Directional signage at truck loading docks

[Mr. Inspector]

RR's are required to be "accessible", including their doors!

The rest rooms are accessible and have an accessible route from the warehouse but not from grade where the trucks park. There is no accessible means of egress from these restrooms. The ware house was just built and this will be a tenant fit-out for it. Does that make the warehouse existing and no accessible egress is required?

 

[Mr. Inspector]

What is your opinion?

See attachment. The lot 5 fit-out has three truckers restrooms with no accessible egress from the truck parking at grade because of a stairway. I think that these entrances are intended primarily for delivery of goods or services because only the drivers that are delivering goods will be using these doors. Service doors for loading docks are not required to be an accessible entrance. There will be a vestibule at these two exterior dock doors with a door into the rest room and a 3rd door into the ware house. They plan to have a one-way lock on this warehouse door so you can get to the exit door and these restrooms from the warehouse but the truckers can’t get into the warehouse.

I'm worrying about the accessible means of egress from these restrooms. The rest rooms are accessible and have an accessible route from the warehouse but not back into the warehouse or from grade where the trucks park. There is no accessible means of egress from these restrooms because the exit door has a stairway and the door will be locked into the ware house. The ware house was just built and this will be a tenant fit-out for it. Does that make the warehouse is existing and no accessible egress is required for the tenant fit-out?

 

[Enri Code]

What is your opinion?

See attachment. The lot 5 fit-out has three truckers restrooms with no accessible egress from the truck parking at grade because of a stairway. I think that these entrances are intended primarily for delivery of goods or services because only the drivers that are delivering goods will be using these doors. Service doors for loading docks are not required to be an accessible entrance. There will be a vestibule at these two exterior dock doors with a door into the rest room and a 3rd door into the ware house. They plan to have a one-way lock on this warehouse door so you can get to the exit door and these restrooms from the warehouse but the truckers can’t get into the warehouse.

I'm worrying about the accessible means of egress from these restrooms. The rest rooms are accessible and have an accessible route from the warehouse but not back into the warehouse or from grade where the trucks park. There is no accessible means of egress from these restrooms because the exit door has a stairway and the door will be locked into the ware house. The ware house was just built and this will be a tenant fit-out for it. Does that make the warehouse is existing and no accessible egress is required for the tenant fit-out?


View attachment 6653

Certain situations can make it impossible to provide an accessible means of egress from building exits to a public way.

It's common to not allow the truckers access to the warehouse space so that's to be expected but it does create an issue.

Looks like that's the situation you have.

I understand that you're looking into at 1009.1 Exception #1 which says that accessible means of egress are not required to be provided in existing buildings. I'm not certain about that as well given that the warehouse was "just built". Depending on how long it had been built before the modifications would be done, I'm not certain that it applies.

I'll probably look at another part of the code that may allow this situation. The IBC permits an exterior area for assisted rescue, a protected area immediately outside a building exit, where a connecting accessible route to a public way from the level of exit discharge is not practical.

Look at 1009.7 Exterior areas for assisted rescue.

This would call for modification of the stair landing to fit the area of assisted rescue and having the immediate wall around the door to be 1 hour fire resistance rated (1008.7.2).

It won't allow a smooth way for someone in a wheelchair to exit out of the "driver's entry" but it will be to code...

 

[ADAguy]

The rest rooms are accessible and have an accessible route from the warehouse but not from grade where the trucks park. There is no accessible means of egress from these restrooms. The ware house was just built and this will be a tenant fit-out for it. Does that make the warehouse existing and no accessible egress is required?

It does not! Existing are bound by the barrier removal requirements of the ADA. T.I's are alterations and must comply with requirements for new construction. There are drivers with mobility limitations who need to pee too!

 

[steveray]

If a CO was issued for the warehouse...yes, it is existing....But the door/ exit probably should have been accessible anyway....I can see how they could get around it though and why I do not CO a shell anymore....

 

[Mr. Inspector]

It does not! Existing are bound by the barrier removal requirements of the ADA. T.I's are alterations and must comply with requirements for new construction. There are drivers with mobility limitations who need to pee too!

I am code plan reviewer and I am reviewing these plans to the 2015 IBC. I'm not legally allowed to looking at more than that.

If a CO was issued for the warehouse...yes, it is existing....But the door/ exit probably should have been accessible anyway....I can see how they could get around it though and why I do not CO a shell anymore....

Not sure how that can be done here legally. Here a CO must issued within 3 days after the final inspection passes and we must do the final inspection within 3 days when requested. Besides why would I care if they don't have an accessible egress for the tenant fit-out when the code does not require it (for existing buildings)? It's just one thing more that I don't need to deal with for a plan reviews and inspections.

 

[ADAguy]

May be so but the landlord is still bound to be code (and ADA) compliant,

 

[Mr. Inspector]

May be so but the landlord is still bound to be code (and ADA) compliant,

I'm interested and would like to know what ADA says about accessible egress for existing buildings. I thought the IBC was close in what the ADA requires.

 

[Enri Code]

I'm interested and would like to know what ADA says about accessible egress for existing buildings. I thought the IBC was close in what the ADA requires.

The IBC is close to ADA because it draws/ references from it but not in full though because ultimately, the ADA is an anti-discrimination law that not only deals with physical barriers but also other forms of discrimination.

I thought the above worth mentioning because I think that distinction is important because it sheds light on how they are similar but also different in the light of application. So a facility can definitely be code compliant but may not really meet the ADA requirements in full... and vice versa.

With regard to stairs being an egress path which would be the case here, they can still be ADA compliant in terms of handrails, guardrails and treads. ADA and IBC are aligned there.

I don't believe they necessarily need to be ramps or paired with ramps as long as an accessible entrance is already provided for elsewhere and signage is provided where applicable letting people know where the accessible entrance is.

They may most likely still need to have that exterior area for assisted rescue at least. That would be code compliant.

However, it won't be fully ADA compliant if you frame the situation in a way that in principle, by having the door back to the accessible path locked, you don't have a complete path without a change of elevation requiring a stair. If ADA is to be met fully, a ramp or a lift would be needed.

That's when it gets messy because in general, with regard to existing facilities... the ADA does dictate that architectural barriers be removed in existing facilities... "when readily achievable".

That phrase "when readily achievable" is definitely a can of worms best opened with a can opener... held by a lawyer.

Who makes the determination of what is readily achievable? You? Them? Uncle Sam? Do you even need to worry about ADA if it already is demonstrably code compliant? Shouldn't ADA then be owner's or tenant's to deal with either now or if faced with a civil suit down the road?

Most likely, owner will bear the burden of proof with regard to if something is readily achievable if challenged in the legal sense.

I'm not sure what the scope of your code plan review is but you may just want to inform the owner of possible issues as a commentary that they need to address without actually prescribing a remedy if that's a liability concern for you.

 

[ADAguy]

I'm interested and would like to know what ADA says about accessible egress for existing buildings. I thought the IBC was close in what the ADA requires.

cLOSE BUT NO CIGAR (SMILING) eXISTING barriers must be removed and maintained. You must be able to enter and exit to a public way or area of refuge.

Have you read the 2010 ADASAD? ICC uses the chapter numbers but is not always in step with its minimums. Yes, in some instances they excedd but not in all.