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Position of the DHHS Safety and Health Program

Minimum Width: Cublicles And Offices


What is the minimum acceptable width for entrances into cubicles and within single-person offices?
Regulatory Requirements
NFPA 101-1991:
5-1.2.9
5-3.4.1
26-2.3.2
27-2.3.2
Discussion
NFPA 101, Life Safety Code, 1991 Edition, was incorporated by 13 NCAC 7F.0102 as North Carolina Occupational Safety and Health Standards.
The North Carolina State Building Code was created by General Statute 143-138, and the Fire Prevention Code was created as a portion of that code. 101.3.2 of the Fire Prevention Code states: "The provisions of this code shall not be held to deprive any Federal or State agency, or any applicable governing body having jurisdiction, or any power or authority which it had on the effective date of the adoption of this code or of any remedy then existing for the enforcement of its orders, nor shall it deprive any individual or corporation of its legal rights as provided by law." Therefore, the Department of Labor is required to conform to the North Carolina State Building Code where it is more restrictive and/or does not conflict with NFPA 101-1991.
NFPA 101-1991 defines Means of Egress in 5-1.2.9 as "a continuous and unobstructed way of exit travel from any point in a building or structure to a public way and consists of three separate and distinct parts: (a) the exit access, (b) the exit, and (c) the exit discharge. A means of egress comprises the vertical and horizontal travel and shall include intervening room spaces, ramps, stairs, enclosures, lobbies, escalators, horizontal exits, courts, and yards."
In the 1991 Life Safety Code Handbook, Formal Interpretation 76-81 is reprinted, as follows:
"Question 1: Are doors that serve individual rooms, such as offices and classrooms, intended to be classified as a portion of a means of egress as defined in Paragraph 5-1.2.9?
"Answer: Yes."
NFPA 101-1991 5-3.4.1 states: "The minimum width of any exit access shall be as specified for individual occupancies by Chapters 8 through 30, but in no case shall such width be less than 36 inches." Three specific exceptions are provided. Both Chapter 26-New Business Occupancies and Chapter 27-Existing Business Occupancies, require conformance with 5-3, but specifically define egress width to 44 inches in the clear for corridors and passageways, with no exceptions provided.
Appendix A, A-26-2.3.2 states, however, that: "it is not the intent of this provision to apply to noncorridor or nonpassageway areas of exit access such as the spaces between rows of desks created by office layout or low height partitions." Low height partitions are not defined in the Life Safety Code, but in 804.1.2 of the North Carolina State Building Code, Volume V-Fire Prevention, it is stated that: "partitions, rails, counters, and similar dividers not over six feet high shall not be construed to form corridors." Therefore, entrances to cubicles and passages within offices created by furniture are governed by the requirement of 5-3.4.1, and the exceptions may be considered.
Exception 3 addresses Assembly Occupancies, which is not applicable in this instance.
Exception 2 allows 28 in. width in existing building occupancies. NFPA 101-1991 specifies the difference between new and existing occupancies as the date the building plans were approved measured against the date the Code was adopted by the authority having jurisdiction. OSHNC adopted NFPA 101-1991 on August 2, 1993. For the purposes of this Department, buildings which were completed prior to that data are "existing", while buildings completed after are "new". Any portion of a building altered or renovated are judged by the same determination, based on completion date of the renovation.
Exception 1 allows exception for doors as provided in 5-2.1.3. That standard states: "No door opening in the means of egress shall be less than 32 inches in clear width", and provides four exceptions. Exception 3 addresses detention and correctional occupancies, and exception 4 addresses dwelling units, neither of which are applicable. Exception 2 provides a minimum of 28 inches for existing buildings. Exception 1 states: "Exit access doors serving a room not greater than 70 square feet and not required to be accessible to persons in wheelchairs shall not be less than 24 inches."
As far as moveable furniture is concerned, 5-3.4.1 Exceptions 1, 3, and 4 do not apply, which leaves a requirement of 36 inches for new buildings and 28 inches for existing buildings. The North Carolina State Building Code, Volume V, states in paragraph 808: "Where the floor space of an occupancy is occupied by tables, chairs, or other moveable furniture, aisles with at least 36 inches of clear width shall be maintained to provide ready access to exit doorways." There are no exceptions provided: however, 101.5 allows "existing conditions not in strict compliance with this code may be permitted to continue if, in the opinion of the fire official, these conditions do not constitute a distinct hazard to life or property." However, because furniture is so easily and often rearranged, moved, or added, it is reasonable to conclude that the minimum acceptable clear width of passage through moveable furniture should be established at a uniform 36 inches.
To address cubicles, one must first fit them into the definitions provided by the standards and codes. Although not specifically addressed in NFPA 101-1991 or in the North Carolina State Building Code, there are several references to "partial partitions", "low-height partitions", and similar terms, which suggest that neither code consider cubicles are a part of the building structure. However, it is reasonable to conclude that partitions are also not "moveable furniture" as referenced in Volume V, 804 - which provides examples such as "tables, chairs", and other items which could be easily thrust out of the way in the event of a fire emergency. Cubicle walls are "portable" and can be moved, but must be first disassembled, and are usually connected to the building structure either directly or through electrical wiring or power poles. The 1997 edition of the Life Safety Code - which does not have the force of law as does the 1991 edition or the Building Code - addresses exit access through "tables, desks, bookcases, counters, or by partitions that are less than floor to ceiling height" as corridors, although they do not have to have 1 -hour fire separation or meet the 44-in. width requirement. Therefore, it is also reasonable to conclude that exit access through cubicle partitions are subject to the requirement of 5-3.4.1 or Exception 2 (depending upon installation date), and must maintain 36 inches of clear width.
Entrances into individual cubicles are also a point of some debate. Although some argument may be made that the entrance to a cubicle is not a "door" per se, the intent of 5-3.4.1 Exception 1 as described in the Handbook is: "to allow a small room (probably occupied by only a couple of people) that is not required to be accessible to people in wheelchairs to use what may be considered to be an absolute minimum size door." It is reasonable to conclude that cubicles, and therefore entrances into cubicles, fall under that intent.
However, the Americans with Disabilities Act includes Title II, Nondiscrimination on the Basis of Disability in State and Local Government Services. Under Title II, Section 35.151(a) : "Each facility or part of a facility constructed by, on behalf of, or for the use of a public entity shall be designed and constructed in such manner that the facility or part of the facility is readily accessible to and usable by individuals with disabilities, if the construction was commenced after January 26, 1992." The standards for accessibility are named in 35.151(c) as "Americans with Disabilities Act Accessibility Guidelines for Buildings and Facilities." These guidelines require in 4.13 a minimum width for doors at 32 inches. Additionally, the North Carolina State Building Code, Volume 1-C Accessibility Standards, also require a 32-inch clear width.
In conclusion, Exception 1 to 5-2.1.3 does not apply, and entrances to cubicles may be no narrower than 32 inches in clear width.
In the Department of Labor, cubicles were installed with approximately 36 inches in clear width at entrances, and were provided with modular bookshelves and filing cabinets which did not impact or interfere with egress. Over time, employees of the Department have added filing cabinets, bookshelves, and other pieces of furniture as convenience and need dictated. However, such actions cannot be at the expense of safety, or of the regulations which we as a public entity are required to meet.
Conclusions
1. Corridors separated from other parts of the building by floor-to-ceiling walls or partitions shall have a minimum width of 44 inches.
2. Passages between cubicles shall have a minimum clear width of 36 inches.
3. In single rooms which are not a part of a common path of travel, aisles shall be maintained from any point in the room to the door of that room, with a minimum clear width of 36 inches.
4. Entrances into cubicles shall have a minimum clear width of 32 inches.

This page last updated on August 31, 2004.

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