Alterations and Accessibility

[TimNY]

Another work classification thread from me.. Check my thinking and let me know what you think.

Existing A-2 bar/restaurant proposes PV panels, new generator and replace A/C unit on flat roof. Small flat roof, PV panels will cover about 75%, a/c unit and generator on the remaining roof.

They propose removing all roof framing and installing new roof rafters, sheathing, rubber roof.

Not really sure which was first, chicken [new load on roof] or egg [roof framing in poor condition].

What I see:

1. A/C Unit - Alteration - Level 1 (removal and replacement of equipment that serves the same purpose)

2. PV Panels - Alteration - Level 2 (extension of the electrical system/ installation of addl equipment)

3. Generator - same as above

4. New roof material (excluding framing) - Alteration - Level 1 Reroofing

Roof framing.. "where addition or replacement of equipment results in additional dead loads, structural components.. shall comply". Alteration - Level 1?

Now, would replacing the roof/ceiling assembly over an entire premises affect an area containing a primary function? Primarily this is roof work; the roof is certainly not an area containing a primary function.

The removal of the roof framing does incidentally cause the removal of the ceiling, but I am thinking this is incidental and therefore would not trigger the accessibility requirements.

Thoughts?

 

[mtlogcabin]

Now, would replacing the roof/ceiling assembly over an entire premises affect an area containing a primary function?

No

PRIMARY FUNCTION. A primary function is a major activity for which the facility is intended. Areas that contain a primary function include, but are not limited to, the customer service lobby of a bank, the dining area of a cafeteria, the meeting rooms in a conference center, as well as offices and other work areas in which the activities of the public accommodation or other private entity using the facility are carried out. Mechanical rooms, boiler rooms, supply storage rooms, employee lounges or locker rooms, janitorial closets, entrances, corridors and restrooms are not areas containing a primary function.

and neither is the roof

 

[TimNY]

and neither is the roof

Yes I agree. On the PV/AC?generator there is no question. The point of interest is removing the roof structure also removes the ceiling over the entire dining area. However, the intent is not to remove the ceiling, but rather to strengthen the roof system.

 

[mtlogcabin]

Removing a celing does not alter the primary function area. I believe you would have to alter walls, doors and flooring before you are affecting the primary function area. Nobody occupies a ceiling area.

 

[TimNY]

Removing a celing does not alter the primary function area. I believe you would have to alter walls, doors and flooring before you are affecting the primary function area. Nobody occupies a ceiling area.

Agreed. Just like knowing other people agree as well

 

[steveray]

Agreed......not affecting

 

[Frank]

Redoing the ceiling of the primary function rooms would be an alteration to the primary function space.

 

[TimNY]

Redoing the ceiling of the primary function rooms would be an alteration to the primary function space.

Ah, and that's why I began the thread

Would not the ceiling be work incidental to the roof work rather than an alteration of the primary function space?

 

[mark handler]

Would not the ceiling be work incidental to the roof work rather than an alteration of the primary function space?

i KNOW YOU DON'T WANT TO HEAR FROM ME, BUT YES.

 

[mtlogcabin]

Redoing the ceiling of the primary function rooms would be an alteration to the primary function space.

No it is not

R & R a ceiling does not reconfigure the space. That said once the ceiling is open that would be the time to look at Chapter 46 2009 IFC and install anyyhing that may not be compliant

WORK AREA. That portion or portions of a building consisting of all reconfigured spaces as indicated on the construction documents. Work area excludes other portions of the building where incidental work entailed by the intended work must be performed and portions of the building where work not initially intended by the owner is specifically required by this code.

 

[mark handler]

The fire code does not "govern" over the Building code. (Chapter 46 2009 IFC)

 

[mtlogcabin]

The fire code does not "govern" over the Building code. (Chapter 46 2009 IFC)

Never said it did but the FM can require compliance with Chapter 46 at any time non compliance is found. Would be a shame to call him in at the final and he says install more emergency illumination or exit lights of notification devices and the contactor has to open up the ceiling to do it.

2009 Existing Building Code IFC SECTION 102

APPLICABILITY

102.1 Construction and design provisions.

The construction and design provisions of this code shall apply to:

1. Structures, facilities and conditions arising after the adoption of this code.

2. Existing structures, facilities and conditions not legally in existence at the time of adoption of this code.

3. Existing structures, facilities and conditions when required in Chapter 46.

4. Existing structures, facilities and conditions which, in the opinion of the fire code official , constitute a distinct hazard to life or property.

2009 IFC SECTION 102

APPLICABILITY

102.1 Construction and design provisions.

The construction and design provisions of this code shall apply to:

1. Structures, facilities and conditions arising after the adoption of this code.

2. Existing structures, facilities and conditions not legally in existence at the time of adoption of this code.

3. Existing structures, facilities and conditions when required in Chapter 46.

4. Existing structures, facilities and conditions which, in the opinion of the fire code official , constitute a distinct hazard to life or property.

 

[TimNY]

i KNOW YOU DON'T WANT TO HEAR FROM ME, BUT YES.

Actually, Mark I think we usually agree on things. Violent agreement, but agreement none the less

 

[brudgers]

Now, would replacing the roof/ceiling assembly over an entire premises affect an area containing a primary function? Primarily this is roof work; the roof is certainly not an area containing a primary function.

The roof/ceiling system isn't an area of the building, it is a component of the area it covers.

If they are replacing the roof structure over 100% of the building then they are affecting changes to all the areas of the building, including primary areas.

Roofing work typically means replacing roof finishes and substrates, not entire structural systems.

 

[TimNY]

Good points.

As I dwell on every letter of the code, I just noticed that 605.2 is titled "alterations affecting an area containing a primary function", and reads "where an alteration contains an area of primary function"

Nowhere in that section does it actually say "work area". I had really been depending on the definition of "work area" as quoted by mtl in post #10.

 

[mtlogcabin]

Why are you using the EBc instead of Chapter 34 of the IBC?

403.1 Scope.

Level 1 alterations include the removal and replacement or the covering of existing materials, elements, equipment, or fixtures using new materials, elements, equipment, or fixtures that serve the same purpose. This would be the ceiling

404.1 Scope.

Level 2 alterations include the reconfiguration of space, the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment. If they reconfigure the space then it is a work area?

The most you could require would be 20% of the ceiling cost for the accessible route. Is it already accessible if so what work are you going to require to be done to the ceiling to meet accessibility. Unless you have some local or state laws that require more don't overthink it

 

[Alias]

Removing a celing does not alter the primary function area. I believe you would have to alter walls, doors and flooring before you are affecting the primary function area. Nobody occupies a ceiling area.

My 2 cents -

If the new ceiling configuration matches the existing configuration, no trigger. Anything else would be a case by case basis for me.

Sue, in frozen CA

 

[brudgers]

The most you could require would be 20% of the ceiling cost for the accessible route. Is it already accessible if so what work are you going to require to be done to the ceiling to meet accessibility. Unless you have some local or state laws that require more don't overthink it

The 20% requirement is to remove architectural barriers within the facility, not just the elements which are proposed to be modified.

In other words, 20% of a simple reroof could be spent on accessible door levers and thresholds.

 

[steveray]

I don't think it is required in this instance, but I agree with Brudgers, it doesn't take much to get to 20% grab bars, lever hardware, ramp, an accessible spot at the bar...maybe even painting a parking spot...JMHO

 

[Jim B]

If the scope of work could be classified as a Level 1 alteration as per the IEBC, and the work area involved the ceiling contained within the primary function of the space (Office, Bank, Bar, etc...) then 20% above the scope of work budget, not to exceed this amount, should be spent toward upgrading the accessible routes. There is sort of a sub-definition to accessible routes to include toilet rooms and water foutains.

I know that the commentary is not code, but it states that it is the designers choice as to what to upgrade. So by adding up many small upgrades (adding lever door hardware, 10" bottom kick plates on doors, re-locating grab bars and dispensers in toilet rooms) may "eat up" a chunk of this amount when replacng a ceiling.

BTW: the ADA reflects this same concept:

2010 ADA Standards for Accessible Design

American With Disabilities Act

28 CFR 35.151

(b) Alterations.

(iii) Disproportionality.

(A) Alterations made to provide an accessible path of travel to the altered area will be deemed disproportionate to the overall alteration when the cost exceeds 20 % of the cost of the alteration to the primary function area.

(B) Costs that may be counted as expenditures required to provide an accessible path of travel may include:

(1) Costs associated with providing an accessible entrance and an accessible route to the altered area, for example, the cost of widening doorways or installing ramps;

(2) Costs associated with making restrooms accessible, such as installing grab bars, enlarging toilet stalls, insulating pipes, or installing accessible faucet controls;

(3) Costs associated with providing accessible telephones, such as relocating the telephone to an accessible height, installing amplification devices, or installing a text telephone (TTY); and

(4) Costs associated with relocating an inaccessible drinking fountain.

 

[TimNY]

it doesn't say "alter" the area, it says "affect" the area.

My question at the moment is to require 20% or zero. Just because you do work at a stie, you are not automatically required to expend 20% on accessibility. My quandary is whether or not this work falls into the category of work that requires the 20% expenditure. I am not invested either way, I just want to make the correct decision.

NY does not have a Chapter 34 in the building code.

 

[mtlogcabin]

Not really sure which was first, chicken [new load on roof] or egg [roof framing in poor condition].

Meet with the DP let him determine in writing the roof framing is in poor condition and needs replaced. 402.3 comes into play.

104.2.1 Preliminary meeting.

When requested by the permit applicant or the code official, the code official shall meet with the permit applicant prior to the application for a construction permit to discuss plans for the proposed work or change of occupancy in order to establish the specific applicability of the provisions of this code.

Exception: Repairs and Level 1 alterations.

104.2.1.1 Building evaluation.

The code official is authorized to require an existing building to be investigated and evaluated by a registered design professional based on the circumstances agreed upon at the preliminary meeting to determine the existence of any potential nonconformance with the provisions of this code.

402.3 Related work.

Work on nondamaged components that is necessary for the required repair of damaged components shall be considered part of the repair and shall not be subject to the provisions of Chapter 6, 7, 9 or 10.

 

[Jim B]

Definition: affect: "produce an change in" area of primary function. Then yes, there is a change in the area of primary function. 20% is applicable

 

[peach]

sometime using existing building code benefits the owner (who is ultimately responsible for the structure - not the building code official)..

not always..