2nd Floor accessible restrooms

[mark handler]

Emergency showers, should not be on second floor, which is what the post is about.

 

[Francis Vineyard]

Emergency showers, should not be on second floor, which is what the post is about.

My reply was too short and left you with the wrong impression; I established with the first response accessible shower needs to be on the accessible level, there were additional questions aside from the accessible shower that were not answered and I meant to add that if an emergency shower is necessary it can be easily rectified by tapping into the eye wash station water supply to a shower head.

Does this mean the building department needs to provide me with a shower since some of the submissions i received are "irriating materials"??

Thanks for having me do right.

 

[Alias]

Stores got nailed about the break rooms and conference rooms on the second floor a few years back. Owner might want to reconsider placing them on the accessible floor.

I stopped a TI for an office here awhile back when they proposed the breakroom on the second floor with no access for handicapped employees. They looked at a lift, then moved the breakroom downstairs. They also had to put in accessible bathrooms, existing were under the stairs.

So, I will agree with those who say that if you have to an accessible shower on the 1st floor along with ones on the 2nd floor.

 

[righter101]

On that note, I am still working on this project review.

They are showing the breakroom on the 2nd floor, with no accessible route (<3000 sq ft.).

I don't see anything in the IBC that would prohibit it. ADA aside, as I can only enforce the building code.

Can anyone correct me or point me in the right direction.

Again, many thanks to those who have an extensive knowledge of this and are willing to share with those of us who know less.

 

[righter101]

I may have found it myself. 2009 IBC 1108.2.9 Exception 1 seems to address just this situation.

Would this be correct to apply to an employee breakroom with a kitchenette??

 

[Alias]

I may have found it myself. 2009 IBC 1108.2.9 Exception 1 seems to address just this situation.Would this be correct to apply to an employee breakroom with a kitchenette??

Unfortunately, I don't have a copy of the 2009 IBC. But, using the 2010 CBC, my answer would be 'yes'. Section 1103B.1 references Section 1114, Facility Accessibility, Section 1114 B.1.2 - Other Building Components(kitchens are included in this subsection).

 

[pmarx]

I may have found it myself. 2009 IBC 1108.2.9 Exception 1 seems to address just this situation.Would this be correct to apply to an employee breakroom with a kitchenette??

I don't quite see that, Righter101 on several levels. 2009 IBC 1108.2.9? Dining areas (at least that what my copy of the commentary has)? Exception 1 deals with mezzanines and it doesn't sound like that applies.

Regardless...

In my opinion the answer to your question is, if showers are provided, even on a non-accessible route, at least one of each type (male & female?) must be accessible. The level of accessibility is per ANSI A117.1, section 608. Makes no neverminds for residential or non-residential. In fact, Chapter 10 on dwelling units refers back to 608 for showers. Something I am still unclear on though. Are these showers for the occupants to bath or are they emergency showers? The type and quantity of fixtures is dictated by the plumbing code. I had asked earlier what you were working under and what was required. I can't speak to other than the National Standard Plumbing Code but that doesn't require any showers in the second floor business use. Just emergency showers for the first floor factory use. If emergency showers are required, they really need to be on the floor where the hazard is, in this case the ground floor.

 

[righter101]

There are several issues with the plans for this project. I think I have grasped the accessibility for showers. The second floor showers are somehow for employee use. Since they do not have an accessbile route to the 2nd floor, they need to provide an accessbile one on the first floor. The issue of an emergency shower will be clarified when I determine if any of the componenets of the process are "irriating", per the UPC. We use 2009 Uniform Plumbing Code, and the CH 29 of the IBC.

As far as the employee lunch/break room, I am wondering if I can apply 1108.2.9. You are right, the exception may not be relevant. My question is this, can they have the employee break room on the second floor and not provide an accessible route to it?

I believe 1108.2.9 Dining areas. In dining areas, the total floor area

allotted for seating and tables shall be accessible.

Would apply...?? Am I correct in applying this to an employee eating area with a kitchenette?? If not, is there anything that can require the break room to be accessible>??

Do i just revert back to 1103.1 Sites, buildings, structures, facilities,

elements and spaces, temporary or permanent, shall be accessible

to persons with physical disabilities.

 

[Francis Vineyard]

The dining area would have to be considered an assembly use group before going to that section; then it will need to be sprinklered. It's still a business use with the dining/kitchen area under 750 sf or the occupant load under 50.

Don’t know UPC but in IPC separate facilities are for required fixtures counted; not emergency showers.

Hope this helps.

 

[righter101]

The dining area would have to be considered an assembly use group before going to that section; then it will need to be sprinklered. It's still a business use with the dining/kitchen area under 750 sf or the occupant load under 50.Don’t know UPC but in IPC separate facilities are for required fixtures counted; not emergency showers.

Hope this helps.

I think we can confuse the issue a bit more. It reads, "assembly areas.....". I believe you can have an assembly area or assembly use, ie. break or conference room, yet be within a "B" occupancy. This is one of those things that has probably been hashed before. I think it is an important distinction. You can have a storage "use or area", but not an S occupancy.

Agree or disagree?

Regardless, i think I can go back to general scoping provisions and use 1103.1, "all elements....." etc.. to require it.

 

[righter101]

As far as the emergency shower, I am still waiting to see a list of the chemicals used in the process to determine if any of them qualify as "irritating", thus requiring the emergency shower.

And, the state of washington has unadopted the UPC portion in CH4 that dictactes fixtures. Rather, they amended in its entirety, IBC CH 29 for fixtures.

 

[Francis Vineyard]

Righter101

I can see where if it looks like a dining area, and it is use as a dining area, it must be a dining area. Back up and look at the title of Section 1108; Occupancies; my interpretation is these are assembly use groups as defined in chapter 3.

As for the emergency stations they are easy to retrofit if it needs them. Did it have one before? Most all F-1 will have at least an eye wash station.

Perhaps another way to look at this is chapter 11 is a civil rights requirement that applies to the building; it does not establish the occupancy (area) of the building.

 

[Francis Vineyard]

I think we can confuse the issue a bit more. It reads, "assembly areas.....". I believe you can have an assembly area or assembly use, ie. break or conference room, yet be within a "B" occupancy. This is one of those things that has probably been hashed before. I think it is an important distinction. You can have a storage "use or area", but not an S occupancy.Agree or disagree?

Regardless, i think I can go back to general scoping provisions and use 1103.1, "all elements....." etc.. to require it.

Agree same as mixed use occupancies along with the definition of Employee Work Area" and 1108 addressing "specific occupancies" substantiates this conclusion.

ADA guidelines comparison also puts forth under IBC that this is considered a B occupancy not an assembly use group dining area. Additionally if this were an alteration to an existing building the dining area would need to be a cafeteria or similar entity open to the public to qualify in my opinion.

1104.3 exception 1 will also work to exempt this area for accessibility.

 

[mark handler]

Breakrooms and employee restrooms/bathing (shower) rooms are considered common use areas and are required to be fully accessible No matter what floor they are on.

 

[Francis Vineyard]

Breakrooms and employee restrooms/bathing (shower) rooms are considered common use areas and are required to be fully accessible No matter what floor they are on.

What is your opinion on accessibility for the kitchenette and dining area?

There are several issues with the plans for this project. I think I have grasped the accessibility for showers. The second floor showers are somehow for employee use. Since they do not have an accessbile route to the 2nd floor, they need to provide an accessbile one on the first floor. The issue of an emergency shower will be clarified when I determine if any of the componenets of the process are "irriating", per the UPC. We use 2009 Uniform Plumbing Code, and the CH 29 of the IBC.As far as the employee lunch/break room, I am wondering if I can apply 1108.2.9. You are right, the exception may not be relevant. My question is this, can they have the employee break room on the second floor and not provide an accessible route to it?

I believe 1108.2.9 Dining areas. In dining areas, the total floor area

allotted for seating and tables shall be accessible.

Would apply...?? Am I correct in applying this to an employee eating area with a kitchenette?? If not, is there anything that can require the break room to be accessible>??

Do i just revert back to 1103.1 Sites, buildings, structures, facilities,

elements and spaces, temporary or permanent, shall be accessible

to persons with physical disabilities.

 

[peach]

If there are equivalent facilities on both floors, you can maybe eliminate the elevator; showers, break rooms, etc need to also be available on the first floor.. or you're in violation of the spirit of the law.

 

[mark handler]

What is your opinion on accessibility for the kitchenette and dining area?

Considered common use areas and agree with Peach on equivalent facilities.

 

[Francis Vineyard]

If there are equivalent facilities on both floors, you can maybe eliminate the elevator; showers, break rooms, etc need to also be available on the first floor.. or you're in violation of the spirit of the law.

Where exceptions are permitted and are outside the perimeters of ADA are in violation with the "spirit of the law"? I cannot find this in ADA.

 

[mark handler]

Where exceptions are permitted and are outside the perimeters of ADA are in violation with the "spirit of the law"? I cannot find this in ADA.

It is in the scoping of the "new" ADAAG

28 CFR 35.151 New construction and alterations

Departures from particular requirements of either standard by the use of other methods shall be permitted when it is clearly evident that equivalent access to the facility or part of the facility is thereby provided.

http://www.ada.gov/regs2010/2010ADAStandards/2010ADAstandards.htm#pgfId-1009827

 

[mark handler]

And in the scoping of the 2002 ADAAG

2.2* Equivalent Facilitation. Departures from particular technical and scoping requirements of this guideline by the use of other designs and technologies are permitted where the alternative designs and technologies used will provide substantially equivalent or greater access to and usability of the facility.

http://www.access-board.gov/adaag/html/adaag.htm

 

[peach]

thanks Mark... for once we agree..



Spirit of the law is my term...

In any event, you aren't allowed to approve something that is clearly discrimates against any protected group.

 

[Francis Vineyard]

Thanks for convincing me the ADA’s kitchenette and dining areas are required to be accessible where the fixtures are built-in.

Advisory 201.1 Scope. These requirements are

2010 ADA Standards for Accessible Design

http://www.ada.gov/regs2010/2010ADAStandards/2010ADAstandards.htm

201.2 Application Based on Building or Facility Use.

Where a site, building, facility, room, or space contains more

than one use, each portion shall comply with the applicable

requirements for that use.

201.3 Temporary and Permanent Structures. These

requirements shall apply to temporary and permanent

buildings and facilities.

to be applied to all areas of a facility unless

exempted, or where scoping limits the number of

multiple elements required to be accessible. For

example, not all medical care patient rooms are

required to be accessible; those that are not

required to be accessible are not required to

comply with these requirements. However,

common use and public use spaces such as

recovery rooms, examination rooms, and

cafeterias are not exempt from these

requirements and must be accessible.

201.2 Application Based on Building or Facility Use.

Where a site, building, facility, room, or space contains more

than one use, each portion shall comply with the applicable

requirements for that use.

 

[peach]

you don't have to go any further than IBC section 1103: sites, buildings, structures, facilities, elements and spaces, temporary or permanent shall be accessible to persons with physical disabilities.

Sure it's broad (probably on purpose).. pretty clear, though.

 

[mark handler]

But

The IBC chapter 11 can be percived to be in conflict with the ADAAG

SECTION 1102

DEFINITIONS

EMPLOYEE WORK AREA. All or any portion of a space used only by employees and only for work.

Corridors, toilet rooms, kitchenettes and breakrooms are not employee work areas.

1103.2.3 Employee work areas. Spaces and elements within employee work areas shall only be required to comply with Sections 907.9.1.2, 1007 and 1104.3.1 and shall be designed and constructed so that individuals with disabilities can approach, enter and exit the work area. Work areas,or portions of work areas, that are less than 150 square feet in area and elevated 7 inches or more above the ground or finish floor where' the elevation ,is essential to the function of the space shall be exempt from all requirements.

Work Areas [4.1.1(3)]

Employee spaces used for purposes other than job-related tasks (breakrooms, lounges, parking, shower and locker rooms, etc.) are considered "common use" and are required to be fully accessible.

http://www.access-board.gov/adaag/about/guide.htm