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California Accessible Means of Egress for an Existing Building

A

arwat23

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Joined
Sep 19, 2023
Messages
106
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California
I'm working on a few interior TI projects where the means of egress is causing me and some of the designers here to butt heads. I and others on my team have different interpretation on two seemingly contradictory sections of code related to accessible means of egress. Can anyone provide their interpretation of these sections of code?

CBC 1009.1: ... Accessible spaces shall be provided with not less than one accessible means of egress. Where more than one means of egress is required by Section 1006.2 or 1006.3 from any accessible space, each accessible portion of the space shall be served by accessible means of egress in at least the same number as required by Sections 1006.2 or 1006.3. In addition to the requirements of this chapter, means of egress, which provide access to, or egress from, buildings for persons with disabilities, shall also comply with the requirements of Chapter 11A or 11B as applicable.

CBC 11B-207.1:
Means of egress shall comply with Chapter 10, Section 1009 and Section 11B-207.
Exceptions:
...
3. Accessible means of egress are not required to be provided in existing buildings.

My question is, assuming my understanding of these two sections is correct, which section takes priority? 1009.1 clearly states that an accessible means of egress is required to some degree, but 11B-207.1 has an exception for existing buildings. Both sections are adopted by DSA-AC, which makes me think I'm missing something obvious or just really overthinking this.
 
The IEBC (the ICC model version) does not require accessible means of egress in existing buildings -- period.

306.7.2 Accessible means of egress. Accessible means of
egress required by Chapter 10 of the International Building
Code are not required to be added in existing
facilities.
Click to expand...

I note that it says accessible means of egress are not required to be added. In line with my understanding of the IEBC in general (i.e. "Don't make it worse"), I take this to mean that you can't eliminate existing accessible means of egress, but you don't have to create any where they don't already exist.
 
Yankee Chronicler said:
The IEBC (the ICC model version) does not require accessible means of egress in existing buildings -- period.



I note that it says accessible means of egress are not required to be added. In line with my understanding of the IEBC in general (i.e. "Don't make it worse"), I take this to mean that you can't eliminate existing accessible means of egress, but you don't have to create any where they don't already exist.
Click to expand...
But if you do create new egress...it has to be accessible...
 
Yankee Chronicler said:
The IEBC (the ICC model version) does not require accessible means of egress in existing buildings -- period.



I note that it says accessible means of egress are not required to be added. In line with my understanding of the IEBC in general (i.e. "Don't make it worse"), I take this to mean that you can't eliminate existing accessible means of egress, but you don't have to create any where they don't already exist.
Click to expand...
The only issue is CEBC / IEBC isn't adopted by DSA-AC. DSA-AC is the authority over public and commercial accessibility in CA and a commercial TI project falls under their scope, so since the CEBC isn't adopted by that agency (and there are multiple references in CEBC that simply state that CBC 11A or 11B should be followed over the CEBC), that section means nothing.

At least, that's how it's been described to me by someone who works at the Division of the State Architect (they just told me to ignore CEBC for accessibility).

I do agree about not making things worse though. That makes complete sense.
 
steveray said:
But if you do create new egress...it has to be accessible...
Click to expand...
Unless I'm reading code wrong, no, it does not. CBC (and I believe IBC, although CA has amended this section) 1009.1 states that only the exists required under 1006.2 and 1006.3 are required to be accessible. Any additional, non-required exit does not need to be accessible, although those exits need to comply with certain signage requirements per 1009.10(1).

Perhaps I'm missing something that changes this?
 
arwat23 said:
Unless I'm reading code wrong, no, it does not. CBC (and I believe IBC, although CA has amended this section) 1009.1 states that only the exists required under 1006.2 and 1006.3 are required to be accessible. Any additional, non-required exit does not need to be accessible, although those exits need to comply with certain signage requirements per 1009.10(1).

Perhaps I'm missing something that changes this?
Click to expand...
But if you are adding new egress...It IS likely REQUIRED.....Most folks don't do it willy nilly...
 
steveray said:
Ask a Cali person, but I would say 11B-207.1 gives you the pass...
Click to expand...
That's how I read it too. Thanks for the info!

Out of curiosity, does IBC / IEBC require all new exits to be accessible? I don't do much work outside of CA, so I'm curious how the I code address this.
 
steveray said:
But if you are adding new egress...It IS likely REQUIRED.....Most folks don't do it willy nilly...
Click to expand...
Is there a section that specifically addresses that? If I'm wrong, I'm wrong, and that's fine. I just don't see anything in code that requires that, although (as always) I could easily be missing something.

All I see is that required exit doors need to be accessible. Anything in excess does not need to be accessible.
 
arwat23 said:
Is there a section that specifically addresses that? If I'm wrong, I'm wrong, and that's fine. I just don't see anything in code that requires that, although (as always) I could easily be missing something.

All I see is that required exit doors need to be accessible. Anything in excess does not need to be accessible.
Click to expand...

801.4 Compliance​

New construction elements, components, systems and spaces shall comply with the requirements of the International Building Code.
 
arwat23 said:
What section in IBC requires ALL new exit doors to be accessible?
Click to expand...
Not all....just the first 2 required:

1009.1 Accessible Means of Egress Required​

Accessible means of egress shall comply with this section. Accessible spaces shall be provided with not less than one accessible means of egress. Where more than one means of egress is required by Section 1006.2 or 1006.3 from any accessible space, each accessible portion of the space shall be served by not less than two accessible means of egress.

In my experience, I have never seen someone add a third required exit...It is usually one of the first 2....
 
steveray said:
Not all....just the first 2 required:

1009.1 Accessible Means of Egress Required​

Accessible means of egress shall comply with this section. Accessible spaces shall be provided with not less than one accessible means of egress. Where more than one means of egress is required by Section 1006.2 or 1006.3 from any accessible space, each accessible portion of the space shall be served by not less than two accessible means of egress.

In my experience, I have never seen someone add a third required exit...It is usually one of the first 2....
Click to expand...
I'm working on a project with seven exterior exit doors. Only two are required by code. Just to confirm I understand correctly, you're interpretation of that section is that only the required exit doors need to be accessible? The other exits that are not "required" do not need to be accessible?

I agree with that, but I'm confused about you saying all new exits are required to be accessible.
 
Last edited:
Yikes said:
Maybe need a clearer distinction as to whether (for example) adding a new exit door into an existing wall is considered an “alteration”, or is considered a type of “new construction”?
Click to expand...
Doesn't matter 801 is from level 2 alterations...

603.1 Scope​

Level 2 alterations include the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment, and shall apply where the work area is equal to or less than 50 percent of the building area.

New work in an existing building meets new code....Generally....
 
steveray said:
Doesn't matter 801 is from level 2 alterations...

603.1 Scope​

Level 2 alterations include the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment, and shall apply where the work area is equal to or less than 50 percent of the building area.

New work in an existing building meets new code....Generally....
Click to expand...
Part of the challenge with this thread is that the original post was very California-specific, and the responses are discussing code sections that were not adopted by California:

1707935948458.png
 
steveray said:
Sorry...I'll stop talking...
Click to expand...
On the contrary, I appreciate what you are saying, because the discussions about the (non-California) IEBC are helping to revealing a vulnerability in how California adopted the changes 2018 IBC without also adopting the complementary language in the 2018 IEBC.
 
steveray said:
I believe it does in 801.4 from post #10...Do you disagree...?
Click to expand...

Yes, I disagree. I have always regarded that as meaning that the construction of new elements has to be done in accordance with the current code for new construction. However, the IEBC has a blanket statement that accessible means of egress are not required in existing buildings. That's my bright line. If it's an existing building, it doesn't need accessible means of egress. (See post #2 for the code citation.)
 
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