ADA Upgrades vs. Change of Occupancy Class

[Mr. Inspector]

PA L&I says the Accessible route only needs to go to the rest room door if there is a rest room and to drinking fountians if there is any.

If I made them put in new restrooms I wouldn't keep my job very long.

 

[TimNY]

PA L&I says the Accessible route only needs to go to the rest room door if there is a rest room and to drinking fountians if there is any. If I made them put in new restrooms I wouldn't keep my job very long.

Interesting interp.. I know the commentary is not code, but in reading the commentary it is clear the intent is to provide accessible bathrooms. I don't know why you would provide an accessible route to an inaccessible bathroom.

EDIT: they are required to spend 20% on accessibility.. you are not making them put in accessible bathrooms., you are assuring they spend 20%. If they spend 20% elsewhere, that's fine. However, they don't get to spend 5% because the only thing left to upgrade is the bathrooms.

 

[Jim B]

Rick18071, you may want to look at this link:

http://www.portal.state.pa.us/portal/server.pt?open=514&objID=553831&mode=2#34094

When an alteration contains or affects an area of primary function then IBC 2006, 3409.7 comes into play for 20% upgrades. For this section only there is sort of a sub definition: “accessible routes shall include toilet rooms and water fountains”.

PA L&I states that priority for the upgrades should include the 6 items listed in IBC 2006, 3409.4. This is only a recommendation as to where to spend the money. They never state that toilet rooms and water fountain are not required to be upgraded. You may want to call the PA L&I Accessibility Advisory Board to inquire about this.