Author(s): Kristin Bigda. Published on July 1, 2019.

In Compliance | NFPA 101

Protecting escape rooms and other special amusement buildings


Escape rooms are a booming part of the worldwide amusements industry. The objective of an escape room is to solve puzzles and challenges, usually as a team, in order to ‘escape’ the room. The irony of these amusements is that, as part of the thrill, they capitalize on a concept that goes against a fundamental principle of the Life Safety Code®—you can’t leave the room or game space until you’ve solved the puzzle or until time runs out.

The fire safety implications of escape rooms are obvious to those of us intimate with fire and life safety: countless people have lost their lives in fires because they were locked in a building or their means of egress was otherwise compromised and out of their control. The safety implications for escape rooms were made real in January, when five teenage girls died in a fire involving an escape room amusement in Poland.

In this episode of Learn Something New by NFPA Journal®, we learn what special amusement buildings are and some of the ways the code works to protect them from fire and other life safety hazards.

Because of their potential risks and growing popularity—both of which are examined in detail in this issue's article, “Safe Escape,” the topic of escape rooms has attracted the attention of NFPA’s Technical Committee on Assembly Occupancies. A task group was established at the end of the 2018 revision cycle to determine whether escape rooms require special attention in NFPA 101®, Life Safety Code®. The task group report was presented to the committee at the First Draft meeting last summer, and recommended code language was incorporated via first revisions. The task group’s scope was expanded to study all special amusement building criteria (not limited to escape rooms), and the group will continue its work through the Second Draft.

NFPA staff receive and respond to code interpretation questions through our Technical Questions Service, a number of which have related to AHJs needing a better understanding of how to classify the occupancy for these types of facilities. For the purpose of determining occupant load, one might enforce the assembly use factor (less concentrated, see Table, but, based on the size of the space and the calculation results, they would not be considered an assembly occupancy unless the occupant load exceeded 49, based on the NFPA 101 definition of “assembly occupancy.” My understanding of these facilities is that many would not result in that high an occupant load due to their size, so the first condition set forth in the assembly occupancy definition would not kick in.

The second condition warranting classification as an assembly occupancy is any occupancy used as a special amusement building, regardless of occupant load. A special amusement building is one that is temporary, permanent, or mobile, and contains a device or system that conveys passengers or provides a walkway along, around, or over a course in any direction as a form of amusement arranged so that the egress path is not readily apparent due to visual or audio distractions or an intentionally confounded egress path, or is not readily available due to the mode of conveyance through the building or structure.

The first draft of the 2021 edition of NFPA 101 extends the use of special amusement to include entertainment or educational purposes in its definition. In addition to the small revision in the definition of special amusement buildings, valuable information has been added to the annex section accompanying the definition to provide additional examples and considerations to help enforcers determine applicability of the special amusement definition.

Typical examples of special amusement buildings include haunted houses. Participants weave through a path not readily obvious, accompanied by low lighting, special effects, and other visual distractions. Per the new advisory text, other occupancies, including escape rooms, might also fall into the classification of special amusement building if the conditions described in the definition exist. It is incumbent on the local AHJ to inquire if the conditions in the escape room meet the definition of a special amusement building. Where such conditions exist, escape rooms should be classified as special amusement buildings and require compliance with NFPA 101. Where such conditions do not exist, escape rooms might be classified as another occupancy type, such as business.

It is also important for an AHJ to recognize that the code requires an occupancy to be classified as a special amusement building if the conditions in the space meet the definition of special amusement building, regardless of the occupant load of the space. No minimum occupant load threshold needs to be met for a space to be classified as a special amusement building.

I have been to an escape room and had a great experience. I don’t believe it was a special amusement building, as the egress path wasn’t confounded and lighting levels at the egress paths were not reduced. It was relatively small, with an occupant load of probably fewer than 50 persons, which would most likely make it a business occupancy. It posed no unusual life safety hazard, and I felt safe the entire time. My team of four people was briefed, in great detail, on the safety provisions of the facility, the details of the room we would be in, and the rules of the game. When our briefing was complete, I asked the room leader if the doors were really locked. To my relief, the answer was “no.” If needed, I could have left at any time. The catch was that if anyone opened the door, the game was over—a small price to pay for safety, in my opinion. There was no need to do so: we beat the game, solved the puzzle, and were able to egress the room safely, and with no penalty.

To follow the work of the Technical Committee on Assembly Occupancies and the escape room task group, visit

KRISTIN BIGDA is a principal fire protection engineer at NFPA.