Lockers vs. locker room

[Amy Reineri]

A proposal for am A-2/A3 has come in. Within the space is a storage/mech. room. However within the room are employee lockers. It is largely an employee workspace for storage and equipment such as the water heater, CO2 tanks, and soda racks, but with a bank of employee lockers, ergo it is a room, with lockers. I see no way around the fact that at least 5% of the lockers must be accessible per 2018 IBC 1109.9. But would it be considered a "locker room" in the context of ANSI 117.1 803? The issue is that the room does not allow room for the bench required by ANSI 803/903 without some reconfiguration. Happy to cite that requirement, just want to be sure of the distinction between a locker being accessible vs. a designated "locker room".

There are requirements for employees to have access to a place to keep their personal belongings while on shift - a locker. There is not a requirement for a locker room, though some places want them out of view or with more security from the public hallways. They could be put in another employee only area like a break room. But a locker room assumes the space is also a changing area - like down to your underwear. Dressing rooms are required to have ADA benches for this reason. If the locker area has no expectation of privacy and nothing to encourage it's use for changing clothing in a manner that requires privacy, then it's not a locker room - because no real dressing occurs. The route to - and heights of - the lockers need to be accessible, but no clothing change bench is needed. However, if a non-ADA clothing change bench is provided, they should either remove it or upgrade it to ADA compliant.

 

[walker.t]

There are requirements for employees to have access to a place to keep their personal belongings while on shift - a locker.

Where? I can’t think of having ever seen that in anything like A117.1 or the IBC, never had a plan review comment telling me to provide storage for employee belongings. Local health department requires a designated storage area for employee belongings in food service establishments but other than that I can’t think of where such a requirement is stated.

 

[Amy Reineri]

Where? I can’t think of having ever seen that in anything like A117.1 or the IBC, never had a plan review comment telling me to provide storage for employee belongings. Local health department requires a designated storage area for employee belongings in food service establishments but other than that I can’t think of where such a requirement is stated.

Might be OSHA? Regs in my state? I don't know where all the requirements come from that clients and reviewers say require lockers - sometimes the employees demand them (salons with hoteling of workstations) other times OSHA does for storing individual safety gear or clothing exposed to certain substances, restaurants and some others it's by Health Department requirements, laws protect some workers in manufacturing who are required to "not have anything personal with them" on the line from being left without access to items they need on breaks, etc. But a lot of my clients are telling me they have to provide lockers for their workers. Dentists tell me they need them - might be an insurance requirement to be sure people's personal medications aren't accidentally offered to patients. If a business isn't required to have lockers, they don't need them - but if there is a locker room in a facility and the question is whether that automatically makes it a locker room, it doesn't unless there is also dressing-room-grade dressing going on in there. Mr. Roger's style dressing is fine (jacket or vest, shoes, apron even), but if people are undressing to the point of needing privacy, it's now a locker room. A flag-maker didn't allow personal items in the sewing or cutting rooms because they could include things that would stain the fabrics. Lockers in the halls like in school settings were the answer there.

 

[MtnArch]

State and/or local Health Department regulations may also dictate employee storage. The California Retail Food Code requires lockers; dressing rooms/areas are only required "... if the EMPLOYEEs regularly change their clothes in the facility."

 

[Amy Reineri]

Related....the A2/A3 is a golf simulator and bar establishment. IBC speaks generically to recreational facilities, and specifically to miniature golf facilities. I think this is further away from a miniature golf facility than a recreational facility. As a recreational facility, an accessible route to the edge of the play area is required, and a W/C space in the player seating area. 2018 IBC 1110.4.1 requires "each" area of sport activity. Not 5% or not less than 1 as identified for bowling lanes. There are 5 identical simulator bays. Could this be viewed a single area of sport activity so that 1 bay meets the requirements? Or, would it be required that "each" bay meet the requirements?

Here is their depiction of a simulator bay. You will note that they indicate a 3' accessibler oute, even though it is covered by furniture. Easy enough to remove a chair which would provide both the AR and W/C space, but less palatable if they must do it all bays.

View attachment 16537

I would pull one chair back to give you a single 36" access, or remove the single chair - there is a lot of seating there compared to bowling lanes, eh? Remove the single chair - then make and indicate that the opening on that side is compliant (36" min.). At that point, if the client puts things in that opening, they have to move it when setting up for the group who has mobility needs or potentially have an ADA violation charged against them. It's not covered under their business insurance, so it's a business risk. If they want more lanes and are going to keep these spaces tight without bring the chairs further out or further in, it's really on them. You need to have advised them to maintain a clear access of the minimum width. Clients can be told 100 times not to put millwork in the clearances for an ADA toilet - and they always do. This is no different - have compliance with the ADA access indicated on the plan. If they won't do it in practice, it's their fine.

 

[Sifu]

I just asked them to verify the furniture is not fixed in place. Based on the drawings it wouldn't appear to be but best to have it documented. The rest is up to them.

 

[Amy Reineri]

I just asked them to verify the furniture is not fixed in place. Based on the drawings it wouldn't appear to be but best to have it documented. The rest is up to them.

True, but it's not just whether it's fixed to the floor/wall/millwork or not, it shouldn't be in the way at all. Like the baby changing stand in the ADA restroom - it's going to take time for someone to drag it out of the way and it's an embarrassment for someone (wheel chair or not) to explain that their hip or nerve damage or whatever means someone has to move that chair. Those lounge chairs look hard to move - they typically are. Whatever keeps you off the hook, I suppose, but I don't allow my drawings to show non-compliant layouts - I show what is legal, I document the spacing and note any exceptions I am using (mostly in chair/table layouts for assembly) but I never show the thing my client has had to be told 5 times already that they cannot do and I strongly suspect they will do the moment the final inspection is approved. Suspicion isn't actionable - indicating a compliant layout is the best you can do in those cases.

 

[Jean Tessmer-HI]

I spoke to Josh Schorr of the US access board the federal agency that writes the ADA Standard for the DOJ to enforce.
Here is what he has to say. You can keep this to show any one else you want. The best to you all.

"No, a bench is not required.

A bench is required for locker rooms – those that are going to be used for changing clothing. Providing lockers/storage in a room doesn’t inherently make it a “locker room”.

Just because a storage unit is a locker doesn’t necessarily mean that it is located in a “locker room”.

Josh Schorr
TA Coordinator
U.S. Access Board
1331 F. Street, NW, Suite 1000
202.272.0029
Website: www.access-board.gov"

 

[Sifu]

I spoke to Josh Schorr of the US access board the federal agency that writes the ADA Standard for the DOJ to enforce.
Here is what he has to say. You can keep this to show any one else you want. The best to you all.

"No, a bench is not required.

A bench is required for locker rooms – those that are going to be used for changing clothing. Providing lockers/storage in a room doesn’t inherently make it a “locker room”.

Just because a storage unit is a locker doesn’t necessarily mean that it is located in a “locker room”.

Josh Schorr
TA Coordinator
U.S. Access Board
1331 F. Street, NW, Suite 1000
202.272.0029
Website: www.access-board.gov"

Copied and pasted in my notes on the project, just in case it comes up. Thanks.