Egress and Accessibility in Existing Buildings

[arwat23]

Recently got a comment from an inspector that I'm struggling to rationalize fully. I'm probably reading too much into it, but I'm hoping you fine folks can help clarify the requirements they're referencing.

2022 California Building Code. Project is an existing commercial building. Permit was issued before the California Existing Building Code got major alterations, so that code isn't very applicable here.

There's an existing exterior door we're planning on using as the accessible entry (CBC 11B-202.4). I'm being told that, due to CBC 1010.1.4 and 11B-404.2.4, we need a level landing (<2% slope) on the interior side of the door. All well and fine, but the part I'm confused about is 11B-404.2.4 in regards to the interior side of an entry door.

The issue is not about egress according to the inspector. The issue is about the path of travel to the space. They're saying that the maneuvering clearance required by Table 11B-404.2.4.1 is required on both sides of the door when entering a space. If maneuvering clearances are required, then a <2% slope is required within that maneuvering clearance (11B-404.2.4.4). Essentially, they're asking for the push and pull side maneuvering clearance when the approach is only from the pull side (exterior side).

I thought that the maneuvering clearances only apply on the approach side. I completely understand that most doors have maneuvering clearances on both sides since most doors can be operated from both sides, but that's apparently not the concern that triggered this comment.

They're adamant on this, which makes me think I'm simply missing something or interpreting code wrong.

I have no complaints about fixing the issue. I'd prefer it fixed anyways. I more just interested in how these sections of code apply to this situation, because I'm reading code differently than the inspector.

Also, 11B-207.1, exception 3 says that accessible means of egress are not required in existing buildings. Would an existing building undergoing an interior alteration with no new exterior doors meet this exception? Inspector says this is no longer an existing building, so I'm hoping to get some clarity on that too.

 

[luckyyiu]

CBC CHAPTER 2 DENFINITION
BUILDING, EXISTING. [HCD 1 & HCD 2] A building erected prior to the adoption of this code, or one for which a legal building permit has been issued.

undergoing an interior alteration is no longer an existing building, because you need to have a legal building permit.

building use, occupant counts and a lot of things may have changed base on your interior alteration.

 

[arwat23]

CBC CHAPTER 2 DENFINITION
BUILDING, EXISTING. [HCD 1 & HCD 2] A building erected prior to the adoption of this code, or one for which a legal building permit has been issued.

undergoing an interior alteration is no longer an existing building, because you need to have a legal building permit.

building use, occupant counts and a lot of things may have changed base on your interior alteration.

Okay, makes sense. Thanks!

What about my other questions?

 

[arwat23]

CBC CHAPTER 2 DENFINITION
BUILDING, EXISTING. [HCD 1 & HCD 2] A building erected prior to the adoption of this code, or one for which a legal building permit has been issued.

undergoing an interior alteration is no longer an existing building, because you need to have a legal building permit.

building use, occupant counts and a lot of things may have changed base on your interior alteration.

Actually, wait... When would that exception apply then? If a new building permit negates that exception, would it ever be applicable for interior alterations?

 

[steveray]

How do you have an interior floor steeper that 2%?

 

[arwat23]

How do you have an interior floor steeper that 2%?

Existing conditions are wack. Looks like someone added a door at some point, probably without a permit (lots of unpermitted work in this building).

 

[JPohling]

So it is intended as the accessible entry door but not an exit door in any way? That is unusual.
Remove the door hardware from the interior and you should be good. I do not believe the maneuvering clearances or level landings are required from the side that you are not approaching or operating the door from. Per 404.2.4.1

 

[arwat23]

So it is intended as the accessible entry door but not an exit door in any way? That is unusual.
Remove the door hardware from the interior and you should be good. I do not believe the maneuvering clearances or level landings are required from the side that you are not approaching or operating the door from. Per 404.2.4.1

That's the thing. It IS (or at least can be used as) an egress door, but the comment we received is specifically about path of travel to the area of work (not egress). The inspector said this isn't an egress issue (which confused me because they referenced Ch 10).

I was told very explicitly that because you need to access the space, you need the maneuvering clearance on both sides regardless of if you can't use the door from the other side. It sounds like the inspector is just wrong or not explaining this well (?)

Here's the comment I got:

11B-207.1, Exception 3 does not apply as this is no longer considered an “existing building” as it is being altered, and is not considered egress. This is an accessible entrance, where it’s requirements are described in 11B-202.1 through 11B-202.3. Accessible entrances are continuously listed as the primary required element within the path of travel requirements.

The "entrance", as defined, complies with accessibility requirements. You can get into the space. It's only when you try to leave the space through that entrance when issues arise.

I apply Section 1010.1.4 of the 2022 CBC as a starting point for all doors, then I apply Section 11B-404.2.4 and Table 11B-404.2.4.1 for compliance with the ADA. Front approach is the approach, exterior and interior.

I know I'm splitting hairs here. I get it. I'm just trying to make sure I'm not missing something.

 

[redeyedfly]

The "entrance", as defined, complies with accessibility requirements. You can get into the space. It's only when you try to leave the space through that entrance when issues arise.


I know I'm splitting hairs here. I get it. I'm just trying to make sure I'm not missing something.

Stop, take a breath, and think about what you're trying to argue. It's a door in the code, no one cares about the word "entrance". Accessibility aside, you need a level landing on either side of every door (1 exception for top of stairs).

In a word, your argument is ridiculous.

 

[arwat23]

Stop, take a breath, and think about what you're trying to argue. It's a door in the code, no one cares about the word "entrance". Accessibility aside, you need a level landing on either side of every door (1 exception for top of stairs).

In a word, your argument is ridiculous.

"Entrance" is defined in our code, so the state seems to care about the word. DSA be like that I guess...

ENTRANCE. Any access point to a building or portion of a building or facility used for the purpose of entering. An entrance includes the approach walk, the vertical access leading to the entrance platform, the entrance platform itself, vestibule if provided, the entry door or gate, and the hardware of the entry door or gate.

I never said my argument wasn't probably a tinsy bit cracked. I know it probably is. Hell, it's probably unhinged and unnecessary. However, I got a stick up my butt about the language in code and no amount of breathing or Xanax will dislodge it. Trust me, I've tried.

Like I said, I honestly don't care if we need to fix the issue. I'd rather it be fixed. Less chance of a lawsuit for my client. I'm just unnecessarily anal about the language of code.

 

[redeyedfly]

"Entrance" is defined in our code, so the state seems to care about the word. DSA be like that I guess...



I never said my argument wasn't probably a tinsy bit cracked. I know it probably is. Hell, it's probably unhinged and unnecessary. However, I got a stick up my butt about the language in code and no amount of breathing or Xanax will dislodge it. Trust me, I've tried.

Like I said, I honestly don't care if we need to fix the issue. I'd rather it be fixed. Less chance of a lawsuit for my client. I'm just unnecessarily anal about the language of code.

Just because entrance is defined does not mean it applies to your question.

You're seriously arguing the building only needs to be accessible to enter, not exit. Wow!

 

[arwat23]

You're seriously arguing the building only needs to be accessible to enter, not exit. Wow!

Like I said, unhinged. Also 11B-207.1, exception 3 (which I think I just misinterpreted - still looking for clarity on when this exception applies):

11B-207.1 General​

Means of egress shall comply with Chapter 10, Section 1009 and Section 11B-207.
Exceptions:
3. Accessible means of egress are not required to be provided in existing buildings.

Edit: Also, no, I'm not arguing anything. I'm trying to understand where the requirement comes from. That's all.

My previous post seems to have replies saying an accessible means of egress wouldn't be required: https://www.thebuildingcodeforum.co...ans-of-egress-for-an-existing-building.35622/

 

[arwat23]

Just because entrance is defined does not mean it applies to your question.

The inspector said it was only an ingress issue, not an egress issue. They reference the maneuvering clearance, which shouldn't apply to the opposite side of the door. The inspector referenced the definition of entrance, so I did to.

I'm not trying to argue anything. I'm trying to understand what I'm missing in code, because clearly I'm missing something.

 

[steveray]

If I was the inspector, I would send the owner the violation for installing the door without a permit....Shirley that will get things fixed...

 

[Mr. Inspector]

The IEBC also does not require accessible egress in an existing building. I would not require the maneuvering space on the inside of the door unless it was a new door. Also, I would require a lever door handle on the outside but not on the inside.

 

[Ana]

In IEBC- if the renovation is Alteration level 1 or 2 you can use the provisions of IEBC, but if alteration level 3 which is alteration to more than 50% of the building, then it's not an existing building anymore. You'll have to treat it as a new building with all the requirements that apply to IBC including egress, accessibility, etc.. All doors will have to have the maneuvering clearance requirements for egress on both sides whether they are accessible or not accessible.

 

[steveray]

but if alteration level 3 which is alteration to more than 50% of the building, then it's not an existing building anymore. You'll have to treat it as a new building with all the requirements that apply to IBC including egress, accessibility, etc..

Incorrect....At least in my world...

 

[Ana]

Incorrect....At least in my world...

Can you explain how it's incorrect in your world? which part is incorrect? In my world- I learned from different code discussions with building officials, that almost everything will need to comply with IBC if a building goes under alteration level 3- The only thing that may not be much affected is the existing structural components because they're already built.
That's my understanding.

 

[steveray]

Can you explain how it's incorrect in your world? which part is incorrect? In my world- I learned from different code discussions with building officials, that almost everything will need to comply with IBC if a building goes under alteration level 3- The only thing that may not be much affected is the existing structural components because they're already built.
That's my understanding.

Do you have a code section? There is nothing in Level 3 that requires you to update the whole building for energy for instance...

907.1​

Level 3 alterations to existing buildings or structures are permitted without requiring the entire building or structure to comply with the energy requirements of the International Energy Conservation Code or International Residential Code. The alterations shall conform to the energy requirements of the International Energy Conservation Code or International Residential Code as they relate to new construction only.

 

[Yikes]

Just because entrance is defined does not mean it applies to your question.

You're seriously arguing the building only needs to be accessible to enter, not exit. Wow!

There are many existing buildings that are required by code to be accessible to enter but not required to be accessible to exit. For example, many existing buildings with upper floors served by elevators are not required to have emergency / standby power for the elevator, and are not required to have an area of refuge or other AMOE features. In event of emergency and either power loss or an elevator recall to the first floor, a person on an upper floor who is incapable of using the stairs must wait for rescue.

 

[steveray]

And for the record and to keep this OT.....I think only the outside of the door/ accessible route is in play....IF the door is legal to begin with....

 

[Ana]

Do you have a code section? There is nothing in Level 3 that requires you to update the whole building for energy for instance...

907.1​

Level 3 alterations to existing buildings or structures are permitted without requiring the entire building or structure to comply with the energy requirements of the International Energy Conservation Code or International Residential Code. The alterations shall conform to the energy requirements of the International Energy Conservation Code or International Residential Code as they relate to new construction only.

I don't have a one specific code section that clearly indicates what I said. It's just that I've had many discussions with building officials and was told that we have to comply with chapter 10 and also lighting, hvac etc.. when we go under alteration level 3. It makes sense to me as it improves the safety in the existing building. I understand sometimes it's physically infeasible to bring the existing building components up to current code (like in existing stairs for example), but the goal is to improve the existing building safety as much as possible. Also I'm not sure if the compliance method would affect that or not- I've always used the work area compliance method.
The section you're referring to is for the energy code-mainly building envelope- Only the modified areas shall comply with the new energy code, but as far as I know-all lighting, HVAC etc will need to comply with the new energy code.

Anyway, it seems this subject has always been a subject of discussion- I just saw other posts in this forum regarding that. I'll go through them all later. Here's one of the posts I just saw:

M

Thread 'IEBC - 50% of Building renovated'

Feb 2, 2024

I hope this is in the correct forum

I need some opinions on this question. My partner and I, both architects, are assessing a rehabilitation project and have a difference of opinion regarding its classification under the IEBC, specifically the definition stipulating "50% of the building to be renovated."

Here is a brief project overview: The building, constructed in 1978, is a three-story structure comprising 60 apartments, offices, and common spaces. Since its construction, it has undergone only routine maintenance and lacks a major renovation. The budget for the project is $5 million...

• Mslacat
• Replies: 20
• Forum: Commercial Building Codes

 

[arwat23]

IEBC / CEBC doesn't really apply here. CA hardly adopted that code until recently. Even now, our adoption is limited. Most things regarding existing buildings is in our Building Code.

 

[Yikes]

arwat23, I may sound crazy, but I'm inclined to agree with you that 11B-202.4 requires a path of travel "to" the space, not "to and from" the space.

However, I would also note that you have not described the nature of the alteration. Are you planning on altering the existing exterior entry door itslef?
11B-202.3 states that any existing element that gets altered must comply with the scoping of division 2.
So if the door currently functions as both an entry and a Chapter 10-required exit (user passage from the interior to the exterior), AND you are altering the door itself, perhaps 11B-206.5.2 would trigger compliance in direction of exit travel (as well as entry travel).
If you are not altering the door itself, then per the limitations in 202.4 maybe an accessible landing on the interior side is not required.