1104.4 Exemption 1: Aggregate Area for 2nd floors in different areas?

[nielsonru]

I have a single story vehicle dealership (new build) with B, S1 & S2 occupancies, mixed, non-separated. Client wants to do a mezzanine for parts storage in the warehouse, and a mezzanine for parts in the repair shop. Each one by themselves is under the 3000 sqft exemption in the 2018 IBC - 1104.4. I understand, however, you have to calculate the aggregate amount. The example the commentary gives is if the main floor is accessible, but there is a 2,000 sqft basement, and a 2,000 sqft 2nd story, the aggregate amount is 4,000 sqft. It says at least one of the areas has to be connected by an accessible route.

Is it correct to understand in my projects case that despite these two mezzanines being several hundred feet apart from each other in this overall facility, because the aggregate is over 3,000, one would need to be accessible?

 

[RLGA]

Look at Exception 2.

 

[nielsonru]

Look at Exception 2.

I did - but per the commentary "Exception 2 is a direct reference to the specific items addressed in Section 1107 and 1108. It is not a general exception for Groups A, I, R and S. The purpose of Exception 2 is to address areas within specific occupancies where a single element would be repeated multiple times on a level..."

1107 is for Dwelling Units and Sleeping Units, which we don't have. 1108 is Special Occupancies, none of which apply in my situation.

See the second to last comment on this thread -> https://www.thebuildingcodeforum.com/forum/threads/warehouse-storage-mezzanine-accessibility.10351/
That OP ran into the same thing I did, but the conversation fizzled out.

 

[RLGA]

I did - but per the commentary "Exception 2 is a direct reference to the specific items addressed in Section 1107 and 1108. It is not a general exception for Groups A, I, R and S. The purpose of Exception 2 is to address areas within specific occupancies where a single element would be repeated multiple times on a level..."

1107 is for Dwelling Units and Sleeping Units, which we don't have. 1108 is Special Occupancies, none of which apply in my situation.

See the second to last comment on this thread -> https://www.thebuildingcodeforum.com/forum/threads/warehouse-storage-mezzanine-accessibility.10351/
That OP ran into the same thing I did, but the conversation fizzled out.

I guess I was mentally treating "or other spaces as determined by Section 1107 and 1108" as an independent clause from "that do not contain accessible elements."

The interesting thing about this IBC section is that it goes against the 2010 ADA Standards. The ADA Standards only require an accessible route to a mezzanine if the building is multi-story (ADA 206.2.3). The advisory for the ADA section clarifies this by stating, "While a mezzanine may be a change in level, it is not a story. If an accessible route is required to connect stories within a building or facility, the accessible route must serve all mezzanines."

The difference between the ADA Standards and the IBC is that the ADA Standards apply the requirement to "multi-story buildings and facilities" whereas the IBC applies it to "multilevel buildings and facilities" (even though the section title states "Multistory"). I think the IBC got it wrong; thus, making the IBC more restrictive than the federal law. You may ask for a code modification using the ADA Standards as justification.

I am surprised no one has attempted a code change proposal for this in the past. I may have to submit it for the next code development cycle.

 

[steveray]

Call the parts mezzanines employee work areas? How big are they?