Accessible single office clearances in an open office space

[SmileyO]

I did some search on here and didn't really find the answer that pertains to my situation. I am currently working under the 2021 Colorado code, which has no amendments so it's the same as the 2021 IBC.

I am working on a tenant fitout and there is an existing office that does not have the door clearances within the office. Below is a screen shot of the office in question. I remember but can not find that individual offices are not required to be ada compliant. I looked all throughout section 11 of the IBC for an exception (includeing specifically 11.03.2.2) regarding work areas, but it says:
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1103.2.2 Employee Work Areas

Spaces and elements within employee work areas shall only be required to comply with Sections 907.5.2.3.1, 1009 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, other than raised courtroom stations in accordance with Section 1109.4.1.4, that are less than 300 square feet (30 m2) in area AND located 7 inches (178 mm) or more above or below the ground or finished floor where the change in elevation is essential to the function of the space shall be exempt from all requirements.
===========================

Take special note of the AND part which is why I don't think this section allows for my excemptions.

Does anyone in the collective hive know if the individual offices in a business use group can be exempt from ADA/accessibility requirements and if so, can you point me to that section?

Thank you in advance

 

[Yikes]

Welcome to the forum!
You say the office itself is existing. Is everything existing / no change that is highlighted in yellow in the image below? Such that the only new stuff may be the furniture and office equipment?

 

[SmileyO]

Thank you for the welcome. I stumbled across this website when I was trying to find my answer, sometimes the algorithm gets me more than just synchronized canooing videos! I hope I can contribute in some small way.

To answer your question. The office itself (partitions and exterior wall) shown are existing to remain. The furniture itself is existing but a comment came up from a reviewer that the existing does not meet accessibility standards for pull side of the door. Regardless if the existing furniture is there, or we were putting in new furniture, I originally thought there was some exception in the code that allowed single offices such as this to be non-compliant. But my "thought" has to be backed up by some actually/referenceable code (plus for my education as well.) I know I could spin or adjust the furniture to make it accessibly compliant but some office users are very particular how they want their desk (I guess in this case, the person doesn't want their back toward the door).

 

[Paul Sweet]

The furniture can be moved or changed if the employee becomes disabled, or the employee can be given a different office.

 

[SmileyO]

I would agree on that. Though I know I am getting deep into the weeds, but I have to reference a code that says it doesn't need to be code compliant for single person offices. I know we need to meet accessible circulation in conference rooms but it seems a single person office would not require to be accessible if the single person using it does not require it to be accessible. If someone in a wheelchair comes along, the tenant or owner could just reconfigure the office as required.

 

[walker.t]

The office itself (partitions and exterior wall) shown are existing to remain.

You mention that there are existing walls, doors, and furniture, yet you reference the IBC instead of the Existing Building Code - maybe there is something in the Existing Building Code that would help?

If it was me I’d just buy a new desk, it’s cheaper than reversing the door swing and they probably don’t want the door to swing out anyway.

 

[Yikes]

SmileyO, let's get a little deeper into the weeds. Depending on the kind of office use and a few other things, the particular room in question may or may not be subject to compliance with the Americans With Disabilities Act. The Owner is responsible for providing reasonable accommodation and not discriminating against person with disabilities. If you are specifying and designing furniture locations, the Owner may (or may not) be relying on you to provide an ADA-compliant solution.

But ADA compliance is a different topic: you have asked specifically about IBC 2021 compliance. (ADA is civil law, and as such is enforced by the courts. It is NOT enforced by the local building department.)

The local building department is enforcing the 2021 IBC, which may have similar door clearances as ADA, but its scoping and enforcement is different.

1101.1 says that IBC chapter 11 covers design and construction of facilities. You are neither designing nor constructing this existing office. It's already there, and you aren't changing it.
From IBC 202 definitions:

Note that the definition of "Facility" does not appear to include non-fixed furnishings.

Now look at the overall scoping of 2021 IBC as it relates to existing structures that aren't changing.


What I'm saying is, your plan already complies with 2021 IBC as that code applies to existing spaces that were previously legally permitted and are not being changed. There should be no accessibility corrections from your plan checker regarding the pull side clearance of that particular door, especially if you mark it "existing - no change".

Again, that doesn't let you off the hook for ADA compliance (for which door clearance around office furnishings may be evidence of good faith effort towards nondiscrimination), but that's a different question. And ADA has multiple options for existing/ no change offices to comply.

 

[ICE]

Why is the furniture on the plans?

 

[walker.t]

Why is the furniture on the plans?

I asked myself the same question. Maybe to show compliance for requirements for aisles per 1018.1, “Aisles or aisle accessways shall be provided from all occupied portions of the exit access that contain seats, tables, furnishings, displays and similar fixtures or equipment.”? But if that was the case then there’d be a few dimensions showing how much space is available around the furniture.

My guess is that the plan with the furniture was intended to be the “pretty picture” to get owner approval and they left the furniture on for the permit drawings without thinking about it. I’ve seen a few sets of drawings with building sections showing scale figures and cars and trees in the background - none of which were needed for drawings for permitting and construction.

 

[Yikes]

When I am the design professional of record and it is not in my contract to provide furniture design, best practice is to show dotted lines at the doors that indicate the minimum required clearances per ADA and/or the applicable local code (whichever is more restrictive). See example of the blue lines at the door for the I.T. staff office below:


That way if someone in the future places furniture in a manner that violates those regulations, you are already on record as having provided a code-compliant solution.

 

[ICE]

Well there’s the problem.

 

[walker.t]

best practice is to show dotted lines at the doors that indicate the minimum required clearances per ADA and/or the applicable local code (whichever is more restrictive)

I think that’s a great idea, some design professionals don’t seem to think it’s important. On the plan you show, one can easily tell by looking that there’s enough room on the pull side of the IT room door, but it’s so close in the corridor that the plans reviewer would have to check a dimension then subtract the thickness of the wall finish.

 

[Yikes]

I think that’s a great idea, some design professionals don’t seem to think it’s important. On the plan you show, one can easily tell by looking that there’s enough room on the pull side of the IT room door, but it’s so close in the corridor that the plans reviewer would have to check a dimension then subtract the thickness of the wall finish.

I do provide a hallway dimension elsewhere on that plan. I'm just showing small excerpt of the drawing.
We actually have the clearances baked into the Revit family for doors.

 

[Yankee Chronicler]

According to UpCodes, Washington, DC, has adopted the 2015 IEBC, so that should be the starting point for looking at this issue.

It's a new tenant fitout in an existing building, and the OP indicates that the office in question is an existing office. My first question is going to be which method of IEBC compliance has been chosen for this project. Very few architects choose to use the Performance (point score) method, so it's likely either the Performance Method or the Work Area Method. If it's the Work Area Method, we need to know if it's a Level 2 or Level 3 (or maybe Level 1?) project.

In general, looking through both the Prescriptive Method and the Work Area Method for Level 2 I don't see anything that addresses the placement of FF&E in an existing single-occupant office. IMHO, this would be left to the ADA under the indivudual worker accommodation provisions rather than be under the purview of the building code.

I'm sure the goal here is to put the same furniture in each office and, as a goal, that's understandable both from an logistics perspective and from an HR (Human Resources) perspective. But sometimes reality rears its ugly head -- you've got one office with a column poking out of the middle of the window wall. If you absolutely must maintain the clearance at the door -- adjust the FF&E. Simple option - turn the desk and typing return 90 degrees:



I assume the 'P' on the return denotes a printer. There's no reason this desk can't have a shorter typing return, and put the printer on a free-standing printer stand that can be pushed back into the recess to the left of the column -- or moved around to the lower right corner of the office. With the printer in the upper left recess, there's still room to put a visitor chair in the lower right corner and still have clearance at the door. Sure, it's not ideal to have your back to the door, but I've worked in offices where my back was to the door and it didn't bother me at all.

I don't see a code issue here.

 

[Yikes]

I am currently working under the 2021 Colorado code, which has no amendments so it's the same as the 2021 IBC.

According to UpCodes, Washington, DC, has adopted the 2015 IEBC, so that should be the starting point for looking at this issue.

Smiley O's profile is based in Washington DC, but apparently the actual project is located in Colorado.

 

[Yankee Chronicler]

Smiley O's profile is based in Washington DC, but apparently the actual project is located in Colorado.

Oops.

Both Colorado and Denver have adopted the 2021 IEBC, but the state didn't amend it, and Denver did amend it. Without delving into what Denver amended in the IEBC, I think my comments pretty much hold true under the 2021 IEBC.

 

[walker.t]

I do provide a hallway dimension elsewhere on that plan. I'm just showing small excerpt of the drawing.
We actually have the clearances baked into the Revit family for doors

My bad, I did a bad job of saying what I was trying to say. What I was trying to say was that if you didn’t show the door maneuvering clearances in the corridor that someone would have to refer to your dimensions to confirm the required space was there. I assumed there were dimension strings not show in the image.

I don’t use Revit to know, but I guess it won’t let you place a door in a location that does not provide the required clearances.

 

[walker.t]

I don't see a code issue here.

Well done, that’s a good breakdown of the though process you followed.

 

[Yikes]

My bad, I did a bad job of saying what I was trying to say. What I was trying to say was that if you didn’t show the door maneuvering clearances in the corridor that someone would have to refer to your dimensions to confirm the required space was there. I assumed there were dimension strings not show in the image.

I don’t use Revit to know, but I guess it won’t let you place a door in a location that does not provide the required clearances.

Unfortunately, Revit doors are not set up this way. You have to customize the Revit door family to do this.

Revit will check for some basic conflicts, but this feature can give you a false sense that it is taking care of all coordination issues. This is especially true if you are more experienced in Revit than you are in design and construction.
For example, I work with staff who will drop in a Revit stair and assume it has already accounted for ADA compliant grab bar extensions (it does not). Next thing you know, they've designed the stairwell landings too short.

It's the drafting equivalent of putting a Telsa in self-driving mode and then taking a nap.

 

[walker.t]

Unfortunately, Revit doors are not set up this way. You have to customize the Revit door family to do this.

Revit will check for some basic conflicts, but this feature can give you a false sense that it is taking care of all coordination issues. This is especially true if you are more experienced in Revit than you are in design and construction.
For example, I work with staff who will drop in a Revit stair and assume it has already accounted for ADA compliant grab bar extensions (it does not). Next thing you know, they've designed the stairwell landings too short.

It's the drafting equivalent of putting a Telsa in self-driving mode and then taking a nap.

I guess if you can customize things then that’s better than nothing.

I know an architect that uses Archicad, he seems to trust the software too much and doesn’t do a good job of checking the drawings for errors. For example, he did a wall section showing the second floor exterior walls bearing on the top chords of the wood floor trusses and the plywood subfloor was butt to the side of the bottom plate of the wall.

I use a 2-D-only drafting application, compared to your Tesla it’s like driving an old Civic - if I fall asleep behind the wheel I end up in the ditch and feel really stupid trying to explain how that happened.

As Yankee Chronicler’s #14 post demonstrates, the designer is responsible for thinking things through and knowing the requirements with which the design must comply. The software might help us get there, but in the end we have to make sure it was done right. Yeah, at least for the time being the plans reviewer doesn’t call your office and say, “Hey, put Revit on the line, I have a few questions about these drawings.”

 

[Yankee Chronicler]

The IBC doesn't explicitly require a separate egress diagram, but it does require that a number of things pertaining to egress be shown as compliant. For many years, starting with the reviewers at the state Department of Education requiring separate egress diagrams for all public school projects, it has become the norm in this state for architects to provide an egress diagram. It's usually one of the first sheets in the drawing set, in with the 'G' or 'A0-xxx' drawings. That's where we find the depiction of the exit access path and distance, the door sizes and capacities, the room/space use classifications and occupant loads, etc. Once in awhile they also show the accessibility approach clearances at doors.

Like walker.t, I only use a 2-D drafting program: AutoCAD LT at home, and the free version of NanoCAD at work.* I've never done it, but this discussion made me realize that it would be easy enough to include the maneuvering clearance box in the plan view symbols for doors.

Sadly, even though almost every architect and unlicensed designer includes an egress diagram, as often as not they're not worth the paper they're printed on. There was the guy at my old job who drew exit access routes through solid walls. A couple of years ago, at this job, we had a guy who claims to be an architect but who isn't licensed (in this state, and apparently not in any state) who drew up a small 2-story spec office building. The second floor was just large enough that he needed two means of egress. Believe it or not, in his plan the exit access route to the second (rear) exit stair led through the first (front) exit stair. He seemed to be genuinely confused when I mentioned that you can't do that. I have lost count of how many egress diagrams I have reviewed for interior alterations in existing buildings where the architect (or whoever drew the egress diagram) only drew the path of travel as far as the door from the affected suite to the corridor, and measured as if the exit access distance ends at the corridor door. They don't even bother showing the rest of the exit access path, or the exits. Just did one on Friday: two exits required. One exit actually shown, with a maximum path of travel shown as 44 feet. The second egress route goes out in another direction, but the egress diagram doesn't show that part of the building (which is also the accessible entrance, and also doesn't show the toilet rooms serving the altered space). We recently approved a tenant fitout for an adjoining space in the same building, so by pulling the plans for that permit I was able open the overall building plan in Adobe Acrobat and measure the travel distance. From the point show as the starting point for the 44-foot travel distance, which is supposed to be the most remote point, the path of travel to the entrance/exit that's not show was 135 feet -- so obviously what the architect showed as the starting point is not the most remote point. (He'll still satisfy the allowed 200-foot maximum, but the distance from the most remote point isn't 44 feet, it's more like 90 feet.)

To be honest, I blame it on the architecture schools. They don't teach students to design to code. In theory, building codes are a required part of the curriculum in order for a school of architecture to be accredited. Unfortunately, although they all say they teach codes, they only pay lip service to it. It's just not important to them.



*NanoCAD 5.0 is a several-versions old copy that the company distributes free to introduce people to NanoCAD as an alternate to AutoCAD. It's completely free and may be used for commercial purposes. In a municipal department of building inspection we have little use for a CADD program and no budget for CADD software, but the IT department was willing to install it on my computer for whenever I might need to sketch something. I have already used it twice this year: once to create a schematic plan of an existing building to document why the egress doesn't meet code now and didn't meet it when it was constructed, and once to generate a sketch to send an applicant's out-of-state architect to illustrate the code violation in a condition we found in field inspections of an interior alteration project for which they are the architects of record. It doesn't read .dwg files created by AutoCAD newer than about ten (or so) years ago, but it does create drawings that can be opened by AutoCAD, and it will open AutoCAD files if the creator saves them back to an earlier format.

 

[walker.t]

it has become the norm in this state for architects to provide an egress diagram. It's usually one of the first sheets in the drawing set, in with the 'G' or 'A0-xxx' drawings. That's where we find the depiction of the exit access path and distance, the door sizes and capacities, the room/space use classifications and occupant loads, etc. Once in awhile they also show the accessibility approach clearances at doors.

I’ve heard of these referred to as “life safety plans” and “code compliance plans.”

You describe some pretty big errors on those plans. I recently reviewed a life safety plan from the Archicad architect I mentioned above, he didn’t show detailed information on the doors such as clear width or capacity. His exit access travel distance was not to the most remote point in the space. He didn’t seem to put much effort into the drawing for whatever reason.

To be honest, I blame it on the architecture schools. They don't teach students to design to code. In theory, building codes are a required part of the curriculum in order for a school of architecture to be accredited. Unfortunately, although they all say they teach codes, they only pay lip service to it. It's just not important to them.

I agree with your comment about accreditation. Schools are probably expecting firms to teach the code. The National Council of Architectural Registration Boards (NCARB) says that passing the licensing exam requires education, experience, and additional study by the candidate - so NCARB is probably expecting firms to recognize deficiencies in their interns’ knowledge and teach them what’s missing. Then finally the candidate who is preparing to take the licensing exam has to access themselves and determine what they need to learn on their own.

 

[Yankee Chronicler]

I used to know my state's licensing board representative to the NCARB and NAAB (National Architectural Accrediting Board). (He has since rertired, moved out of state, and may no longer be with us.) I had this argument with him, and he adamantly insisted that the NAAB requires architecture school curricula to include codes, as a prerequisite to accreditation. And yet even licensed architects, who theoretically have survived the intern development program and passed a professional examination, still seem generally to be clueless on this stuff. As a licensed architect myself, I find it distressing.

 

[walker.t]

he adamantly insisted that the NAAB requires architecture school curricula to include codes, as a prerequisite to accreditation.

I wonder just what they mean by “include codes” and how they confirm that when they go back to review the school to confirm it is still meeting the accreditation requirements. Part of that probably looks at what books are required for classes, the school can have a class that requires Ching’s Building Codes Illustrated but that doesn’t mean there is any significant discussion of the matter.