The Second Egress:
A Wicked Problem


Conrad Speckert
McGill University
School of Architecture


Written January 4, 2021
Revised March 18, 2022

Published in Cellar Architectural Journal, 2023








This paper presents a first attempt to decode the requirement for two exit stairs in the National Building Code of Canada – to document its adverse effect on the design of small apartment buildings, and to compare Canada with other jurisdictions where this is not required. This study has since evolved into a project to thoroughly compare international building codes, study the history of the Canadian requirements and submit a code change request to the federal code commission. Underpinning the research is the idea that architects should actively question and contribute to the rules we work with.



A means of egress is defined by the 2015 National Building Code of Canada as a “continuous path of travel provided for the escape of persons from any point in a building or contained open space to a separate building, an open public thoroughfare, or an exterior open space protected from fire exposure from the building and having access to an open public thoroughfare.”1 Across Canada, the building code requires two means of egress for any multi-unit residential building exceeding two storeys, such that buildings of three storeys are subject to the same basic requirement as buildings of thirteen, or even thirty storeys. The implications of this rule upon the layout and therefore the efficiency of small apartment buildings is immense and creates a significant barrier to the construction of ‘missing middle’ and mid-rise housing. In the context of Toronto, the uneven distribution of housing typologies - as a city of detached single-family dwellings covering two-thirds of the land zoned for residential use, and a downtown of high-rise condo towers - is further exacerbated by this building code requirement.2



“In many of Toronto’s residential neighbourhoods deemed to be stable or imbued with character, our current zoning regulations make it far easier to build a 5,000 square foot single-family house than a multi-unit low-rise apartment or a rental suite in a house.” 3




It would be reasonable to expect that as buildings increase in scale, corresponding regulatory frameworks would adjust proportionately. In 2005, the Province of Ontario established the Greenbelt to prevent additional urban sprawl around Toronto, compelling developers to look inward at the existing urban and suburban fabric. In order to accommodate growth without defaulting to the high-rises of the downtown core or upsetting existing homeowners in the so-called ‘Yellowbelt’ of residential detached zoning, planners identified arterial roads as appropriate opportunities for densification. Officially adopted into the Toronto Official Plan in 2010, the ‘Avenues and Mid-rise Buildings Performance Standards’ established new building heights corresponding to the width of adjacent streets along the main transit corridors of the city. While this planning policy allowed for mid-rise densification, the reality is that very little has since been built. Land use and zoning restrictions were revised, but the construction of mid-rise buildings remains subject to the same lengthy approvals process, development charges and building code requirements as much taller high-rise buildings, thereby making them significantly less efficient and cost-competitive to build.




2010 Mid-rise Buildings Performance Standards. Image courtesy City of Toronto.



1 National Building Code of Canada 2015.



2 City of Toronto, “Expanding Housing Options in Neighbourhoods”.







3 Annabel Vaughan, "Radical Typologies," in Alex Bozikovic, Cheryll Case, John Lorinc, and Annabel Vaughan, eds., House Divided: How the Missing Middle Will Solve Toronto’s Affordability Crisis, (Toronto, Ontario: Coach House Books, 2019), 157-166, 164.




“My colleagues, we like mid-rise work,” said architect Richard Witt, principal at Toronto’s Quadrangle. “It’s interesting; it’s less formulaic, so you often get more interesting buildings. But the economics of it don’t work for anybody. Almost every client that’s done them has never done another one.” 4




Eberhard Zeidler (1926-2022) was one of Toronto’s most renowned modern architects. Born in Germany and educated at the Bauhaus, Zeidler immigrated to Canada in 1951 and designed many of the landmark buildings that define the city: the Eton Center; Ontario Place; the Rotman School of Management at the University of Toronto; as well as Sick Kids and Princess Margaret Hospital. In 1996, Zeidler wrote an essay entitled ‘Main Streets Initiative Handicapped by Building Codes,’ for the book A Practitioner’s Guide to Urban Densification. He describes the problem of the building code requirement for two exit stairs and how this makes it very difficult to build the kind of buildings envisioned by planning policy. The building typology of four to ten storey apartment buildings is typically designed with one exit stair and elevator shared between two to four apartments per floor. However, because the building code in Canada requires two means of egress, mid-rise buildings in this country are designed with two exit stairs connected by a long corridor, with a dozen or more units arranged along this corridor to achieve an efficient floor area ratio. Zeidler claims that “this appears to be a reasonable precaution for life safety. However, the life safety of this single stair type in Europe has been equal to, if not better than ours,” due to the fact that the single stair scheme is shared between fewer people on each floor.5 Such single stair buildings are the dominant housing type in dense urban contexts like Berlin, Paris, or Barcelona, but remain illegal to build in Canada since the National Building Code was first published in 1941. Amending the code requirement for two means of egress would make smaller apartment buildings of mid-rise height feasible on smaller properties and allow them to be built as originally envisioned by planning policy.




4 Shane Dingman, “Toronto wants mid-rise housing, but can we afford it?” The Globe and Mail, June 26, 2018,












5 Christopher Hume, “Stairway to a Better Toronto.” Toronto Star, January 22, 2004.

"The two-stair plan entrenched in our building codes should be eliminated, to give us the incentive to rebuild our main streets with residential/commercial buildings that are in scale with the streets."6




In February 2019, the Housing Affordability Task Group of the Ontario Association of Architects issued a report with the objective of “identifying key design and planning elements to address housing affordability, including building form, construction methods, location and municipal planning.”7 The document is a comprehensive summary of housing affordability issues and presents solutions to increase housing supply, to make housing financially attainable, and to address the urgency of the crisis. One of the recommendations includes creating “an alternative means of achieving Ontario Building Code compliance to permit a four-storey building with a single exit.”8 In alignment with Zeidler’s recommendation, the report also associates the issue of the second egress with the housing affordability crisis.



6 Ibid.




7 SvN Architects + Planners Inc, Housing Affordability in Growing Urban Areas, February 2019, OAA Affordability Task Group, 50.

8 Ibid.


Building code requirements for the number of exits in multi-unit residential buildings vary significantly between international jurisdictions - comprising different rules dependent on criteria such as building height, occupancy load, travel distances, dead-end lengths, stair width and configuration, fire-resistance rating of assemblies, fire-protection rating of doors, refuge areas and stretcher-sized elevators, automatic sprinkler systems and other protective measures. For instance, the United Kingdom’s Building Regulations are drastically different to the National Building Code of Canada. The United Kingdom does not establish a maximum building height for apartment buildings with a single exit stair.9 Tall residential buildings are designed with a stay-in-place firefighting strategy (Canada requires immediate evacuation), and regardless of building height, only a horizontal travel distance and maximum occupancy load per storey limit the size of the building, resulting in many tall buildings with a single exit stair.10 In 2017, one such building, the Grenfell Tower, was engulfed by the deadliest residential fire in the UK since the Second World War and cost the lives of seventy-two people. Subsequent inquiry determined the negligent use of combustible insulation to have caused the rapid spread of the fire across the building facade. The tower consisted of a twenty-four storey concrete structure with a single exit stair, for which the stay-in-place evacuation policy was sustained for more than eighty minutes before a general evacuation was ordered. Following the Grenfell inquiry, the government announced new fire safety regulations in 2020 to require sprinklering for residential buildings over eleven metres in building height, require increased evacuation signage, forbid the use of combustible materials in exterior wall assemblies and demand increased oversight during planning and construction.11 Notably, the new regulations do not include any changes to the unrestricted building height for single stair designs despite concerns raised by the Royal Institute of British Architects and London Fire Brigade.12


Consider another Commonwealth jurisdiction - In Australia, fire safety requirements increase significantly with buildings exceeding 25 metres in height, equivalent to the maximum vertical extent of a typical aerial apparatus (ladder firetruck). Buildings of up to ten metres in height are allowed to have a single unprotected escape path while buildings up to twenty-five metres in height require a single protected stair (corridor separation) and are governed by a maximum travel distance of six metres - only buildings exceeding twenty-five metres in height require two exit stairs.13 An excellent example of what the code allows for is the well-documented Nightingale 1 designed by Breathe Architecture in Brunswick, Australia - a five storey apartment building with a single central exit stair and a total of twenty apartments, on an urban infill property the size of a typical single-family detached lot.





Nightingale 1. (2017). Image by and courtesy of Breathe Architecture. Edited by author.






9 Her Majesty’s Government, Building Regulations 2010 – Fire Safety, Approved Document B, Volume 2: Buildings other than dwellings (2019 edition incorporating 2020 amendments), 2020.


10 Boris Stock and Karl Wallasch, “Fire Safety Requirements for High-Rise Residential Towers in England and Germany,” FeuerTrutz International, (2020): 5-10.

11 Ministry of Housing, Communities & Local Government, “A reformed building safety regulatory system: government response to the Building a Safer Future consultation”, London, UK, April 2020,

12 Kate Youde, “RIBA demands fire regs clarity amid single-stair towers controversy,” Architects Journal, January 26, 2022


13Australian Building Codes Board, National Construction Code, Series 2015, Volume 1 (Class 2 to Class 9 Buildings)


In Germany, the ‘Musterbauordnung’ is the model building code adopted with modifications by the individual states. This code establishes the principle that buildings must generally have two means of egress - however the second egress can be a designated window or balcony for rescue by the fire department.14 Such rescue is permitted with extension ladders reaching up to eight metres or with an aerial apparatus reaching up to twenty-two metres (only if the local fire department is equipped with such a firetruck). A second egress is not required if the first egress is a “fire safety” stair (a pressurized stairwell with a protected lobby and standpipe).15 Over twenty-two metres in height, buildings are classified as high-rises, for which a single exit stair is permitted in apartment buildings up to sixty metres in height with several additional fire safety requirements.16



Kompendium: Flächen für die Feuerwehr.
In Joseph Messerer and Peter Bachmeier, Vorbeugender baulicher Brandschutz, 9., aktualisierte Auflage, Vorbeugender Brandschutz (Stuttgart: Kohlhammer, 2021). Edited by author.

14 Fachkommission Bauaufsicht, Musterbauordnung 2002 [Model Building Code, 2002], Bauministerkonferenz, 2020.


15 Karl Wallasch and Boris Stock, “Single Living,” Fire & Risk Management (F&RM) Journal, (2009): 19.


16 Fachkommission Bauaufsicht, Muster-Richtlinie über den Bau und Betrieb von Hochhäusern, Fassuing 2008 [Model-Highrise-Regulations, 2008], Bauministerkonferenz, 2012.
The ‘Bremer Punkt’ (designed by Lin Architects + Urbanists) is a pilot project for urban densification in Bremen, Germany commissioned by the local housing association to address an “increasing housing shortage and a growing demand for affordable housing.”17 The project was included in the OAA’s Housing Affordability report as a case study on urban infill densification.18 The first of these projects, built in 2017, is a four-storey apartment building made of prefabricated, panelized wood construction with the single exit stair in cast concrete. The building is an almost perfect cube, occupying a footprint of 13.35 by 13.35 metres and fourteen metres in height. As a result of the single exit stair design, the building can be reconfigured for anywhere from four to eleven dwelling units, varying from studios of thirty square metres up to five bedroom units of 138 square metres, each benefiting from a corner condition and shallow depth. Alex Bozikovic, the architectural critic for the Globe and Mail newspaper and co-editor of the book House Divided: How the Missing Middle Can Solve Toronto’s Affordability Crisis, dedicates an entire chapter of this book to the ‘Bremer Punkt’. Bozikovic suggests that in the context of Toronto’s residential detached neighbourhoods, “if you built a Bremer Punkt building here, it would have a comparable footprint to the house that’s here now. It would be no taller than the neighbouring apartment buildings. To a casual observer, it wouldn’t look dramatically different in scale from the existing houses.”19





Bremer Punkt. (2017). Lin Architects Urbanists.
Image courtesy of Nikolai Wolff/Fotoetage




17 Maria Francisca Gonzalez, “Bremer Punkt / Lin Architects Urbanists,” ArchDaily, January 10, 2018.


18 SvN Architects + Planners Inc, Housing Affordability in Growing Urban Areas, 61.


19 Bozikovic, "The High Cost of Building a Box," in Bozikovic et al., House Divided, 189-192, 190.

“Larger buildings reflect economies of scale in multifamily construction. As land costs increase, developers need to fit more housing units on a single land parcel. The costs of design, regulation, and operations don’t vary much by building size, so larger buildings allow developers to spread these fixed costs over more apartments. As one developer put it: From an operations standpoint, it costs almost as much for us to operate a 30-40 unit building as it does a 100-unit building, so we are looking for sites that can accommodate larger projects.” 20




383 Sorauren is a ten-storey mid-rise development in the Roncesvalles neighbourhood of Toronto consisting of 142 residential units. The building won the 2017 Toronto Urban Design Award of Excellence for fitting in with the surrounding context of heritage industrial buildings and is considered an example of best practices in the design of mid-rise buildings. The project is described here to demonstrate the resulting building size and layout when dealing with the requirement for two means of egress. The plan consists of deep, repetitive and single orientation units accessed off an efficient double-loaded corridor with two exit stairs placed at opposite ends. The project is one of the best recent midrise buildings in Toronto and demonstrates what is presently viable in the best possible light. However, the reality is that this scale of development is deemed too small for Toronto’s market and serves as reminder that the ‘missing middle’ and midrise scale of the Bremer Punkt and Nightingale 1 remains unbuilt in this city partially due to the steadfast requirement for two means of egress.







383 Sorauren. Image and Illustration by and courtesy of architectsAlliance. Edited by author.







20 Hannah Hoyt, “More or Less? An Inquiry into Design and Construction Strategies for addressing Multifamily Housing Costs,” Joint Center for Housing Studies, Harvard University, 2020.

“Where our current system allows new development, it favours bigness: big plans, big sites, big buildings, big capital, and big billings for planners and lawyers who know how to navigate the maze of regulation and consultation that governments have put in place. The city – government and entrepreneurs alike – should be able to build new housing at every scale in every area. Right now, we cannot.” 21




The West Don Lands (also known as the Canary District) is another recent Toronto example of the resulting designs when two means of egress is required for mid-rise housing. In advance of the 2015 Pan American Games, the City of Toronto allocated eighty acres of former industrial land to serve initially as Athletes Village and thereafter as “vibrant twenty-first-century century neighbourhood” of mid-rise buildings.22 The precinct policy and urban plan for the neighbourhood has been developed as perimeter blocks of ten to fifteen storeys, each averaging more than 100 residential units. The buildings consist of either courtyard or L-shape floor plans with deep building depths and repetitive, single-orientation units arranged along a double-loaded corridor. While the building code specifies a maximum dead end condition of six metres to reach one exit stair, the maximum travel distance between two exit stairs is fourty-five metres, resulting in long, narrow and artificially lit corridors to reach a central elevator core.23 An alternate single exit stair design could have allowed the architects to subdivide the floor plans with fewer apartments sharing a stair on each floor, and to propose shallower building depths with units getting daylight and fresh air from both sides. The design flexibility of a single stair layout also could have accommodated more diversity in the mix of unit types and much-needed larger, more family-friendly apartments with three or four bedrooms.





21 Bozikovic, "Conclusion," in Bozikovic et al., House Divided, 229-234, 229.






22 Urban Design Associates, West Don Lands Block Plan and Design Guidelines, Toronto Waterfront Revitalization Corporation, 2006.


23 2012 Ontario Building Code, Section 3.3.1.9.9 and Section 3.3.1.4.4.

“In dense environments across much of America, urban homes are stacked and tied together by a framework of systems that meet specific functions within tight efficiency requirements. These internal systems allow for humans to make their way from the public street to their dwellings, often hundreds of feet off the ground with ease and comfort. They also allow for mail to be delivered, trash to be removed, and water, air and electricity to service each home. And in all but a few examples, these functions are gauged by their built efficiency: what arrangement allows for the maximum amount of rentable area with the minimum amount of supporting space. In other words, how can a building make apartments as large as possible while meeting the minimum code and engineering standards to support their occupancy. To meet these ends, the connective tissue to access American urban dwellings has leaned heavily on the implementation of the double-loaded corridor. While not initially recognizable by name, the double-loaded corridor is spatially ubiquitous. Uniformly 5 feet wide with two rows of 26-30 foot deep dwellings flanking each side, these arrangements maintain a uniform height, material and direction. Their often lengthy procession is centered on an elevator core and capped by two egress stairs; a case study in anti-human engineering.” 24





Building code requirements for means of egress are closely tied to firefighting practices, and just as the code has evolved differently between jurisdictions, so to have firefighting practices. Though firefighting operations in Europe and North America share much in common, the differences in the design and tasking of aerial apparatus (ladder trucks) are a direct result of differences in evacuation and rescue practice. Aerial apparatus in Europe are used primarily as a rescue ladder with “a basket or small platform that can takefirefighters up and victims down,” whereas North American ladder trucks are equipped with pumps and water tanks and focused more on water flow and fire suppression.25 Fire truck manufacturers explain that differences in streets widths as well as the height of buildings also require “smaller, more compact aerials and more articulating platforms in Europe than we use in the U.S.”26 Means of egress therefore must be understood within the context of North American firefighting practices and urban planning. Nevertheless, performance-based building code compliance should allow additional life safety measures - like increased fire ratings on doors, limits to the number of dwelling units sharing the exit, or sprinklering and pressurization of the stairwell - to be proposed for a single stair design without any change to local firefighting and evacuation practices. It is also worth noting that many existing non-conforming buildings in Toronto today were built with a single exit stair.

















24 Frank Zimmermann, “Breaking Up with the Double Loaded Corridor: A Study of Progressive Housing Design and Its Influence on Social Networks,” 2020.









25 Alan M. Petrillo, “Fire Apparatus – United States vs. Europe,” Fire Apparatus Magazine, (June 7, 2016).

26 Ibid.

“Like most North American cities, Toronto has a history of incremental development that reflects growth patterns and population shifts. Take a walk through any older neighbourhood and you will see a diversity of housing stock: detached houses, duplexes, triplexes, walk-up apartments, rooming houses, small apartment buildings (fewer than eight to ten storeys), apartments above shops, laneway housing, coach houses, loft apartments in converted warehouses, multi-generational family housing, and everything in between. It is a perfect mix of housing types that organically grew out of the demands of people moving into the city. Yet the majority of this stock was built before Toronto’s zoning regulations came into effect in 1952. Paradoxically, much of what we love about the older parts of Toronto would not be allowed under current regulations.” 27




The conflicting priorities of planning departments with other institutions is a significant form of resistance to change, in which a technocratic approach of relying on empirical evidence can fail to produce consensus. The example of street building practices, explained by Professor Paul Hess at the University of Toronto, describes how “planning and other bureaucratic units within the urban bureaucracy such as fire departments often make competing or even contradictory safety claims. Pedestrian planners, for example, argue that narrow streets will reduce traffic speeds and the severity of pedestrian collisions, while fire department planners argue they will slow critical response times to fire or medical emergencies.”28 The issue of the second egress is a similar issue for which empirical evidence struggles to address inherently competing value systems between authorities. Hess further describes the dilemma of such wicked problems with the perspective of elected decision makers, who “may give less weight to the broad but relatively weak technical knowledge of planners, compared to the narrower, but more developed technical knowledge of engineers particularly as this is often directly connected to safety concerns and issues of legal liability. This inclusion or exclusion of actors and the differential valuing of viewpoints and types of knowledge in decision making processes narrows potential outcomes and sustains existing practices.” The term ‘wicked’ is borrowed from social policy and planning theory, used to define complex problems where stakeholders have differing or opposing views, and there is no immediate and ultimate way to test the success of a solution.29


In terms of a building code change request, the Canadian Commission on Building and Fire Codes, CCBFC, develops the model National Building Code on a five-year code cycle (each province thereafter harmonizes to it). A code change request to allow for single egress conditions will require review from several of the CCBFC’s Standing Committees: Use and Egress (SC-UE); Fire Protection (SC-FP); as well as Housing and Small Buildings (SC-HSB). Each committee includes twenty voting members (from within the construction industry, fire prevention and regulatory enforcement officers, as well as individuals from other research and public interest groups) who will need to form consensus that the requested change meets the respective fire and life safety objectives of the building code.














27 Vaughan, "Radical Typologies," in Bozikovic, et al., House Divided, 165.







28 Paul M. Hess, “Avenues or Arterials: The Struggle to Change Street Building Practices in Toronto, Canada,” Journal of Urban Design 14, no. 1 (February 1, 2009): 1–28.



29 Horst W. J. Rittel and Melvin M. Webber, “Dilemmas in a General Theory of Planning,” Policy Sciences 4, no. 2 (June 1, 1973): 155–69.


Building codes are by historical necessity, unyielding, the result of catastrophic fires in major cities at the turn of the twentieth century and an urgent need for regulation of construction practices within rapidly growing urban populations. The introduction of two means of egress was a decisive and understandable requirement within the context of an industry dominated by combustible wood-frame construction and remains in place today as undisputed regulatory permanence.30 However building codes do evolve to address emerging crises. Allowing mass timber construction at increasing heights to combat the embodied carbon of construction is proof that the governing assumptions on fire safety can be revised and adapted to new realities.31
 


“In the last century or two of social disruption, we were tempted by an excess of faith in the machine to do everything by means of it. We were like children left alone with a paint brush who applied it impartially to unpainted wood, to varnished furniture, to the tablecloth, to his toys, and to his own face. When with increased knowledge and judgment, we discover that some of those uses are inappropriate, that others are redundant, and that others are inefficient substitutes for a more vital adjustment, we will contract the machine to those areas in which it serves directly as an instrument of human purpose.” 32



 
The building code should not prohibit the construction of single stair buildings, but rather regulate the conditions in which it is acceptable. What additional life safety measures could be proposed for single stair buildings to meet the risk assumptions of the current code? The intention is to raise this question to architects, as well as planners, developers, and code consultants to reconsider the requirement for two means of egress. Canada is one of the most restrictive jurisdictions with regard to the maximum building height for single egress, and this presents a significant obstacle to building the much-needed ‘missing middle’ of housing, especially in Toronto. The intention of this paper has been to introduce the wicked problem of the second egress as it relates to the design and supply of housing and to offer a starting point for further investigation towards a building code change.




30 Keith Calder, The Historical Development of the Building Size Limits in the National Building Code of Canada, The Canadian Wood Council, 2015.


31 David Israelson, “'Harder, faster, better, stronger' Mass timber is trending up,” The Globe and Mail, August 16, 2022.







32 Lewis Mumford (1963) in Barbara Brown Wilson and Steven A. Moore, Questioning Architectural Judgment: The Problem of Codes in the United States, New York: Routledge, 2014.









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