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2015 IEBC: existing non-compliant ramp inside a new addition

T

Tim Mailloux

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Hartford CT
This morning one of the junior staff in the office asked me to look at a condition on a project he is working on that didn’t sit right with him, but his project manager told him was fine as is. The project is a small side entrance addition to a church, the addition includes a vestibule, a ‘handicap ramp’ (more on the ramp to come) and two handicap accessible single user toilets. Currently there is not an accessible entrance or accessible toilets in the facility. The condition that didn’t sit right with the junior staff member is the ramp. The ramp is an existing exterior concrete ramp with a 1” over 8” pitch and a 24” vertical rise. The new addition is being built over and around this existing ramp, and the ramp will remain in use.

The IEBC states that additions must comply with the IBC, and in my opinion any ramp in the addition must be code compliant under the IBC. The Project Manager feels that the ramp is an existing non-complying condition and is grandfathered “as-is”. As the church does not currently have an accessible entrance, section 705.2 ‘Alterations affecting and area containing a primary function’ comes into play here, and 20% of the overall project budget needs to be spent on improving the accessible route, which in my understanding starts outside at the handicap parking, then the accessible path to the building entrance, then an accessible entrance, and then an accessible path to the toilet facilities and so forth.

Do any of you feel this existing ramp inside the new addition is grandfathered?
 
I detest the term "grandfathered". It is over-relied upon by those with a lack of knowledge, particularly those who wish not to spend money on accessibility.

Per the IEBC...

705.2 Alterations Affecting an Area Containing a Primary Function
Where an alteration affects the accessibility to a, or contains an area of, primary function, the route to the primary function area shall be accessible. The accessible route to the primary function area shall include toilet facilities and drinking fountains serving the area of primary function.
Exceptions:
1. The costs of providing the accessible route are not required to exceed 20 percent of the costs of the alterations affecting the area of primary function.
2. This provision does not apply to alterations limited solely to windows, hardware, operating controls, electrical outlets and signs.
3. This provision does not apply to alterations limited solely to mechanical systems, electrical systems, installation or alteration of fire protection systems and abatement of hazardous materials.
4. This provision does not apply to alterations undertaken for the primary purpose of increasing the accessibility of a facility. 5. This provision does not apply to altered areas limited to Type B dwelling and sleeping units.​
 
The following is the only exemption that may apply.

705.1.1 Entrances
Where an alteration includes alterations to an entrance, and the facility has an accessible entrance on an accessible route, the altered entrance is not required to be accessible unless required by Section 705.2. Signs complying with Section 1111 of the International Building Code shall be provided.
 
Ty J. said:
The following is the only exemption that may apply.

705.1.1 Entrances
Where an alteration includes alterations to an entrance, and the facility has an accessible entrance on an accessible route, the altered entrance is not required to be accessible unless required by Section 705.2. Signs complying with Section 1111 of the International Building Code shall be provided.
Click to expand...

I was looking at that as well, but the existing church does not have an accessible entrance, which would then kick you over to 705.2. Additionally, this an an addition, and I don't see away around the addition not being fully code compliant.
 
Tim Mailloux said:
I was looking at that as well, but the existing church does not have an accessible entrance, which would then kick you over to 705.2. Additionally, this an an addition, and I don't see away around the addition not being fully code compliant.
Click to expand...
I agree. I was more indicating that 705.1.1 was the only exemption, and that it did not apply.
 
The term grandfathered is usually referring to a condition that was never approved.....such as a ramp with a 12.5% slope.
 
Depending on the particular floor plan, I would only hold you to the 20%...I could call the ramp existing (as it is...) but the route would have to be improved, which may include the ramp....The ramp is in the addition, but is not an addition itself.....Of course I would also look if it was ever permitted and call that violation if needed...
 
steveray said:
Depending on the particular floor plan, I would only hold you to the 20%...I could call the ramp existing (as it is...) but the route would have to be improved, which may include the ramp....The ramp is in the addition, but is not an addition itself.....Of course I would also look if it was ever permitted and call that violation if needed...
Click to expand...

Thanks Steve!

Any chance your the BO in Middletown :-)
 
Ty J. said:
I detest the term "grandfathered". It is over-relied upon by those with a lack of knowledge, particularly those who wish not to spend money on accessibility.
Click to expand...

I agree with this statement!

Leave it alone and it can stay as is, non compliant!
 
The ADA is based on the 1964 Civil Rights Act, which exempted churches and private clubs. However, use of church facilities by the public (day cares not limited to church members, AA meetings, etc.) make those facilities subject to ADA.

I believe BOCA used to allow 1:8 ramps as exits back in the 1970s.
 
Paul ... that’s the first time I have seen something tying the ADA to the 1964 civil rights act ...
 
The NFPA Life Safety Code allows a 1:8 ramp for existing buildings. Just saying that a steep ramp is not considered too crazy by everyone involved.
 
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