Minimum Commercial 2nd Door Width & Any Exceptions

[Ed Scanlan]

20221017_070137.jpg

I have a client in NJ desiring an additional door be installed between two existing doctor offices. The subject partition is non-loadbearing and there are 36” doors already present in each office. Due to counters/cabinets, the available space prohibits a matching 36” desired door between the two spaces. It appears the minimum width door is 32” (IBC 1010.1.1)? Can you confirm? More importantly, might there be any exception for a smaller door (say, 30”)? For example, since each office already has full size 36” doors and this new one is merely a passage door between the two offices. A sketch is pasted/attached herein.

I did see the exception #1 of the related post < viewtopic.php?f=17&t=175&p=471#p468 > but it referenced R groups – this would be business/commercial.

Thank you.

[Jerry Peck - Codeman]

Many building code questions are simple and have simple answers, other building code questions appear simple, and are simple when answered with "It depends", as in it depends on things not stated in the question.

Making a presumption that the following code applies: it is an existing building (obviously, yes); the work area does not include exits or corridors shared by more than one tenant (from IEBC 804.1 Scope), and that the work area is equal to or less than 50 percent of the building area (from IEBC 603.1 Scope).

Starting at the NJ building codes: https://www.nj.gov/dca/divisions/codes/codreg/ , which linked the 2021 IBC: https://codes.iccsafe.org/content/IBC2021P2 , which confirmed that we were in the correct code for a doctor's office: (bold and underlining are mine)

The IBC states:
- [A]101.4.7 Existing buildings.
- - The provisions of the International Existing Building Code shall apply to matters governing the repair, alteration, change of occupancy, addition to and relocation of existing buildings.

From the ICC 2021 Existing Building Code:

- Section 101
- - Scope and General Requirements
- - - [A] 101.4 Applicability
- - - - This code shall apply to the repair, alteration, change of occupancy, addition and relocation of existing buildings, regardless of occupancy, subject to the criteria of Sections 101.4.1 and 104.1.2.
- - - - [A] 101.4.1 Buildings not previously occupied.
- - - - - (not applicable to the question)
- - - - [A] 101.4.2 Buildings previously occupied.
- - - - - The legal occupancy of any building existing on the date of adoption of this code shall be permitted to continue without change, except as is specifically covered in this code, the International Fire Code, or the International Property Maintenance Code, or as is deemed necessary by the code official for the general safety and welfare of the occupants and the public.

- Chapter 2
- - Definitions
- - - Section 202
- - - - General Definitions
- - - - - [A] Alteration. Any construction or renovation to an existing structure other than a repair or addition.

- Chapter 6
- - Classification of Work
- - Section 603
- - - Alteration - Level 2
- - - - 603.1 Scope.
- - - - - Level 2 alterations include the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment, and shall apply where the work area is equal to or less than 50 percent of the building area.
- - - - - Exception The movement or addition of nonfixed and movable fixtures, cases, racks, counters and partitions not over 5 feet 9 inches (1753 mm) in height shall not be considered a Level 2 alteration.
- - 603.2 Application.
- - - Level 2 alterations shall comply with the provisions of Chapter 7 for Level 1 alterations as well as the provisions of Chapter 8.

- Chapter 7
- - Alterations - Level 1
- - - Section 704
- - - - Means of Egress
- - - - - 704.1 General
- - - - - - Alterations shall be done in a manner that maintains the level of protection provided for the means of egress.

- Chapter 8
- - Alterations - Level 2
- - - Section 804
- - - - Means of Egress
- - - - - 804.1 Scope
- - - - - - The requirements of this section shall be limited to the work areas that include exits or corridors shared by more than one tenant within the work area in which Level 2 alterations are being performed, and where specified they shall apply throughout the floor on which the work areas are located or otherwise beyond the work area.

While the NJ building codes referenced the IBC, which exempts out existing buildings to the IEBC, the NJ codes also references the Barrier Free Code (identified as Chapter 11 of the IBC).

Chapter 11 of the IBC is the accessibility code: (which does not specifically exempt existing buildings)

- Chapter 11 Accessibility
- - Section 1103
- - - Scoping Requirements
- - - - 1103.2 General exceptions.
- - - - - Sites, structures, facilities, elements and spaces shall be exempt from this chapter to the extent specified in this section.
- - - - - 1103.2.1 Specific requirements.
- - - - - - Accessibility is not required in buildings and facilities, or portions thereof, to the extent permitted by Sections 1104 through 1112.
- - - - - 1103.2.2 Employee work areas.
- - - - - 1103.2.3 Detached dwellings.
- - - - - 1103.2.4 Utility buildings.
- - - - - 1103.2.5 Construction sites.
- - - - - 1103.2.6 Raised areas,=.
- - - - - 1103.2.7 Limited access spaces.
- - - - - 1103.2.8 Areas in places of religious worship.
- - - - - 1103.2.8 Equipment spaces.
- - - - - 1103.2.10 Highway tollbooths.
- - - - - 1103.2.11 Residential Group R-1.
- - - - - 1103.2.12 Day care facilities.
- - - - - 1103.2.13 Detention and correctional facilities.
- - - - - 1103.2.14 Walk-in coolers and freezers.

Note that "existing buildings" is not specified as being exempt from this Chapter 11 in Section 1103. Also note that 1103.2.1 Specific requirements can serve as an 'exception to the exemption' listed here if Sections 1104 through 1112 specifically includes it.

In various sections in the IEBC it states that alterations shall be 'not less safe' than was what legally existing, with the caveat that if the IBC allows for 'less safe' work than what was legally existing, then the IBC may be applied to allow for the 'less safe' work.

Here is a good place to give my base description of what building codes are: building codes are simply the most unsafe one is legally allowed to construct something. Or, to state it less obtrusive that "most unsafe": building codes are simply the least safe one is legally allowed to construct something. Both are one and the same, it is just that the "most unsafe" wording seems to get comments of 'but we are not building unsafe structures'. When, in fact, no structure "is safe". Some structures may be 'more safe' than other structures are ... no structure "is safe".

Keep in mind that all "new work" needs to be done in compliance with the code applicable at the time of the "new work", in this case, the IBC. Adding a door is "new work".

From the 2021 IBC for "new work": (bold and underlining are mine)

- SECTION 1010
- - DOORS, GATES AND TURNSTILES
- - - 1010.1 General.
- - - - Doors in the means of egress shall comply the requirements of Sections 1010.1.1 through 1010.3.4. (blah, blah, blah - doesn't apply to the question)
- - - - 1010.1.1 Size of doors.
- - - - - The required capacity of each door opening shall be sufficient for the occupant load thereof and shall provide a minimum clear opening width of 32 inches (813 mm). The clear opening width of doorways with swinging doors shall be measured between the face of the door and the stop, with the door open 90 degrees (1.57 rad). Where this section requires a minimum clear opening width of 32 inches (813 mm) and a door opening includes two door leaves without a mullion, one leaf shall provide a minimum clear opening width of 32 inches (813 mm). In Group I-2, doors serving as means of egress doors where used for the movement of beds shall provide a minimum clear opening width of 41 1/2 inches (1054 mm). The minimum clear opening height of door openings shall be not less than 80 inches (2032 mm).
- - - - - Exceptions:
- - - - - - 1. In Group R-2 and R-3 dwelling and sleeping units (blah, blah, blah - not applicable)
- - - - - - 2. In Group I-3, (blah, blah, blah - not applicable)
- - - - - - 3. Door openings to storage closets less than 10 square feet (0.93 m2) in area (blah, blah, blah - not applicable)
- - - - - - 4. Width of door leaves in revolving doors (blah, blah, blah - not applicable)
- - - - - - 5. The maximum width of door leaves in power-operated doors (blah, blah, blah - not applicable)
- - - - - - 6. Door openings within a dwelling unit or sleeping unit (blah, blah, blah - not applicable)
- - - - - - 7. In dwelling and sleeping units (blah, blah, blah - not applicable)
- - - - - - 8. In Group I-1, R-2, R-3 and R-4 occupancies, (blah, blah, blah - not applicable)
- - - - - - 9. Door openings required to be accessible intended for user passage shall have a minimum clear opening width of 31.75 inches (806 mm).
- - - - - - 10. Buildings that are 400 square feet (37 m2) or less (blah, blah, blah - not applicable)
- - - - - - 11. Doors to walk-in freezers and coolers (blah, blah, blah - not applicable)
- - - - - - 12. The minimum clear opening width shall not apply to doors for nonaccessible showers or sauna compartments.
- - - - - - 13. The minimum clear opening width shall not apply to the doors for nonaccessible toilet stalls.
- - - - - 1010.1.1.1 Projections into clear width.
- - - - - - There shall not be projections into the required clear opening width lower than 34 inches (864 mm) above the floor or ground. Projections into the clear opening width between 34 inches (864 mm) and 80 inches (2032 mm) above the floor or ground shall not exceed 4 inches (102 mm).
- - - - - - Exception: Door closers, overhead door stops, power door operators, and electromagnetic door locks shall be permitted to be 78 inches (1980 mm) minimum above the floor.

The above brings up a question: means of egress

- [BE] MEANS OF EGRESS. A continuous and unobstructed path of vertical and horizontal egress travel from any occupied portion of a building or structure to a public way. A means of egress consists of three separate and distinct parts: the exit access, the exit and the exit discharge.

1010.1 General states "Doors in the means of egress" ... versus ... 'doors in a required means of egress'. The proposed door would be a doors in the means of egress (that door would be in the "egress travel from any occupied portion of a building or structure"), thus the proposed door would be required to comply with 1010.1 and its exception: "9. Door openings required to be accessible intended for user passage shall have a minimum clear opening width of 31.75 inches (806 mm)."

HOWEVER, there may be an option ... but you would need to get the approval of the AHJ ... if a permanent sign was placed on the door and possibly above the door, such as where an exit sign would be located, with the sign stating " NOT AN EXIT ". If the door is "not an exit", it is no longer 'part of the means of egress'. Those two rooms only "require" one egress door, adding another door between the two offices allows that additional door to be used by either office as a second means of egress - a sign stating "NOT AN EXIT" may ... may ... be accepted by the AHJ as "not being in a means of egress and thus not an egress door".

HOWEVER (this may be a dreaded "however") ... that door may likely need to comply with the Accessibility Code, in which case, that door would need to comply with the NJ Barrier Free Subcode: https://codes.iccsafe.org/content/IBC2021P2 , which links to the 2021 IBC Chapter 11, Accessibility.

Which takes us to: https://www.ada.gov/regs2010/2010ADASta ... Id-1006675 )bold and underlining are mine)

- 404.2 Manual Doors, Doorways, and Manual Gates. Manual doors and doorways and manual gates intended for user passage shall comply with 404.2.
- - 404.2.1 Revolving Doors, Gates, and Turnstiles. Revolving doors, revolving gates, and turnstiles shall not be part of an accessible route.
- - 404.2.2 Double-Leaf Doors and Gates. At least one of the active leaves of doorways with two leaves shall comply with 404.2.3 and 404.2.4.
- - 404.2.3 Clear Width. Door openings shall provide a clear width of 32 inches (815 mm) minimum. Clear openings of doorways with swinging doors shall be measured between the face of the door and the stop, with the door open 90 degrees. Openings more than 24 inches (610 mm) deep shall provide a clear opening of 36 inches (915 mm) minimum. There shall be no projections into the required clear opening width lower than 34 inches (865 mm) above the finish floor or ground. Projections into the clear opening width between 34 inches (865 mm) and 80 inches (2030 mm) above the finish floor or ground shall not exceed 4 inches (100 mm).
- - - EXCEPTIONS:
- - - - 1. In alterations, a projection of 5/8 inch (16 mm) maximum into the required clear width shall be permitted for the latch side stop.
- - - - 2. Door closers and door stops shall be permitted to be 78 inches (1980 mm) minimum above the finish floor or ground.

32 inches minimum width, with doors in alterations (which is what that is) being allowed an exception for a reduction of 5/8 inches, giving a minimum clear opening of 31 3/8 inches.

Note: I will come back and review it with a fresh mind - eyes glazed over right now from reading too many codes.

[Jerry Peck - Codeman]

I came back with a fresh mind, reviewed the codes and my answer, made some underlining and bold highlighting changes, along with a couple of grammatical error corrections, added some additional explanatory comments, corrected some typos, and - hopefully - have it all corrected and done.