Alterations affecting an area containing a primary function.

[Mr. Inspector]

2018 IEBC 305.7
Adding new truck docks to one side of warehouse. Plan indicate that this existing warehouse has existing accessible routes complying with code.
1. Some things in the rest rooms that don't comply with accessibility codes. Not sure if this matters because the things in the rest room (height of lavatories and mirrors to high) are not an accessible route. I am not sure because the code lets them spend at least 20% on the toilet facilities if the route is not fully accessible.
2. The code says route not routes. If there was more than one accessible route when the building was built does only one route need to comply?
3. Will I need to walk around this whole million plus sq ft warehouse to check all the accessible routes to all toilet rooms and drinking fountains? (my knee hurts just thinking about this)

 

[arwat23]

1. Not all toilet facilities or drinking fountains need to be accessible, depending on the design of the space. However, if they are required be be accessible (per IBC), then they should be accessible unless the 20% exception applies or they serve an area that is not a area of primary function.

2. This I'm not sure of. In California, we're required to have the primary entrance to a building or facility, toilet facilities, and drinking fountains that serve the area of alteration be accessible. If a restroom serves the area, then it needs to be on an accessible route (with some exceptions). Not sure what the layout of your building is, but if IEBC works similarly to CBC/ADAS, I would assume multiple interior routes may be required to be accessible. But again, I'm not completely sure how IEBC handles this.

3. Only routes to toilet accessible toilet rooms and drinking fountains that serve the area of primary function that this alteration is happening at and then only those the 20% exception doesn't apply to.

 

[Yankee Chronicler]

The altered area is the area where the new truck dock is being installed. Section306.7.1 of the IEBC says:

306.7.1 Alterations affecting an area containing a primary
function. Where an alteration affects the accessibility to, or
contains an area of primary function, the route to the primary
function area shall be accessible. The accessible route to the
primary function area shall include toilet facilities and drinking
fountains serving the area of primary function.

You only need to be concerned about one route to the altered area containing a primary function. But, per the code, the accessible route includes the toilet facilities serving the [affected] area of primary function.

So, if the toilet rooms serving the loading area are not 100% accessible, unless they spend 20% of the project cost on other accessibility upgrades, they should spend their 20% on fixing whatever about those particular toilet rooms isn't accessible (per A117.1).

 

[Mr. Inspector]

1. There are toilet rooms in the offices that have an accessible idem wrong but may also serve the warehouse, I can't be sure. There is nothing to keep the people in the warehouse from using them. They are the first rooms you get to when going from the warehouse through a door to the office area and seems to be larger than the office area would need, and the warehouse workers need to go by them when entering the warehouse. There are other toilet rooms located in the warehouse too. How could I be sure if they also serve the warehouse too.?

2. There are no drinking fountains. Since the accessible codes don't require them, and there is no increase of occupants, only that they be accessible if there is any, am I right that I can't require them? There is a place where it looks like there may have been two at one time but replaced with a large, bottled water dispenser (the kind where they deliver a large bottle of water).

3.Had this problem a few times when the architect said the accessible route is fully accessible at a existing building plan review and they are not when doing a final inspection. This speeds up the plan review but stalls things up at the final inspection. Even if I check out this out before the final inspection and tell the contractor this can be a problem because nothing gets done towards this. The contractors seem to just care about getting what they are getting paid to do, not the C. O. Any suggesting's?

 

[Sifu]

I am conflicted that adding an overhead door affects or contains an area of primary function. If the dock doors are for trucks to back up to, and there is no pedestrian door it makes me wonder about the difference between an OHD and a window, which the code excepts. Also, 306.7.5 ('21) puzzles me. It wouldn't require an entrance to be accessible if there are other accessible entrances, "unless" it is considered an alteration to an area of primary function. It seems like the language here means there are times when an entrance (pedestrian loading dock door? Overhead loading dock door?) would not be considered an alteration to an area of primary function. Commentary seems to tell us when an entrance would be required to be accessible, which is when the entrance is part of the route to the primary function. So the opposite would be when an entrance is not part of the route to the primary door. I question how the OHD's affect the route to primary function. Beyond that, a service entrance is not required to be accessible. Don't crucify me for this opinion, it is just a subjective approach to the scoping, which the code admits this subject is. (❖ Primary function areas contain the major activities for the building or space. Determination of what constitutes a primary function space can be somewhat subjective)

But I digress. If you and the consensus on the forum is that this is an alteration affecting or containing an area of primary function I would follow the code as written. I would consider it to be one route (singular) to accessible toilet rooms that serve the primary function. I wouldn't get hung up on which toilet rooms are designated to serve the primary function.

 

[Mr. Inspector]

I guess I should have detailed what the alteration was. The overhead doors were already there. They are cutting out the floors to build in 65 dock levelers one side of the building. I'm sure anyone would agree that the warehouse portion of a warehouse would be a primary function.
Definition in the 2018 IEBC:
[A] ALTERATION. Any construction or renovation to an
existing structure other than a repair or addition.

Do you mean that if this warehouse has 4 men's and women's toilet rooms only one man's and one women's toilet room will need to comply as an accessible toilet room be required?

Section 306.7 is confusing to me, but do I know "primary function" is not singular because you could have more than one area of primary function being worked on at the same time ( this warehouse has a firewall down the middle but the alterations are on both sides so it has two areas of primary function being altered) and the code not only talks about an alteration that affects the "accessibility" to area of primary function but also any alterations that are "contained" an area of primary function.

But I am not sure about is if the word "route" in "the route to the area(s) of primary function" in the second sentence is singular or could also be plural when it comes down to accessible entrances (IBC requires 60% of entrances to be accessible in new buildings). But where it says "The accessible route to the primary function area(s) shall include toilet facilities and drinking fountains serving the area(s) of primary function", that are having alterations, toilet facilities and drinking fountains are plural which would make me think that "all" of the toilet rooms and drinking fountains that serve the area of primary function are required to be accessible including "all" the routes to them from the area(s) of primary function.

306.7 Alterations affecting an area containing a primary
function. Where an alteration affects the accessibility to, or
contains an area of primary function, the route to the primary
function area shall be accessible. The accessible route to the
primary function area shall include toilet facilities and drinking
fountains serving the area of primary function.

 

[Mr. Inspector]

3 men's and women's rooms and 3 drinking fountains serve the area containing the primary function and there are 3 entrances. Does the IEBC require all the restrooms, drinking fountains and all the entrances to be accessible or just one?

 

[Yankee Chronicler]

I would be concerned only about the men's and women's toilet rooms closest to the part of the building being altered. If ALL you are doing as adding a dock leveler somewhere in a 300,000 s.f. warehouse, although the entire warehouse includes the primary function of warehousing, only the area around the new dock leveler is the altered area containing a primary function.

But -- if the toilet rooms nearest to the new dock leveler aren't accessible but there are accessible men's and women's toilet rooms in the warehouse, it could be argued that nothing more need be done.

 

[Mr. Inspector]

It's an at least a million sq ft. warehouse. The work is along the whole long side of the building, so it would be close to everything in the building.

Are you saying I should not be concerned with accessible entrance(s) and drinking fountain(s)?

Not sure what the cost of the job but it must me at least $500.000.

 

[Yankee Chronicler]

It's an at least a million sq ft. warehouse. The work is along the whole long side of the building, so it would be close to everything in the building.

Are you saying I should not be concerned with accessible entrance(s) and drinking fountain(s)?

Not sure what the cost of the job but it must me at least $500.000.

Without seeing the plans I can't comment any more than I have, except to pint out that the code says "the" accessible route (singular, not plural). So if there is one compliant accessible route to the area being altered, that's probably enough.

The language of IEBC 306.7 then says "The accessible route to the primary function area shall include toilet facilities and drinking fountains serving the area of primary function." It doesn't say "all" toilet facilities and drinking fountains that might possibly serve the altered area containing a primary function. Remembering that the ADA, and thus by extension the accessibility requirements in the building codes, is at heart anti-discrimination legislation, it's perhaps logical to look at what the code says about toilet facilities in general: the general rule is no more than 500 feet and one story of vertical travel.

From the original question, I wasn't envisioning a million square feet, and I thought the scope was installing one new dock leveler. With this new (to me) information, I'm inclined to think that you need to look at all toilet rooms that are within 500 feet of any part of the altered area.

I began to wonder if dock levelers even constitute an alteration, but I guess they do. From the 2021 IEBC Commentary:

ALTERATION. Any construction or renovation to an
existing structure other than a repair or addition.

Commentary:

**The code utilizes this term to reflect construction operations

intended for an existing building, but not in the
scope of an addition or repair (see the definitions of
“Addition” and “Repair”).

So then I looked at the exceptions to IEBC 306.7.1. 306.7.1 says:

306.7.1 Alterations affecting an area containing a primary
function. Where an alteration affects the accessibility to, or
contains an area of primary function, the route to the primary
function area shall be accessible. The accessible route to the
primary function area shall include toilet facilities and drinking
fountains serving the area of primary function.

You wrote that the route to the altered area is accessible, but some of the toilet rooms are not. Since 306.7.1 defines the accessible route as including toilet facilities and drinking fountains serving the area of primary function, that's where the question arises. It doesn't say the "altered" primary function area, but that's the way I have always approached it. Especially if they are using the work area method, and the work area is defined as less than the total area of the building, I would look at those toilet rooms that are closest to the defined work area as being the toilet rooms that "serve" that area. This means there should be 100% accessible toilet facilities within 500 feet of any part of the work area. (If they aren't following the work area method of IEBC compliance, this isn't of much help.)

Next I would look at the exceptions to IEBC 306.7.1. Exception #1 is the 20% rule:

1. The costs of providing the accessible route are not
required to exceed 20 percent of the costs of the
alterations affecting the area of primary function.

If they are adding loading docks along an entire side of a million square foot building, it would seem that the cost of replacing a few toilet room accessories to satisfy accessibility would be a drop in the bucket. They could probably add a couple of brand new toilet rooms without exceeding the 20% threshold.

I looked at the other four exceptions to see if any of them might be a get out of jail free card, but I don't think so.

I would like to correct one statement from your original post:

I am not sure because the code lets them spend at least 20% on the toilet facilities if the route is not fully accessible.

The code doesn't "let" them spend at least 20% on the accessible toilet facilities. The code requires that the accessible route, including the toilet facilities and drinking fountains, be accessible. If they are not already 100% accessible, the code REQUIRES that they spend AT LEAST 20% on making the accessible route (including the toilet facilities and drinking fountain) accessible.

 

[Mr. Inspector]

Thanks for your thoughts.
I will let them how to figure out how the spend the 20%. If they want to spend it on more than one accessible route or toilet I won't care. I the y only want to fix one accessible route and one toilet room before they use up the 20% I will have to look into it more.

I am thinking on my final inspection if I should spend a long time going over the whole building and list all the things that need to be upgraded to make the accessible route, drinking fountains and toilet rooms 100% fully accessible since the plans say that it is already fully accessible or since I know already that a couple things do not comply because I used the toilet room once that I just should report that the building does not comply to 2018 IEBC 305.7 and let the architect go through the whole building and figure it out themself. I am sure they would miss somethings and hold up the C. O. We are a 3rd party for profit company, and I don't think I am obligated to spend a lot of time going over the whole building before the architect gives us plans for the repairs.

What would you do Yankee?

 

[Yankee Chronicler]

What would you do Yankee?

Since you know that at least one toilet room is not 100% accessible, if the plans say they all ARE 100% accessible I would inform the architect that the drawings are incorrect and ask them to revise the plans. Considering the size of the building and the probability that there are multiple routes from the accessible entrances to the area where the new dock levelers are being installed, I would ask the architects to show on the drawings what they consider to be the accessible entrance serving the loading docks (most likely a rear or employee entrance, not the front entrance), what they consider to be the accessible route (or routes) from the accessible entrance to the loading dock area, and to designate which toilet rooms they consider to be the ones serving the work area. (Keeping in mind the general rule that a person should not have to travel more than 500 feet to reach a toilet room.) I doubt a million square foot warehouse qualifies for unisex toilets, so you're probably looking at at least one male toilet room and one female toilet room.

FWIW, I don't agree but our state building inspector has ruled that the 500 feet to a toilet room can include putting the toilet room(s) in a separate building. We're currently looking at two new structures that will have NO toilet facilities, and which be served by existing toilet rooms in other buildings on the same property. (And the architects are pushing back because we're asking for documentation that those toilet rooms are accessible and that there is an accessible route between the buildings.) Some people don't know when to shut up.

 

[Mr. Inspector]

Thanks, Yankee, I will consider this. But I would call this an industrial occupancy which the 2018 IBC has an exception which can exceed the 500' travel distance.
But I agree with your state building inspector that toilet rooms can be in a different building. the code does not say you can't.
I let a snack bar at a baseball field have a separate building for toilet rooms and the same at a public swimming pool and an auto repair garage at a used car lot use their sales office building for toilet rooms and multiple self-storage buildings site use a separate office building for toilet rooms.

 

[Yankee Chronicler]

Thanks, Yankee, I will consider this. But I would call this an industrial occupancy which the 2018 IBC has an exception which can exceed the 500' travel distance.

You called it a warehouse, I didn't. I wouldn't classify a warehouse as Industrial.