Accessible path to other exit required?

[Mr. Inspector]

I am inspection a very large S2 building that has a lot of non accessible exits.The whole building inside and out is an employee work area. Using 2009 IBC.

Section 1110.2 (5) At exits and exit stairways serving a required accessible space, but not providing an an approved accessible means of egress, signage shall be provided in accordance with section 1007.10.

Section 1007.10 Directional signage indicating the location of other means of egress and which are accessible means of egress shall be provided at the following:
1. At exits serving a required accessible space but not providing an approved accessible means of egress.

There is no way they can have accessible routes in this building and are not required in an an employee work area except for Common Use Circulation routes because of conveyors running all over that have ship ladders that go over them. There are no Common Use Circulation routes.

Where in the code is an accessible route required from a non accessible exit to an accessible exit?

 

[RLGA]

Accessibility is not my expertise, but what about a wheelchair-bound company owner that wants a tour of his/her facility? What about the supervisor that had an accident is walking around temporaily with a cane? I believe there should be a common use circulation path around the perimeter of the floor, through the middle, or somewhere that links all of the required exits. A typical means of egress path for able-bodied occupants has the same requirements for an accessible route. The exceptions in the IBC, ANSI A117.1, and the ADA Standards are not meant to be completely in lieu of other requirements, but for specific, limited applications.

 

[Mr. Inspector]

I forgot to say the building is existing but the conveyors are new. Accessible means of egress is not required in an existing building.

The new conveyor system goes right to the truck loading doors which blocks any accessible route between the exit doors. The regular egress requirements work out ok because there are stairs and catwalks over the conveyors but no accessible routes most places. The whole conveyor system is like one huge machine. 1104.3.1 exception 2 Common use circulation paths, located within employee work areas, that are an integral component of equipment, shall not be required to be accessible routes.

I am just referring to the directions sign requirement in section 1110.2 (5). What should the directional sign say? The code doesn't say if the route to the accessible exit needs to be accessible. It would seem dumb to have a directional sign to an accessible exit it the route to the accessible exit is not accessible.

 

[RLGA]

The ADA Standards state paths "that are an integral component of work area equipment" are not required to be accessible. I think the key word here is "integral." Are the stairs and catwalks "integral" to the equipment, or are they "added" to avoid the equipment? The advisory in the ADA Standards for this exception states in part, "Large pieces of equipment, such as electric turbines or water pumping apparatus, may have stairs and elevated walkways used for overseeing or monitoring purposes which are physically part of the turbine or pump." (emphasis is mine)

If the stairs and catwalks are there to monitor and maintain the equipment, then yes, they are not required to be accessible. But if they are there because the equipment obstructs the circulation paths, then I would say they are not integral and, therefore, are not compliant.

Just my opinion.

 

[Mr. Inspector]

RLGA, some stairways and ramps are used for overseeing and maintenance of equipment. But some are used to get to other areas where stairways and ramps are used for overseeing and maintenance of equipment

 

[RLGA]

RLGA, some stairways and ramps are used for overseeing and maintenance of equipment. But some are used to get to other areas where stairways and ramps are used for overseeing and maintenance of equipment

Then those stairs and ramps "used to get to other areas" are part of the common use circulation path and, in my opinion, are subject to ANSI A117.1/ADA Standards Section 402, unless there is another nonobstructed path available.

The question I have, assuming the area with the equipment is permitted without common use circulation paths, then all those exits that are nonaccessible and are not on an accessible route, have no need for the signage, because someone with disbilities could not have possibly reached that nonaccessible exit. If there's a portion of the facility that is accessible (i.e. offices, break room, restrooms, etc.) and has nonaccessible exits, then those exits should have signs directing disabled occupants to the accessible exits.