysis:
Question:
Does this Hazardous
location apply to Exterior Doors only adjacent to Exterior Windows or Does this
Condition apply to Interior Doors as well adjacent to Exterior Windows?
Answer:
For the project in question and as per Section 2406.4.2,
Exception 4, of the 6th Edition (2017) Florida Building Code,
Building, the hazardous location requirements of Section 2406.4.2 is only
applicable to windows adjacent to exterior doors.
TAC
Action – March 28, 2018
Question
1: Does this Hazardous location
apply to Exterior Doors only adjacent to Exterior Windows? Or
Answer:
No.
Question
2:
Does this Condition apply to Interior Doors as well adjacent to Exterior
Windows?
Answer:
Yes, as per Chapter 24 of the 6th
Edition (2017) Florida Building Code, Building.
Staff
proposed amendment to the TAC action:
Question
1: Does this Hazardous location
apply to Exterior Doors only adjacent to Exterior Windows? Or
Answer:
No;
the general hazardous location requirements of Section 2406.4.2 of
the 6th Edition (2017) Florida Building Code, Building “the Code” apply
to glass adjacent to both exterior and interior doors.
Question
2:
Does this Condition apply to Interior Doors as well adjacent to Exterior
Windows?
Answer:
Yes; as per Chapter 24 of the 6th
Edition (2017) Florida Building Code, Building. the
general hazardous location requirements of Section 2406.4.2 of the Code apply
to glass adjacent to interior doors. However, within dwelling units and as per Section 2406.4.2,
Exception 4, of the Code, the hazardous location requirements of Section
2406.4.2 do not apply to glazing adjacent to interior doors where the glazing
in walls on the latch side of and perpendicular to the plane of the door in a
closed position.