Fire Escape Code

**NEW**  2012 IFC 1104.16.5.1   Examination: Fire escape stairs and balconies shall be examined for structural adequacy and safety, in accordance with Section 1104.16.5, by a registered design professional or others acceptable to the fire code official every five years, or as required by the fire code official. An inspection report shall be submitted to the fire code official after such examination.


Existing exterior fire escapes require an inspection by a registered design professional or persons acceptable to the fire code official no more than every 5 years.


2012 CODE: 1104.16.5 Materials and Strength. Components of fire escape stairs shall be constructed of noncombustible materials.

Fire escape stairs and balconies shall support the dead load plus a live load of not less than 100 pounds per square foot (4.78 kN/m2 ).

Fire escape stairs and balconies shall be provided with a top and intermediate handrail on each side.

The fire code official is authorized to require testing or other satisfactory evidence that an existing fire escape stair meets the requirements of this section.

1104.16.5.1 Examination. Fire escape stairs and balconies shall be examined for structural adequacy and safety, in accordance with Section 1104.16.5, by a registered design professional or others acceptable to the fire code official every five years, or as required by the fire code official. An inspection report shall be submitted to the fire code official after such examination.


CHANGE SIGNIFICANCE: Building fire escapes are a means-of-egress component in many existing multiple-story buildings. Neither the IBC nor IFC contains a specific definition as to what actually constitutes a fire escape, and in previous editions of the codes, they did not establish a frequency for their inspection. The IBC provisions for existing building in Section 3406.1.2 only permits a fire escape as a means-of-egress component in existing buildings and limits the installation of new fire escapes on existing buildings when the building code official determines they are necessary based on the substantiation by the registered design professional that exterior stairways cannot be used due to the lot line limiting the size of the stair, or conditions where the fire escapes could impact the egress path in sidewalks, alleys, or roads at grade. Additionally, new fire escapes, when allowed by the building code official, cannot utilize ladders or windows as a means of egress component. Fire escapes are typically prohibited in new construction.

A new requirement in Section 1104.16.5.1 establishes an inspection frequency for fire escapes and balconies erected on existing buildings. By design, fire escapes present a lot of concern to code officials because the stairs, ladders, balconies, and mechanical fasteners are commonly constructed of carbon or galvanized steel, which will rust if not properly maintained. Rust is a metal oxide that corrodes and damages carbon or galvanized steel and reduces its strength. The evaluation is necessary to confirm that this exterior stair egress component satisfies a minimum design load requirement prescribed in Section 1104.16.5, is properly maintained, and is available for service in the event of an emergency that requires the occupants to egress the building. Unless otherwise specified by the fire code official, the 2012 IFC requires an inspection of fire escapes and their balconies every 5 years. Fire escapes are now subject to specific examination requirements.

1104.16.5.1 continues International Code Council ® 42457_ch11_ptg01_122-128.indd 127 3/25/11 6:17 PM128 PART 3 ■ Building and Equipment Design Features The individual evaluating fire escapes is required to be a registered design professional or an individual approved by the fire code official. The evaluation should include a review of the requirements in ASCE 7, Minimum Design Loads for Buildings and Other Structures, including the requirements in Section 13.4 for mechanical fasteners and Section 4.4 for handrails and grab bars. If adopted by the jurisdiction, the individual performing the inspection should also review the ASCE 7 Appendix 11B requirements for existing buildings. 1104.16.5.1 continued 42457_ch11_ptg01_122-128.indd 128 3/25/11 6:17 PM

Portland, OR – Model City

Members of the National Fire Escape Association visit cities every week where both the Fire and Building Departments are in various stages of development with both interpretation and enforcement of their respective Fire Escape programs.  In about 75% of these cities, testing, inspection and certification of fire escapes fall on the city’s Fire Department or Fire Safety and Prevention Departments – the remaining cities have designated their Building Department govern these laws and its code.  Through our awareness, education and outreach programs, we have worked closely with many of these departments to help put our expertise and experience into action in improving the safety and enforcement of these valuable pieces of code.  One of first and greatest successes in this area comes from Portland, OR – our model city.

**For more information about the NFEA – visit our homepage**

Code FIR 2.08 – Fire Escape Issues: Portland, OR

Some 5+ years ago we ended up in contact with the Fire Prevention Department in Portland, OR.  Initially we came in to do a seminar on overall fire escape awareness in which we talk about steps for putting together a program of both awareness and enforcement.  This includes not only interpretation of existing code, but also the adoption of industry standard documentation, tags and designating exactly what it is that they will except as “other evidence of strength” for those certified to perform inspections.  What came of this one seminar resulted in many more seminars and some great results within the city in getting what is typically a very big problem that has been swept under the rug, under better control.

The following is the result of all that hard work (as printed here ):


Administrative Rule Adopted by Portland Fire & Rescue Pursuant to Rule-Making Authority



A. This policy is established February 12, 2008 and replaces previous policies CE B-3, B-9, and B-12. This policy combines elements from all three policies, the 2010 Portland Fire Code, and the 2010 Oregon Structural Specialty Code into this single document. B. It is the purpose of this policy to:

1. Establish procedures for the inspection, evaluation and testing of fire escapes, and to provide information pertaining to the acceptable methods of repair when needed.

2. Address the process for removal of counterbalance stairs.

3. Address the removal of fire escapes.

C. This policy applies to all structures where Portland Fire & Rescue (PF&R) has authority.

D. The City of Portland currently has more than 600 fire escapes that are attached to existing buildings and are part of the required emergency egress system or serve as firefighting platforms. Many of these fire escapes and the buildings they are attached to are very old. Without routine maintenance, deterioration can result in fire escapes becoming unsafe for use by occupants or firefighters during an emergency.

E. Counterbalance stairs allow occupants to exit fire escape platforms. Some building owners request the removal of counterbalance stairs to prohibit unauthorized use for entry into buildings. This policy provides guidance to resolving this public safety issue.

F. When exit systems throughout a building are upgraded, an owner may request removal of existing exterior fire escapes as part of the commercial building permit process.



1. Portland City Code (PCC) Title 31, 31.20.080

2. 2010 Portland Fire Code (PFC) Chapter 10

3. 2010 Oregon Structural Specialty Code (OSSC)


A. Implementation of Testing and Repair:

1. At the first available fire inspection (Regular/Special Owner Request/Special) following the effective date of this policy, fire inspectors shall perform a visual inspection of the fire escape(s).

2. The fire inspector shall determine whether or not the fire escape is an “imminent hazard” based upon key visual indicators (refer to Attachment #6). Key visual indicators include missing pieces, deformation of joints due to rust development, loose or absent connections between pieces, or degraded connections to the structure.

3. If the inspector determines a fire escape is an imminent hazard, he/she shall order an evaluation and certification of the fire escape by a registered design professional and comply with Section A, items (5), (6) and (7). NOTE: the definition of a Registered Design Professional can be found in the Oregon Structural Specialty Code.

4. If the fire escape is not deemed to be an imminent hazard following the visual inspection, the building owner will then have five (5) years from the date of the first available visual inspection by a fire inspector to complete an evaluation of the fire escape by a registered design professional and comply with Section A, items (5), (6) and (7).

5. An engineering assessment is required for the evaluation of a fire escape and shall involve a structural analysis, an in-situ load test or a combination of both.

a. The engineering assessment shall be based on the design criteria specified in Attachment #1.

b. In-situ load testing shall follow the requirements outlined in Attachment #2.

c. Structural analysis procedures shall follow the requirements outlined in Attachment #3.

6. During the evaluation process, if a fire escape component is determined to be in an unsafe/imminent hazard condition, the fire code official and building code official shall be notified immediately. Any deficiencies identified during the evaluation process shall be mitigated immediately. Any extensive repairs shall be performed under a permit through the City of Portland, Bureau of Development Services (BDS). Where permits are required for extensive repairs, a plan for mitigation of deficiencies, stamped by a registered design professional along with required calculations shall be submitted to BDS for review and approval. If work on a standpipe is also needed, a separate permit through the Fire Marshal’s Office shall be required.

7. An affidavit shall be provided by a registered design professional acceptable by the Fire Marshal indicating the fire escape has been evaluated, all deficiencies identified during the evaluation have been mitigated, and the fire escape is structurally safe. See Attachment #4 for the affidavit.

8. After the affidavit is accepted, a placard shall be posted on the approved fire escape. The placard will be provided by the Fire Marshal’s Office and must meet the following:

a. Placard facing the street on the balcony of the lowest level.

b. 12” x 12” with a white background and green numbers 6” in height.

c. Marked with the year that the fire escape was tested and approved.

d. Marked on the back with the building address.

B. Ongoing Testing and Repair Requirements:

1. After evaluating the fire escape as previously described in Section A, it shall be re-evaluated every 5 years as prescribed by the Portland Fire Code. Re-evaluation shall follow the procedures as previously described in Section A, items (5), (6), and (7).

C. Routine Maintenance:

1. When a fire escape shows signs of rust, paint deterioration, or requires minor repairs, such as incidental welding or the replacement of nuts and bolts, the fire inspector shall cite the owner or responsible party to make the necessary repairs. Generally, a permit is not required for minor repairs and routine maintenance. See Attachment #5 for Fire Escape Repair, Cleaning and Painting. NOTE: the Fire Marshal’s Office shall be notified prior to taking the fire escapes out of service for maintenance or repairs.

D. Other Fire Escape issues:

1. Fire escapes found to be in a condition that constitutes a significant hazard to building occupants and/or firefighters at any time shall be cause for immediate attention. In addition to citing the owner or representative to make the repairs the fire inspector shall consider the following:

a. Notify their supervisor or the Senior On-Duty.

b. Mark the areas in question on the fire escape with a contrasting color of paint to aid in locating the areas requiring repair. Refer to Attachment #6 for guidance.

c. Contact the Fire Liaison and request a fire company to come to the site to attach a placard to the lowest rung of the firefighter’s ladder and at the roof access to the fire escape. The placard will be provided by the Fire Marshal’s Office and must meet the following:

• 24” x 24” with a red background and a white reflective border.

• Marked with the “F/E” symbol – letters shall be a minimum of 12” in height with a minimum stroke width of 2”.

• Marked on the back with the building address.

d. Ensure the building occupants are notified that the fire escape is out of service. Consider signage at entry points to the fire escape and at the building entrance.

e. A fire watch may be necessary while the building is occupied until the repairs are completed.

f. Send an email regarding the hazard to “Fire Liaison”, the appropriate Battalion Chief, and to the first and second arriving EOPS suppression companies. Remember to send a follow-up email when the repairs are made.

2. In the course of their duty, fire inspectors shall insure that fire escapes are documented properly in FIRES2000; including the location on the building, last certification date and whether it is an imminent hazard.

3. Inspectors may want to consider a Stipulated Agreement due to the extended time frame sometimes necessary to complete some of this work; i.e. permit process, time of year and weather conditions can impact when and how some repairs can be made. Stipulated Agreements should be documented in the FIRES2000 Appeals & Agreements tab under “Agreements” and must include a “Due Date” along with an attached electronic copy of the agreement.

E. Fire Escape Access:

1. Exterior fire escapes are commonly accessed via doors/windows at the end of a corridor or via a tenant space/apartment unit. Exit access requirements limit the number and types of locks/locking devices, the size of the opening, size and type of breakable glass, the presence of tools for breaking the glass, and signage for locating the fire escape.

a. Visual inspection is required to determine that all landings are accessible from inside the building and provided with proper signage. Egress from the building shall be available from a clear opening having a minimum dimension of not less than that required by the code under which it was built. Such opening shall be operable from the interior of the building without the use of a key or special knowledge or effort. The sill of an opening giving access shall be not more than 30 inches above the floor of the building or balcony.

b. Locks: The final access opening to a fire escape is limited to a single locking device that can be operated without a key or special knowledge. Generally, this is a simple window latch located where it can be easily seen and reached. Additional storm windows and screens shall be as approved by the district fire inspector. Doors at the end of a hallway may have a simple passage handle or a thumb-turn lock.

c. Access Doors: Doors to businesses or apartments most often have a single breakable glass panel mounted near the door handle/thumb-turn lock. The glass should be marked ‘In Case of Emergency Break Glass’ with lettering that is a minimum of 1.5 inch tall letters and a contrasting color. There should be an appropriate tool suitable for breaking the glass hanging next to the door. The minimum size breakable glass panel is 6” diameter (or 6” x 6” square). Original State Law specified that the glass was to be single-strength in order to facilitate breaking. If other glass is used, the Fire Marshal may order a field test to prove the breakability. The only locking device allowed on these doors is one thumb-turn lock positioned near the passage set.

d. Break glass: consider the fact that tempered glass was not invented when the State law was written. Regular glass is no longer allowed close to a door handle under current building code because of the possibility of injury from broken shards. Single thickness tempered glass may be the best alternative, but only if a break glass tool is available, and the pane is large enough that there is confidence that the tempered glass will break with little effort.

F. Signage:

1. In addition to the marking of the glass on an access door, fire escape access points are to be provided with a sign “FIRE ESCAPE” to be visible on approach. These signs have been installed as paper/plastic/metal signs with external illumination, older style glass light fixtures (green or red) with FIRE ESCAPE painted on them, or newer internally illuminated signs indicating either FIRE ESCAPE or EXIT. Modifications or upgrades to existing signage may be ordered by the Fire Marshal or required as part of permitted work through the Bureau of Development Services. The preferred wording for signage leading to an exterior metal fire escape is “FIRE ESCAPE”.

G. Requests for Removal of Counterbalance Stairs:

1. Requests for removal may be granted by the Fire Marshal when the counterbalance stair can be used by unauthorized persons to enter the building. To approve removal, the Fire Marshal will judge all of the following in the affirmative:

a. Is an automatic sprinkler system installed (minimum coverage = exit way plus at least one head in each room)?

b. Are smoke detectors provided throughout all corridors?

c. Is the existing fire escape structurally sound and adequately maintained?

d. Can a 22’ extension ladder be used to access the lowest fire escape platform?

e. Are all previous appeals and agreements between the city and the building being maintained (Chapter 13, FM 68, FM41)? f. Is the central stair tower enclosed?

2. All requests for removal of counterbalance stairs shall be handled as an appeal item which includes payment of the fee specified in Title 31.

3. Requests for removal shall include floor plan(s) of the building which specifically details all stair towers, interior corridors, fire escape locations and location of counterbalance stairs to be removed.

4. If the counterbalance stair is removed, the hole in the platform shall be filled with a permanent grate or other material to meet minimum requirements as stated in Attachment #1.

5. Staff shall report to the Fire Marshal, with the answers to the above policy questions and a recommendation for or against removal.

6. The Fire Marshal shall accept, accept with conditions, or reject the request.

7. If the request is granted, removal shall be completed under benefit of permit through the Bureau of Development Services.

H. Requests for Removal of Existing Fire Escapes:

1. Request for removal shall be completed under benefit of permit through the Bureau of Development Services. NOTE: in addition to the standpipe requirements, the number and arrangement of exits shall comply with the current Oregon Structural Specialty Code. An alternative to a code compliant exiting system may be granted through a building code appeal.

a. The application shall include the following:

• Plot Plan showing the building in relation to adjacent property lines and fire escape location(s), and

• Floor Plans showing the exit layout on each floor in relation to the fire escape(s) being reviewed, location of interior standpipes, and location of the Fire Department Connection.

• Fire and Life Safety Summary identifying the building’s construction type, fire rating of the exiting system and types of fire protection equipment within the building.


#1 Fire Escape Performance Criteria  (PDF Document, 65 kb)

#2 Fire Escape Evaluation Using In-Situ Testing  (PDF Document, 67 kb)

#3 Fire Escape Evaluation Using Structual Analysis and Limited Testing  (PDF Document, 85 kb)

#4 Fire Escape and Fire Balcony Affidavit  (PDF Document, 108 kb)

#5 Fire Escape Repair, Cleaning and Painting  (PDF Document, 73 kb)

#6 Fire Escape Inspection Checksheet  (PDF Document, 94 kb)