2016 California Building Code 1009.1 exception #1: Accessible means of egress are not required in existing buildings.
So then the question is, does an
alteration to an existing building then force you to provide an accessible means of egress?
CBC 11B-202.3 requires alterations themselves to comply with 11B-202.4 "Path of Travel Requirements in alterations, additions, and structural Repairs." It appears that only 202.4 requires accessibility modifications to building components (that are not otherwise being contemplated for alteration), and it's a very limited list of items:
1. A [one] primary entrance to [NOT "all exits from"] the building or facility
2. Toilet and bathing facilities serving the area
3. Drinking fountains serving the area
4. Public phones serving the area
5. Signs.
Notice - no mention of egress, only entrance is required.
Now, it very often happens that a primary entrance is also functioning as an exit, and so if you make the entrance accessible, you're most of the way there to making made it an accessible egress as well. Nevertheless, accessible means of
egress is NOT automatically required for alterations to existing buildings.
The second thing to note is that CBC 202.4 exception #8 does NOT say you MUST spend 20% of your budget on accessibility.
It says you must provide the 5 items mentioned above, but you can stop once you've spent 20% of your construction budget.
For example, if your alteration budget was $200k, and you could achieve items #1-5 by only spending $10k, the code does not compel you to keep making more and more modifications (such as to the 3' high exit) in order to spend down $40k (20%) of your budget.
But the third thing to point out is, of course, that this is purely about the building code requirements. This does not address ADA, which
(because it is enforced in civil court, not by building permit) may have more requirements than the CBC.
for example, you may only be remodeling the operating room in the veterinary clinic, and the CBC could not compel you to have an accessible reception / bill paying counter. But good practice for ADA compliance may require it, even though the CBC (and the local code official) does not.
