Hatchway or bulkhead doors must be lit even where the local building code doesn't consider them to be an official entrance or path of egress.
The drawing shows a hatchway door to a dwelling basement, with the regular back door on the same side of the house and about 15 ft away. There have been many questions over the years concerning whether the hatchway needs a light, and if so, whether a light had to be dedicated for this area. Another question has been whether a light in the basement could be used for this purpose. The reasoning for this approach is that when the hatchway is locked, it cannot be opened from the outside, only from within. Therefore, the likely use at night would be from the inside, allowing that light to be turned on.
The EC&M panel's response
We think the hatchway doorway requires illumination from the outside. However, this illumination might be provided by an adjacent source as long as the inspector was satisfied that the adjacent source was adequate. Frequently, but certainly not in all cases, we think the illumination that is customarily available in the back of a dwelling is reasonably adequate for this purpose.
The relevant requirement in the NEC is the first paragraph in Sec. 210-70(a):
(a) Dwelling Units. At least one wall switch-controlled lighting outlet shall be installed in every habitable room; in bathrooms, hallways, stairways, attached garages, and detached garages with electric power; and at the exterior side of outdoor entrances or exits.
We think that the phrase "entrances or exits" includes any doorway that can reasonably be used to enter or exit a building, whether or not the building code defines the doorway as a legitimate path of egress. The building code definitions are for a different purpose related to the speed and ease of egress, particularly during a fire. The NEC requirement is related to the safety of personnel at night. These are entirely different objectives, and therefore the words can be applied differently. Nothing in the NEC remotely implies that the terminology within it must be bound by the usage in a building code.
The mandatory rules for lighting outlets originated 20 years ago, and required lighting for "outdoor entrances." This was changed in the 1987 NEC to read as it does today, "outdoor entrances or exits." There were two proposals in that cycle to clarify the entrance rule, both from inspectors. The first, which was accepted, suggested adding "or exits." The submitter noted instances of multifamily occupancies with exit doors that had all exterior hardware removed, so the door could not be opened from outside. Since this could not normally be an entrance, requiring a lighting outlet was creating an enforcement problem.
The second proposal was to add the phrase "including basement entrances." The inspector noted that this was "often an area of dispute between the owner and inspector," and that "this type door is the most controversial of all basement doors." He said that developers and builders seem to think that an "entrance" is "where your company enters the building." The submitter also noted that these steps were typically very steep and required "the safety afforded by lighting." We would also add that in some houses, there is no inside access to the basement, which means the hatchway must be used for basement access, and at night whenever necessary.
He did not do as well with CMP 2, however. They rejected the proposal, but apparently not because they disagreed with the concept of lighting the hatchway. They rejected the proposal because "a basement entrance is an outdoor entrance," and they also referred to the panel action accepting the words "or exits." In other words, the only reason for rejecting the proposal was that CMP 2 felt the existing wording clearly included these entries and did not need further modification.
The next question is whether the light must be exclusively for the hatchway, or whether some other nearby source would do. The Code properly leaves this to local interpretation. The requirement is for lighting outlets "at" outdoor entrances or exits. Where the normal back door lighting is nearby, an inspector could reasonably consider the one outlet to be "at" both entries.
We think inspectors should be flexible in applying the word "at" and do so in terms of the objective of the requirement. If there is a reasonable degree of illumination for the hatchway stairs, then a dedicated light need not be installed. Common sense would hold that some consideration must be given to the character of the luminaire; a set of floodlights would be "at" a wider span of adjacent entries than a 60W bulb in a coach light.
The other question is whether the light could be on the inside of the basement. We think that the answer to this question should be answered in the same way as for the light at the front door, since the same words in the Code apply. We don't think a light on the inside of the door should be interpreted as the required lighting outlet. We do admit that the preposition "at" could have been applied on either side however, which is why we welcome the new words "exterior side of" before "outdoor entrances or exits" in the 1996 NEC.
The wall switch
The light must be controlled by a wall switch; however, the location of that switch isn't specified. Many proposals over the years have sought to require the switch to be at the entry door; however, these have always been rejected as design considerations. At present, if the designer wants to place the switch in a bedroom for security reasons, he or she may do so, although this would be unusual unless three-way switches were used to control the light from both the doorway and a remote location.
The other option is some kind of automatic control, as permitted in Sec. 210-70(a) Ex. 2: Photocells have been used for many years for this purpose. Often outside lights installed today have infrared proximity sensors in addition to photocells to save energy. That way they stay off during the day, and only light at night when someone approaches the doorway.
Note that these two options can also be used together. Often these sensors include a provision to stay on or off with a prescribed sequence of applying and removing power, and the wall switch is ideally suited for the purpose. Under any of the various alternatives, however, anyone using a doorway at night should be able to turn on a light, even if the doorway is at the bottom of a hatchway.
These answers are given by our panel of experts. I am chairing this panel, and the other panel members include Bill Summers, James Stallcup, and Dan Leaf. The opinion expressed is that of the panel. If a panelist disagrees with the majority opinion, his explanation is printed following the answer. Although authoritative, the answers printed here are not, and cannot be relied on as formal interpretations of the National Electrical Code.