Is a hall an "access room"

EmmetF

TGD B
1.5 Dwelling Houses
1.5.2 (i) any habitable room which is an inner room should be provided with a window for escape or rescue in accordance with 1.5.6.
1.5.6 (b) The bottom of the window opening should be not more than 1100 mm and not less than 800mm

Definitions - 1.0.9
"Inner room - A room from which escape is possible only by passing through an access room."
"Access room - Room through which passes the only escape route from an inner room."

In a bungalow with bedrooms located directly off a hall which leads to the front door (no lobby), is the hall an access room? Or is it the escape route?

In the case where there is a draft lobby to the bungalow, is the hall now an access room? I'm having difficulty wrapping my head around the definition above.

The reason I ask is, if the hall is an access room (in both cases), then there is no scenario whereby a bedroom (without an ensuite that has a window in accordance with 1.5.6) can have a window opening say 500mm above the finished floor level. I find this can restrict what you can do with the elevation of a small bungalow.

sydthebeat

EmmetF wrote: »

The reason I ask is, if the hall is an access room (in both cases), then there is no scenario whereby a bedroom (without an ensuite that has a window in accordance with 1.5.6) can have a window opening say 500mm above the finished floor level. I find this can restrict what you can do with the elevation of a small bungalow.

The hallway is an access route and the draught lobby doesn't constitute the creation of an inner room.

also, TGD K diagram 7 and section 2.4 dictates openable section levels for what are essentially ground floor windows. This section was created to deal with the apparent restriction in TGD B

the '800 above floor level' is required where there is more than a 1.4 m drop outside

EmmetF

sydthebeat wrote: »

This section was created to deal with the apparent restriction in TGD B

Thank you, I have been working with TGD K 1997, completely unaware a version was released in 2014.

Metric Tensor

I've had a lot of difficulty with this one syd -

From TGD B:

The bottom of the window opening should be not more than 1100 mm and not less than 800 mm (600 mm in the case of a rooflight) above the floor, immediately inside or beneath the window or rooflight. As an exception to the general guidance in TGD K (Stairways, Ladders, Ramps and Guards) that guarding be provided for any window, the cill of which is less than 800 mm in height above floor level, guarding should not be provided to a rooflight opening provided in compliance with this paragraph.

My reading of this is that any opening below 800mm regardless of the drop outside does not "count" as an escape window in compliance with TGD B.

I agree with you that TGD K does not mandate guarding for openings below 800mm at ground floor level but I have not found anywhere that then allows this window to count as the escape window.

Am I missing something?

EmmetF

Metric Tensor wrote: »

Am I missing something?

I think if we are talking about the literal wording of the law, the amendment in TGD K dealing with falls >1.4m doesn't change what is considered a window in compliance with 1.5.6, however it doesn't make sense from a fire escape point of view that a window opening needs to be 800mm above the FFL vs a 500mm opening. I would guess that when TGD B is revised, the wording in 1.5.6 regarding heights and guarding will be revised also. A bit of a grey area IMO.

sydthebeat

Metric Tensor wrote: »

I've had a lot of difficulty with this one syd -

From TGD B:


My reading of this is that any opening below 800mm regardless of the drop outside does not "count" as an escape window in compliance with TGD B.

I agree with you that TGD K does not mandate guarding for openings below 800mm at ground floor level but I have not found anywhere that then allows this window to count as the escape window.

Am I missing something?

i had been in contact with DOE on this issue years ago, before the revised TGD K, and they agreed that the 800 restriction shouldnt apply to ground floor windows as, practically, a door is allowed as an escape ope ... so a window within say 400mm of the floor should also be allowed.

Metric Tensor

I fully agree with both of you but I haven't seen it written anywhere - yet!

Any chance you got it in writing from them syd?

sydthebeat

Metric Tensor wrote: »

I fully agree with both of you but I haven't seen it written anywhere - yet!

Any chance you got it in writing from them syd?

yah i have it on the back of that willy wonka golden ticket

nah i didnt get it in writing, it was a phone conversation.

guess we should page Kceire on this?

Metric Tensor

Ah yes - I have the same Golden Ticket hanging on my wall with a sky-hook!

Gumbo

sydthebeat wrote: »

i had been in contact with DOE on this issue years ago, before the revised TGD K, and they agreed that the 800 restriction shouldnt apply to ground floor windows as, practically, a door is allowed as an escape ope ... so a window within say 400mm of the floor should also be allowed.

sydthebeat wrote: »

guess we should page Kceire on this?

Lower than 800mm at ground floor doesn't bother me at all as the drop outside is low.
Could be an argument for toughened/laminated glass to prevent injuries from falls etc


TGD Part B 2016, the new section is 1.3.7.
Wording doesn't seem to have altered from 2006.

Metric Tensor

I'm pretty sure the spirit of the rule is that the opening should not be below 800mm at any floor higher than ground floor but the wording is very direct.

It appears the Department mustn't have had (m)any queries on this if the new wording is unaltered!

sydthebeat

kceire wrote: »

Could be an argument for toughened/laminated glass to prevent injuries from falls etc
.

thats a requirement anyway under TGD K 2.5

EmmetF

Metric Tensor wrote: »

I'm pretty sure the spirit of the rule is that the opening should not be below 800mm at any floor higher than ground floor but the wording is very direct.

It appears the Department mustn't have had (m)any queries on this if the new wording is unaltered!

Still in draft format - where do we make a submission on the wording of 1.3.7? I feel like we should kick up a fuss.

EDIT: http://www.housing.gov.ie/public-consultation-review-part-b-fire-safety-building-regulations-2016

Link for public consultation on TGD B 2016 is above.

sydthebeat

EmmetF wrote: »

Still in draft format - where do we make a submission on the wording of 1.3.7? I feel like we should kick up a fuss.

EDIT: http://www.housing.gov.ie/public-consultation-review-part-b-fire-safety-building-regulations-2016

Link for public consultation on TGD B 2016 is above.

closing friday 14th october, and they havent dealt with this issue in the draft regs

Gumbo

Metric Tensor wrote: »

I'm pretty sure the spirit of the rule is that the opening should not be below 800mm at any floor higher than ground floor but the wording is very direct.

It appears the Department mustn't have had (m)any queries on this if the new wording is unaltered!

Still out for consultation.
DCC Building Control, are preparing their observations to be submitted.......so im told

Metric Tensor

I might try and make a submission on this issue if I get a chance.

Mellor

A hall is a circulation space. So rooms off of hallways are not inner rooms. (and therefore a hallway not an access room).


A window at ground floor with a cill bellow 800 can often be considered a door, not a window. So none of the restrictions in TGD B apply. There's is probablt some middle ground between a door and an escape window that it not covered. But remember that the TGDs are guidance, not laws.

Metric Tensor

Although they are only guidance you would be hard pressed to prove to a building control officer that your house was compliant with the law regrading fire safety if it did not comply with the TGD B guidance.

It's different in fire certificate cases where you can provide engineering solutions and have these "certified"

EmmetF

Just an update on this. The minimum height of a window of 800mm from the FFL has now been removed in the latest TGD - B (2017)

"(b) The bottom of the window opening should be not more than 1100 mm and in the case of a rooflight not less than 600 mm above the floor, immediately inside or beneath the window or rooflight."

it used to be worded as;

"The bottom of the window opening should be not more than 1100 mm and not less than 800 mm (600 mm in the case of a rooflight) above the floor, immediately inside or beneath the window or rooflight."

sydthebeat

EmmetF wrote: »

Just an update on this. The minimum height of a window of 800mm from the FFL has now been removed in the latest TGD - B (2017)

"(b) The bottom of the window opening should be not more than 1100 mm and in the case of a rooflight not less than 600 mm above the floor, immediately inside or beneath the window or rooflight."

it used to be worded as;

"The bottom of the window opening should be not more than 1100 mm and not less than 800 mm (600 mm in the case of a rooflight) above the floor, immediately inside or beneath the window or rooflight."

it hasnt really....

section (c) still refers to guarding being required for any window whos cill is less than 800mm above floor level (except for a roof light used for escape purposes)

so what they are say is ... you can have a first floor window as normal as long as the cill doesnt go below 800mm.... but where the cill DOES go lower than 800mm you need to provide guarding in accordance with TGD K

by omitting the reference to 800mm in section (b) they are accepting that architecturally sometimes a first floor window opening section may need to be lower than the 800mm that the previous regs outlawed..... once guarding is provided.

EmmetF

sydthebeat wrote: »

it hasnt really....

section (c) still refers to guarding being required for any window whos cill is less than 800mm above floor level (except for a roof light used for escape purposes)

so what they are say is ... you can have a first floor window as normal as long as the cill doesnt go below 800mm.... but where the cill DOES go lower than 800mm you need to provide guarding in accordance with TGD K

by omitting the reference to 800mm in section (b) they are accepting that architecturally sometimes a first floor window opening section may need to be lower than the 800mm that the previous regs outlawed..... once guarding is provided.

Yes it has. Previously you couldn't even have a ground floor window opening below 800mm from the FFL - now you can. That was the point of the revision, it didn't make sense to have a restriction in Part B when it was dealt with in Part K.

Part B (2006) - "The bottom of the window opening should be not more than 1100mm and not less than 800mm". This explicitly says the window opening needs to be at least 800mm from the FFL as we have discussed above.

sydthebeat

EmmetF wrote: »

Yes it has. Previously you couldn't even have a ground floor window opening below 600mm from the FFL - now you can. That was the point of the revision, it didn't make sense to have a restriction in Part B when it was dealt with in Part K.

Part B (2006) - "The bottom of the window opening should be not more than 1100mm and not less than 800mm". This explicitly says the window opening needs to be at least 600mm from the FFL.

we're kind of going round in circles here.... following on from this post just brings us straight back to the start of the thread.

the reason ive said that its hasnt really been removed is due to the spirit behind the original wording. The 800mm min was to protect against falling. This protection against falling is still there, in the very next section (c).

youve quoted the revised section (b) but you make no reference to the revision of section (c) which reintroduces the need for guarding when the cill is reduced below 800mm

Also..

Previously you couldn't even have a ground floor window opening below 600mm from the FFL - now you can.

ive designed many many ground floor windows below 800mm under 2006 TGD B... for reasons already stated in this thread.

Metric Tensor

To be fair to EmmetF syd I was always concerned about having fire escape windows on the ground floor that had an opening at closer than 800mm to the floor because, whilst I recognised that they were compliant with TGD K, on a strict reading they were non-compliant with TGD B.

I think this rewording that brings TGD B and TGD K into line with one another helps clarify what was probably the spirit of the rules anyway.

sydthebeat

Metric Tensor wrote: »

To be fair to EmmetF syd I was always concerned about having fire escape windows on the ground floor that had an opening at closer than 800mm to the floor because, whilst I recognised that they were compliant with TGD K, on a strict reading they were non-compliant with TGD B.

I think this rewording that brings TGD B and TGD K into line with one another helps clarify what was probably the spirit of the rules anyway.

agreed... but as there was a direct conflict with TGD K then individually as certifiers we needed to make a call on it.... and we had to ask ourselves WHY would windows lower than 800mm on a ground floor be an issue.... especially as the lower they go the more they essentially become a door.

anyway.... im glad they have clarified the issue.... as long as the requirement for guarding is understood fully.

Mellor

The TGDs are guidance not regulations. The onus is on designers to interpret the intention of the TGD in complying with the regulations. Not treating every word as black and white.

EmmetF

Mellor wrote: »

The TGDs are guidance not regulations. The onus is on designers to interpret the intention of the TGD in complying with the regulations. Not treating every word as black and white.

And now on this particular issue, there's no longer any need for interpretation. I was just updating you all to tie off this thread regarding the original issue I had - there's nothing to argue here.

fatty pang

EmmetF wrote: »

And now on this particular issue, there's no longer any need for interpretation. I was just updating you all to tie off this thread regarding the original issue I had - there's nothing to argue here.

From the horses mouth;
http://www.i-b-c-i.ie/docs/conferences/2017/2017-04_Chris_Barry_TGD_Part_B_Fire_Safety_Volume_2_Dwelling_Houses.pdf

1.3.7 Windows for escape or rescue
Remove angled approach
“Simplified wording” or change of meaning ?

fatty pang

sydthebeat wrote: »

anyway.... im glad they have clarified the issue.... as long as the requirement for guarding is understood fully.

Is it though ?

In post #12 you referred to TGD-K 2.5.
TGD-K 2.5 is very poorly worded; “Where guarding contains glazing, it should be in accordance with the recommendations of BS 6262 - 4: 2005”

BS 6262-4 is only concerned with accidental human impact and associated injuries. Guarding is something else altogether. Para 2.5 should be referring designers to BS 6180 Barriers in and about Buildings- Code of Practice where glazing providing containment, rather than merely safe breakage, is a fundamental criteria.

EmmetF

fatty pang wrote: »

From the horses mouth;
http://www.i-b-c-i.ie/docs/conferences/2017/2017-04_Chris_Barry_TGD_Part_B_Fire_Safety_Volume_2_Dwelling_Houses.pdf

1.3.7 Windows for escape or rescue
Remove angled approach
“Simplified wording” or change of meaning ?

"1.3.7.1
windows for escape or rescue (b) Simplified wording only reference egress requirement: ref to 800mm cill height removed"

I wouldn't call it a change of meaning. As we discussed above, I think we all agree that the previous wording was ambiguous and we understood what the spirit of the regulation was saying. Now that they have removed the 800mm restriction and referred over to Part K, that ambiguity is gone.

sydthebeat

fatty pang wrote: »

Is it though ?

In post #12 you referred to TGD-K 2.5.
TGD-K 2.5 is very poorly worded; “Where guarding contains glazing, it should be in accordance with the recommendations of BS 6262 - 4: 2005”

BS 6262-4 is only concerned with accidental human impact and associated injuries. Guarding is something else altogether. Para 2.5 should be referring designers to BS 6180 Barriers in and about Buildings- Code of Practice where glazing providing containment, rather than merely safe breakage, is a fundamental criteria.

the reference i was making to part 2.5 was in response to this post:

Could be an argument for toughened/laminated glass to prevent injuries from falls etc

which is pertinent to BS 6262-4

the requirement for pedestrian guarding at windows is set under section 2.3 and 2.4 of TGD K.
further guidance is advised under BS 6180: 2011

fatty pang

sydthebeat wrote: »

the reference i was making to part 2.5 was in response to this post: which is pertinent to BS 6262-4

I understand what you are referring to and I’m not taking issue with what you have written. The issue I have is with how the TGD is written.

the requirement for pedestrian guarding at windows is set under section 2.3 and 2.4 of TGD K.
further guidance is advised under BS 6180: 2011

As you point out section 2.3 refers to pedestrian guarding and sends the designer off to IS EN 1991-1-1. Section 2.5 referring to Guarding containing glazing sends the designer of to BS 6262-4. A fair percentage of them don’t get beyond that and end up specifying glass in compliance with BS 6262-4 in situations where containment is required in addition to safe breakage. BS 6180 is only mentioned in the what is effectively the Bibliography and how many people bother wading through that. Further difficulty results from BS 6180 having different loadings for glass barriers then those in the annex of IS EN 1991-1-1 (different jurisdiction). Esoteric some might say but I would maintain it’s the designers responsibility to provide the relevant loadings for the window contractor.