Date: January 8, 2008

Attention: ASCIP Members

Subject: Residential-Type Fire Escape Ladders - Updated

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ASCIP has received numerous inquiries regarding the potential use of various residential-type fire escape ladders for emergency evacuation of teachers and students from classroom windows on the elevated floors of school buildings having two or more stories. Some classroom occupants reportedly fear becoming entrapped should a structure fire make other existing exits impassable.

ASCIP has researched applicable codes and standards, reviewed product and manufacturer's documentation and consulted with fire and life safety experts on this topic. School buildings are generally required to meet the Means of Egress standards and guidelines of the Division of the State Architect (DSA), California Code of Regulations, Title 24 (California Building Code) and Title 19 (State Fire Marshal/Public Safety).

Most if not all portable self-rescue ladders and like devices are designed and marketed for residential use and utilize an upstairs window or similar architectural feature as an attachment point. In respect to such use in a school environment, the California Code of Regulations, Title 24 (California Building Code) does not require windows to be provided in school buildings as long as adequate artificial light and ventilation are provided. California schools are also not required to install windows for the purpose of providing an alternate escape route or rescue point. Therefore, the proper attachment and anchorage of a self-rescue device may not be possible. Additionally, with the implementation of the 2007 California Building Code on January 1st, 2008, Title 24 Section 3404.1.3 does not allow new fire escapes to incorporate the use of ladders or access by windows in existing buildings.

The National Fire Protection Agency (NFPA) Fire and Life Safety Handbook strongly discourages the use of fire escape ladders, windows, ropes and portable ladders as a means of emergency egress from buildings. The use of such devices presents additional hazards during evacuation due to their limited size, capacity and stability.

Additionally, collapsible residential-type fire escape ladders may not meet accessibility guidelines for use in educational institutions by disabled persons.

Manufacturers' instruction manuals for such self-rescue devices also warn that collapsible, residential-type, fire escape ladders should not be deployed from a window located directly above a window from the first story, as the rung stabilizers would break through the glazing of the window below, destabilizing the ladder which could cause a person descending on it to fall and be injured or killed. Additionally, these ladders are designed to be used by only one person at-a-time. Should a person panic or become entangled in the ladder, that escape route would become unusable and present additional rescue and evacuation responsibilities. More than one person using such ladders at the same time could overload the product and result in failure when most needed.

In California, school buildings are designed and constructed to meet applicable building and safety codes, are reviewed and approved by the Division of the State Architect and contain appropriate means of egress and/or safety systems for the protection of the occupants. Departure from such approved standards may result in potential liability and increased risk rather than a risk reduction. ASCIP does not recommend the use of any collapsible, residential-type, fire escape ladders or devices in school buildings.

ASCIP staff is available to assist in addressing potential fire and life safety questions and concerns as they may arise. Please let us know if we can be of assistance.
Updated March 2008