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Are A2 kitchens considered 1103.2.2 Employee Work Areas?

Section 804 applies more aptly to personal type kitchens like those found within a dwelling or a break room.

What I'd say is that you need to focus on 1104.3.1, as is required by 1103.2.2. Given this, I would then suggest that you have a doorway without a door at the detailed 3-ft opening. A minimum 36-in opening is required wherein the opening has a depth of more than 24-in per the Accessibility Code (404.2.2).

WI BC (2015 IBC) 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 1108.4.1.4, 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.

WI BC (2015 IBC) 1104.3.1 Employee Work Areas​

Common use circulation paths within employee work areas shall be accessible routes.
Exceptions:
  1. Common use circulation paths, located within employee work areas that are less than 1,000 square feet (93 m2) in size and defined by permanently installed partitions, counters, casework or furnishings, shall not be required to be accessible routes.
  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.
  3. Common use circulation paths, located within exterior employee work areas that are fully exposed to the weather, shall not be required to be accessible routes.

WI AC (2009 A117.1) - 404.2.2 Clear Width​

Doorways shall have a clear opening width of 32 inches (815 mm) minimum. Clear opening width of doorways with swinging doors shall be measured between the face of door and stop, with the door open 90 degrees. Openings more than 24 inches (610 mm) in depth at doors and doorways without doors shall provide a clear opening width of 36 inches (915 mm) minimum. There shall be no projections into the clear opening width lower than 34 inches (865 mm) above the floor. Projections into the clear opening width between 34 inches (865 mm) and 80 inches (2030 mm) above the floor shall not exceed 4 inches (100 mm).
EXCEPTIONS:
  1. Door closers and door stops shall be permitted to be 78 inches (1980 mm) minimum above the floor.
  2. In alterations, a projection of 5/8 inch (16 mm) maximum into the required clear opening width shall be permitted for the latch side stop.
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classicT said:
Common use circulation paths, located within employee work areas that are less than 1,000 square feet (93 m2) in size and defined by permanently installed partitions, counters, casework or furnishings, shall not be required to be accessible routes.
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Note that this exception (WI BC 1104.3.1, Exception #1) may apply, thereby exempting the kitchen from having an accessible route that allows for approach, entrance, and exiting of the work area.

Hard to say from the image provided, but I'd speculate that you are less than 1,000sf.
 
Ryan Schultz said:
With an A2, in a scenario like the following, the areas circled are considered 1103.2.2 Employee Work Areas and are not considered accessible kitchens per 804.2.1.
Therefore, the 40" min clearances outlined in 804.2.1 do not apply.
Would that be a correct interpretation?

View attachment 11853
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I would agree. That said, I think it would be a mistake to design a commercial kitchen that doesn't have the required access dimensions. Remember that, although employee work areas are generally exempt from need to be designed for universal access, if a qualified job candidate applies for a job and is the best candidate -- or if a current employee becomes disabled but is still able to perform the work with reasonable accommodation -- the employer is required under the ADA to provide the accommodation. That's usually not difficult in a typical office setting, but it could be a challenge in a kitchen.
 
Yes, a commercial kitchen is considered an employee work area, and needs an accessible path (door with clearances) to the area. After that the equipment itself is not required (in most states) to either be accessible or on an accessible path.
In California, CBC-11B has gone a step further and said that common circulation paths within employee work areas need to be accessible. In that scenario, if an aisle is serving more than one workstation area, then the aisle needs to be accessible.
 
mark handler said:
an office kitchen is a common space
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This made me curious, so I looked at the OP... the OP does not say that this is an office kitchen. To me it looks more like a small cafe. OP indicates an A-2 use; whereas a small break room type office kitchen would likely be an accessory use and classified as a Group B.
 
classicT said:
This made me curious, so I looked at the OP... the OP does not say that this is an office kitchen. To me it looks more like a small cafe. OP indicates an A-2 use; whereas a small break room type office kitchen would likely be an accessory use and classified as a Group B.
Click to expand...
I did not see the "With an A2..."

If it is a small café, it would also be a "B".
Whether it is a "B" or not does not effect the accessibility.
If it is a Commercial kitchen, it does not need to be accessible.
If it is a Kitchen in an office it does need to be accessible.
 
mark handler said:
I did not see the "With an A2..."

If it is a small café, it would also be a "B".
Whether it is a "B" or not does not effect the accessibility.
If it is a Commercial kitchen, it does not need to be accessible.
If it is a Kitchen in an office it does need to be accessible.
Click to expand...
Out of curiosity, why would a commercial kitchen not need to be accessible?
 
roxas said:
Out of curiosity, why would a commercial kitchen not need to be accessible?
Click to expand...
28 CFR Part 36, Appendix B to Part 36 - Analysis and Commentary on the 2010 ADA Standards for Accessible Design

206.2.8 of the 2010 Standards exempt common use circulation paths in employee work areas from the requirements of section 402 where it may be difficult to comply with the technical requirements for accessible routes due to the size or function of the area
Common use circulation paths within employee work areas that are less than 1,000 square feet and are defined by permanently installed partitions, counters, casework, or furnishings are exempt. Kitchens in quick service restaurants, cocktail bars, and the employee side of service counters are frequently covered by this exception
 

2010 ADA Standard 804.2, [Kitchens and Kitchenettes], Clearance, Exception, states, “Spaces that do not provide a cooktop or conventional range shall not be required to comply with [Standard] 804.2.” In other words, the cook-top or range is the trigger for when the kitchen or kitchenette ADA laws apply.​

 
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