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Door Maneuvering Clearance at Storage Room Door

P

Phil B

SAWHORSE
Joined
Sep 15, 2018
Messages
223
Location
Florida
I have a storage area that is less than 300' but not elevated. The width of the room does not allow the required maneuvering clearances. The door needs to swing in. My interpretation of the code section below is that IF the floor in this room is elevated at least 7", then the door maneuvering clearances would not be required. Does anyone interpret this differently? Is there an exception I am missing that would allow the door as shown if the floor was not raised?

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If you are using the exception for 7"+ elevation change, it must be related to the function of the space. I've typically seen this at walk-in refrigerator/freezer units, or at coved / curbed floors that are meant to contain materials, or contain the spills of materials.
 
Yikes said:
If you are using the exception for 7"+ elevation change, it must be related to the function of the space. I've typically seen this at walk-in refrigerator/freezer units, or at coved / curbed floors that are meant to contain materials, or contain the spills of materials.
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So if the space does not need to be elevated, doing so to get the exception is not allowed, or at least may be frowned upon?
 
Phil B said:
So if the space does not need to be elevated, doing so to get the exception is not allowed, or at least may be frowned upon?
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If a building official asked you how the change in elevation is essential to the function of the 300 SF storage room, what would you say in response?


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As Yikes has pointed out, you are trying to ignore the "... where the elevation is essential to the function of the space ..." part. It's almost like the authors of the 2010 ADAS predicted that people would try to use this as a way to avoid providing accessibility, and the intent of the ADA (and the ADAS) is to maximize accessibility within a consensus of what's "reasonable."

The following appears as an advisory to section 203.9 in the 2010 ADAS:

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If the Access Board is pushing people to design for accessibility even where it's not strictly required, it's a safe bet that the intention wasn't to allow arbitrary raised floor areas as a way to escape providing access.
 
It's a storage closet. Why do you need the door to be automatic?

Does the door need to remain closed except when someone is entering the closet? Can you use an overhead (or side) coiling door?
 
Phil B said:
I have a storage area that is less than 300' but not elevated. The width of the room does not allow the required maneuvering clearances. The door needs to swing in. My interpretation of the code section below is that IF the floor in this room is elevated at least 7", then the door maneuvering clearances would not be required. Does anyone interpret this differently? Is there an exception I am missing that would allow the door as shown if the floor was not raised?

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Hi Phil, you call the area a storage area. The key distinction I think is "where the elevation is essential to the function of the space". What is the function for storage that raising it would be essential to the function? I must be missing something. I think you will need to comply with 206.2.8 common use circulation path, 207.1 Accessible means of egress, 215.3 visible and audible alarms, and 811 clear floor space, reach range, and operable parts. Jean T
 
Yankee Chronicler said:
It's a storage closet. Why do you need the door to be automatic?

Does the door need to remain closed except when someone is entering the closet? Can you use an overhead (or side) coiling door?
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The door to the room will remain locked when not in use. It will be a liquor storage room in a restaurant and have windows on the side walls if that makes any difference.

I was looking at automatic doors because FBCA 2023 1010.1.2 appears to exempt this size room from having to have a swinging door, and 1010.3.3 requires them to be power operated. Am I reading it correctly?

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Jean Tessmer-HI said:
Hi Phil, you call the area a storage area. The key distinction I think is "where the elevation is essential to the function of the space". What is the function for storage that raising it would be essential to the function? I must be missing something. I think you will need to comply with 206.2.8 common use circulation path, 207.1 Accessible means of egress, 215.3 visible and audible alarms, and 811 clear floor space, reach range, and operable parts. Jean T
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I am backing off raising the floor. Also please see my response to Yankee Chronicler.

How about this: FBCA 2023 206.2.8 excludes compliance to 402 which includes doorways, for employee work areas under 1,000 sf. This space is defined by walls (partitions?) on all sides and counters and casework for storage. That would mean the maneuvering clearances don;t need to be met? Thank you! Phil

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The exception to 206.2.8 applies within the employee work area, not into the employee work area. The theory is to make all spaces accessible for ingress and egress, and then leave accommodation for whatever a particular employee might need (such as perhaps a special desk) to be resolved on a case-by-case basis.
 
You highlighted an exemption including "very narrow passageways," yet you acknowledge that you would hesitate to call your wine closet a passageway.

I think you answered your own question, but lets examine that second exemption more closely:

"spaces accessed only by ladders, catwalks, crawl spaces, or very narrow passageways." The wine closet isn't the access path -- it's the destination space. I understand that you have a vested interest in justifying your design. To do that, I believe it's important to analyze it properly. The wine closet is not the circulation path -- it's the employee work area (i.e. the destination space). The circulation path is how employees get into and out of the space -- the doorway.

I generally suggest to designers that they think of themselves as "the temporarily able-bodied" when asking questions about accessibility. The ADA doesn't just apply to long-term disabilities, it also applies to people with short term impairments, such as while recovering from surgery or from injuries. For a restaurant, you can argue that a waiter/waitress/server wouldn't be able to work if they were in a cast or in a wheelchair -- but what about a manager or shift supervisor? Certainly a supervisor, who doesn't routinely carry around trays laden with dinners, can perform their supervisory duties even from a wheelchair -- and might need access to the liquor closet to check inventory.

But -- if you equate the liquor closet to a private office, as long as the person can get in and out, they can perform their job. The doorway is the stumbling block. I don't think you are correct about 1010.3.3. That's for special purpose doors. What is there about this door that makes it "special purpose"? I have seen any number of medical suites recently that use a sliding "barn" door at the staff break room. The code section you need to look at is 1010..1.2, Exception #1. It's a storage room, and the occupant load is less than 10. Therefore, the door does not have to be a side-hinged, swinging door. Exception #9 specifically states:

9. In other than Group H occupancies, manually operated horizontal sliding doors are permitted in a means of egress from spaces with an occupant load of 10 or less.
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So you can use a pair of bi-parting pocket doors -- if you can find hardware that will lock them together when closed.
 
I've always run the wall shelving short on latch side because of these clearances, as it is typically on the accessible: AHJs interpretation I've mostly seen says if you can get in, you need to get out. If it is just a closet. Only outside 18" pull was a requirement
 
Dinheru said:
I've always run the wall shelving short on latch side because of these clearances, as it is typically on the accessible: AHJs interpretation I've mostly seen says if you can get in, you need to get out. If it is just a closet. Only outside 18" pull was a requirement
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I've got the 18" on the interior pull side if I hold the shelves short, which of course the client doesn't want. I know the code doesn't address this, but since a wheelchair couldn't turn around if it went into this space, why would the 18" be required anyhow? Regardless, I'll do what's necessary to comply.

Thank you all for your input!!
 
Phil B said:
since a wheelchair couldn't turn around if it went into this space, why would the 18" be required anyhow?
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There are many other types of mobility issues than those which confine someone to a wheelchair. The code is written with those people in mind also. Think of the accessibility codes from this perspective and it will make much more sense.
 
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