2nd Floor accessible restrooms

[Francis Vineyard]

A little off topic; my previous deductions how the building code defines an occupancy area and ADA defines how the space is occupied was the issue I was grappling with here. Some previous experience that led to my earlier interpretation to provide other non-required accessible fixtures and elements eventually comes to the point where the owner says no one wins and because of cost and space does not provide the extras it at all. This was the underlying event in the OP. But there is a little wiggle room provided for in the ADA Guidance;

"The Department believes that the responsibility for determining and demonstrating equivalent facilitation properly rests with the covered entity. The purpose of allowing for equivalent facilitation is to encourage flexibility and innovation while still ensuring access. The Department believes that establishing potentially cumbersome bureaucratic provisions for reviewing requests for equivalent facilitation is inappropriate."

 

[righter101]

OK, one more question

The applicant has resubmitted the drawings, upper floor <3000 sq ft.

Added shower facilities on the lower floor.

Relabeled a small room on the lower floor "employee break room". about 200 sq ft.

Upper floor has an "employee lounge" that is much larger. Say about 600 sq ft. Stove and sink shown on plans.

Using only the IBC, is this legal?

If they put the sink and stove in the lower floor break room also, is this then ok?

Does the discrepancy in size matter?

Or is the spirit of the code satisfied by having an accessible break room on the lower floor??

This is new construction. I have rejected the plans for a litany of issues and the architect is not knowledgeable about accessibility. I understand it largely, but I am unsure the differences between what is contained in the building code and the ADA.

I understand that they need to provide the elements as accessible (with the noted exceptions in CH 11.).

I guess I am unclear if 1108 can be used and consider an employee break room or lunch room as a "dining area", or is this over reaching or misapplying the code.

This is the only place in the IBC I can find that would dictate the size of accessible vs. non-accessible in a quantified amount.

I can only use the IBC, not ADA as a local AHJ.

Thanks again guys.

 

[righter101]

Equivalent Facilities??

Are the requirements for "equivalent facilities" that you have shown in the ADA found in the IBC or do I need to interpret 1103 to arrive there?

Using the upper floor and lower floor "employee break room" example.

For the sake of argument, upper floor, no acc. route b/c <3000 sq ft. Employee break room is large, has couches, tv, sink, gas range, dishwasher.

Lower floor has a tiny, minimum size needed for accessibility, room, with a single table with a microwave and sink.

Ok using only IBC?

 

[peach]

Chapter 11 is not a safe harbor from compliance with ADA; ADA compliance is the responsibility of the owner and RDP.

 

[brudgers]

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[mark handler]

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