Accessibility Advisory 202.4 Alterations Affecting Primary Function Areas.

[Mr. Inspector]

My understanding is that it should be. The first thing that comes to my mind is in the 2010 ADAS (I'm assuming this is in IEBC / IBC somewhere too since ADAS has this).

206.2.1 Site Arrival Points. At least one accessible route shall be provided within the site from accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; and public transportation stops to the accessible building or facility entrance they serve.

EXCEPTIONS:

1. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, no more than one accessible route from a site arrival point to an accessible entrance shall be required.
2. An accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing pedestrian access.

Edit: Or maybe I'm getting my California amendments mixed up with what's required by ADAS...

It says accessible route from accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; public transportation stops. It doesn't say that accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; public transportation stops need to be accessible. For instance, How would you make them make a sloped bumpy public street accessible. I think it just means from the public street and these other things.
Comments?

 

[Sifu]

I am encouraged to see that there are AHJ's with an actual form for this issue. So many AHJ's barely know how to administer the IEBC, and so few DP's have ever opened it, but to be fair, it has it's challenges. It is ironic that many (DP's, and code officials) complained when there was no code to help with existing buildings, yet they continue to ignore the IEBC's existence.

When I encounter this my first comment is to provide the accessible route. Upon resubmittal, when they don't address it, or claim they are exempt because they aren't "touching" it, I make the comment again. Then they inevitably complain, usually to the CBO or even higher up the food chain. Then I get to explain what the IEBC is and how it works. At that point I advise them there are exceptions they can take advantage of...like the 20% cap, as identified in the section of the IEBC I referenced in my comment. That is where the math gets fuzzy. I can barely get BO's and permit techs to ask for valuation, much less discern what it should include. Without some sort of policy, form or process I simply ask them to demonstrate the 20%.

I have a T/I-Change of Occupancy right now. It is an old, typical downtown space, originally constructed with a step at the front door, like so many are. Not a huge, expensive project. The plans show a ramp, interior to the front door, no details, just a down arrow indicating a small ramp, no landing at the bottom. After some research I find that at some point in the past (years ago), the AHJ went through the town and asked everyone to do this (I suspect it was not the building department). Suffice it to say this condition has been ignored for a long time, probably in most of the other similar spaces in the same downtown area. So here we are today, with a change of occupancy. They must add a fixture, so they are adding another accessible toilet room. That likely gets them the 20% the IEBC would require, but I must ask them to demonstrate it. Smoke will pour out of their ears.

 

[Yankee Chronicler]

I would like to discuss if a parking space is part of an accessible route and should be on this list or not.

I like a couple of those forms and, after shamelessly stealing them, I'll sit down with the boss and see if we want to steal the best parts of all and incorporate them into a form for our use.

As to accessible parking: Yes it should be on the list, but not as part of the accessible route. The accessible route connects the accessible parking (or site arrival point) to the accessible primary function area. The accessible parking space is the starting point, the accessible primary function area is the end point. Everything in between (including the toilet rooms and drinking fountains serving the accessible primary function area) constitutes the accessible route.

As to the priorities not being in the code -- they're not. But the concept has been around for a long time. I have heard it somewhat crudely expressed as:

1. Get them to the building
2. Get them into the building
3. Get them through the building
4. Give 'em a place to pee.

The Access Board may have issued that as guidance somewhere along the way. I'm not sure, but it had to have come from somewhere.

 

[Mr. Inspector]

As to accessible parking: Yes it should be on the list, but not as part of the accessible route. The accessible route connects the accessible parking (or site arrival point) to the accessible primary function area. The accessible parking space is the starting point, the accessible primary function area is the end point. Everything in between (including the toilet rooms and drinking fountains serving the accessible primary function area) constitutes the accessible route.

like you said it is not on the list. Some of the existing places would need to do major work to make an accessible parking space level in this hilly area.

If an accessible parking space is not available, the accessible route cannot start there. Also, if there is a parking space that has anything missing that the code requires for an accessible parking space, but it almost does, it is not an accessible parking space by definition. It is only required for a "complete change of occupancy" and plainly stated in 2018 IEBC 305.4.2 without an 20% exception or unless technically infeasible. It is not mentioned under 305.6 'Alterations" or 305.7 "Alterations affecting an area containing a primary function" or "partial change of occupancy", which would make me (and should for anyone else) believe it is only required for a "complete change of occupancy".
So, if there is no accessible parking the accessible route will still need to start from public transportation stopes, accessible loading zones and public sidewalks or streets.

Most of the existing building that I get that are doing alterations or/and a change of occupancy are just tenant spaces that are just part of a building, like a strip mall or office building, so in all my years of an inspector never got a "complete change of occupancy" to require any accessible parking.
.

 

[steveray]

Not so fast:

206.2.1 Site Arrival Points. At least one accessible route shall be provided within the site from accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; and public transportation stops to the accessible building or facility entrance they serve.

 

[Yankee Chronicler]

Most of the existing building that I get that are doing alterations or/and a change of occupancy are just tenant spaces that are just part of a building, like a strip mall or office building, so in all my years of an inspector never got a "complete change of occupancy" to require any accessible parking.
.

We see a tremendous number of tenant fit-outs in existing buildings. We require accessible parking -- subject to the 20% limitation in the IEBC. Section 306 applies to all work in existing buildings, not only to changes of occupancy. IEBC 306.2 says:

306.2 Design. Buildings and facilities shall be designed and
constructed to be accessible in accordance with this code and
the alteration and existing building provisions in ICC
A117.1, as applicable.

So IEBC 306.2 brings in ICC/ANSI A117.1. A117.1 addresses accessible parking.

 

[Mr. Inspector]

I guess you are working with a different year IEBC than I am. The 2018 does not have any 306 sections.
Also the ICC/ANSI 117.1- 2006 we use does not have any thing about accessible parking in the Chapter 4 "Accessible Routes". Accessible parking is in Chapter 5.

 

[arwat23]

It says accessible route from accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; public transportation stops. It doesn't say that accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; public transportation stops need to be accessible. For instance, How would you make them make a sloped bumpy public street accessible. I think it just means from the public street and these other things.
Comments?

Yeah, I messed up on that one. CA has language specific to making existing non-complaint parking spaces accessible in 11B-202.4, exception 8. Other states / ADAS / A117.1 don't have that language as far as I see. I was getting things mixed up in my head. My bad.

 

[Yankee Chronicler]

I guess you are working with a different year IEBC than I am. The 2018 does not have any 306 sections.
Also the ICC/ANSI 117.1- 2006 we use does not have any thing about accessible parking in the Chapter 4 "Accessible Routes". Accessible parking is in Chapter 5.

Sorry -- we're on amended versions of the 2021 ICC codes and the 2017 A117.1

 

[Yankee Chronicler]

Hmmm ... Section 306 in the 2021 IEBC was section 305 in the 2018 IEBC, and indeed there is nothing corresponding to the 2021 306.2 (Accessibility) in the 2018 IEBC.

 

[Sifu]

2018 IEBC 305.7 says "where an alteration affects the accessibility to, or contains an area of primary function, the route to...." I have understood this to mean that if they are altering the area of primary function they must work on the route to it, unless one of the exception apply. I have an area of primary function that is being altered, with a change of use. The entry door is not accessible. The applicant is arguing that since they are not altering the entry door, they don't need to improve it. I see both 305.6 and 305.7 as applicable to this situation. Agree or disagree?

 

[Yankee Chronicler]

I have been called out on multiple projects for not showing the existing conditions of a space, specifically for the restrooms. Since then, we've made it a point to measure the existing conditions of the restrooms thoroughly and draw them on our plans.

Recently, a jurisdiction we typically work in hired a new senior plans examiner who is really, really strict and wants a ton of accessibility details for all existing conditions (not just a note). It's been a bit of a headache, but now we throw a ton of standard ADA details on a sheet and just reference those for existing conditions. For example, when we show the path of travel from the parking to the main building entry, we note how wide the path is, how it meets the "changes in level" requirements (referencing a standard detail), how it meets requirements for ground surfaces, how there's no openings in the path of travel (and if there are openings, we reference a standard detail)... etc. Anything new or altered we use unique details specific to the building obviously. The only existing room we detail out, even if it's outside our scope of work, is the restrooms.

It's more work, but it's better than being called out and delaying a project by weeks / months.

I hate it when architects include a sheet (or multiple sheets) that do nothing more than reproduce the diagrams out of the ADAS or A117.1. It's even more annoying when the actual plans for the project then DON'T agree with the standard details. If I had my druthers, I'd like to be able to reject any set of construction documents that includes a sheet showing standard A117.1 accessibility details. The contractors NEVER look at that sheet -- they know it's just there for eyewash.

 

[Yankee Chronicler]

2018 IEBC 305.7 says "where an alteration affects the accessibility to, or contains an area of primary function, the route to...." I have understood this to mean that if they are altering the area of primary function they must work on the route to it, unless one of the exception apply. I have an area of primary function that is being altered, with a change of use. The entry door is not accessible. The applicant is arguing that since they are not altering the entry door, they don't need to improve it. I see both 305.6 and 305.7 as applicable to this situation. Agree or disagree?

Unless they can satisfy the 20% elsewhere, the entry door should be made accessible.

This is not new. In the 2015 IEBC it was in section 410.7. Same requirement, same exceptions, same 20% exemption.

 

[steveray]

2018 IEBC 305.7 says "where an alteration affects the accessibility to, or contains an area of primary function, the route to...." I have understood this to mean that if they are altering the area of primary function they must work on the route to it, unless one of the exception apply. I have an area of primary function that is being altered, with a change of use. The entry door is not accessible. The applicant is arguing that since they are not altering the entry door, they don't need to improve it. I see both 305.6 and 305.7 as applicable to this situation. Agree or disagree?

If you want to get crazy with commentary:

 

[Sifu]

I hate it when architects include a sheet (or multiple sheets) that do nothing more than reproduce the diagrams out of the ADAS or A117.1. It's even more annoying when the actual plans for the project then DON'T agree with the standard details. If I had my druthers, I'd like to be able to reject any set of construction documents that includes a sheet showing standard A117.1 accessibility details. The contractors NEVER look at that sheet -- they know it's just there for eyewash.

Almost every plan set I get has this. I can't figure out where they get the details though because most of the time there are details that don't meet either ANSI or ADA. Minor stuff, but annoying.

 

[steveray]

The contractors NEVER look at that sheet

You can lead a horse to water, but it is hard to hold his head under until the bubbles stop....

 

[Mr. Inspector]

If they are doing any alterations at all, not just to the entry door, they will need to spend at least 20%.

305.4.1 Partial change of occupancy. Where a portion of
the building is changed to a new occupancy classification,
any alterations shall comply with Sections 305.6, 305.7
and 305.8.

[A] ALTERATION. Any construction or renovation to an
existing structure other than a repair or addition.

If the cost of the job is $0 nothing towards accessibility needs to be done.

 

[Sifu]

In the current plan I am working on, there is a front entry door, recessed into an alcove. The recess has an angled wall. I asked for them to provide the required access in accordance with 305.7, since the renovation includes an area of primary function. They are adding accessible toilet rooms, and I think they can demonstrate the 20%. Instead, they have provided an argument that 1) It isn't required since they are not altering the door itself, 2) Code doesn't address an angled wall, 3) The angled wall, in their opinion is more accessible than a the required front approach with the clear space beyond the latch of the door.

Per usual, the original plan did not reference the IEBC. Maybe I forced them to buy the book.

I pointed out the 20% limitation. We'll see what happens.

 

[Yankee Chronicler]

In the current plan I am working on, there is a front entry door, recessed into an alcove. The recess has an angled wall. I asked for them to provide the required access in accordance with 305.7, since the renovation includes an area of primary function. They are adding accessible toilet rooms, and I think they can demonstrate the 20%. Instead, they have provided an argument that 1) It isn't required since they are not altering the door itself, 2) Code doesn't address an angled wall, 3) The angled wall, in their opinion is more accessible than a the required front approach with the clear space beyond the latch of the door.

Per usual, the original plan did not reference the IEBC. Maybe I forced them to buy the book.

I pointed out the 20% limitation. We'll see what happens.

I would have rejected the plans based on the lack of mention of the IEBC. In a jurisdiction that adopts the IEBC, unless the adoption significantly changes the language, the IEBC is the starting point for ALL work in existing buildings: repairs, alterations, additions, and changes of use. Yes, the architerct should buy the book, but they can always roll the dice and use UpCodes (and hope UpCodes didn't mess up any of the sections that apply to their project).

Their argument #1 is clearly wrong, since it affects the accessible route to the altered area containing a primary function.

Argument #2 is just wrong. The maneuvering clearances for doors are pretty much the same in both A117.1 and the ADA technical standards. If an angled wall intrudes on the required clear maneuvering space -- it's addressed by the standards saying it can't be there.

Argument #3 seems just silly.

 

[Sifu]

I try not to reject and not review anything, I would rather include that as a comment then give as much review as possible to avoid repeating the same unrelated mistakes on the next review. It is really just a way for me to manage the workload for myself. In this case, there was a lot missing, so I made the comments about that, then reviewed what I could. There were lots of comments, this is the only one they could pick out and dispute I guess. They have some leeway if they will just read the code a little closer. They actually quoted 305.7 in the argument, but (strategically?) left out the sentence "or contains an area of primary function". I pointed that out for them.

 

[Yankee Chronicler]

They have some leeway if they will just read the code a little closer. They actually quoted 305.7 in the argument, but (strategically?) left out the sentence "or contains an area of primary function". I pointed that out for them.

Ah, yes ... the old selective citation trick. I love it [not] when they try that. Do they think that I don't have a copy of the code section I dinged them on?

We got that "but it's existing so I don't have to do anything" argument just a few days ago. Apparently reading (or reading comprehension) is a lost art among architects.