Couple oddball accessibility questions.........

[JPohling]

I get the pleasure of reviewing many Casp produced accessibility surveys. These are clearly California facilities. They are typically produced by one company and I see a couple items that keep coming up on the reports that I cannot corroborate the code necessity of the violations that are indicated. This is just a sample of two that are on my mind currently.

#1) The first "violation" I will discuss has to do with the paint stripes marking the accessible parking spaces. In this particular instance my accessible parking spaces are bound by a single curbs on one side and the shared access aisle on the other. The violation indicates that the stall needs a stripe on the side with the curb and the stripe should be "blue".

First question is do you believe that a stripe is needed in addition to the curb in order to define the space? And do you believe that this stripe needs to be blue.

Code sections 11B-502.2 is quoted. Code indicates that the space is to be "marked to define the width" For this condition I have seen numerous examples of only the curb being provided to mark the space as well as the much less seen curb painted blue. California code is silent about any color being used to mark the parking space. See 11B-502.1 and 502.2

California code is very specific about specifying the color blue to be used for the striping of the shared access aisle. 11B-502.3.3. "Blue painted borderline around the perimeter"

That is very clear. Blue marking is code required for the Access Aisle, but silent on the color of the actual space itself. We almost always see the striping between spaces being done in blue as well, but that seems to be a convenience for those striping. It may make some sense, but it does not seem to be required by code. What do you think?



#2) Here is another one that we see tagged a lot. This has to do typically with a building lobby and the primary double door exits. These are all typically all glass storefront/curtainwalls where the exit is obvious as there are 30 feet wide expanses of glass with double doors in the middle. The violation is typically to provide tactile exit signage at these doors.

CBC 1013.1 Exception #2 allows the elimination of exit signs in this condition if approved by the AHJ. Main exits and clearly identifiable.
CBC 1013.4 regarding the tactile exit signs indicate that the tactile signage is required on doors that are required to comply with 1013.1.

My thought is if the exit signs have been eliminated by AHJ approval then tactile exit signage would no longer be required either. What do you think?

 

[Joe.B]

Thanks for posting this. There is a lot of over-lap of various rules and regulations which can present potential conflicts, but I don't see it for question one. CA codes allow things to remain as-is if they still comply with the codes at the time they were built, but I don't think federal ADA standards are written that way... For question one I agree with you. If this were proposed in a plan set I'd it would not need a stripe if bordered by a curb.

That's specific for the access aisles, and as you said, the other required markings do not specify color. Same for 2019, 2016, and 2013. 2010 looks a lot different, but amounts to the same requirement. 2001 CBC also looks totally different, it's the last time CBC was based on the UBC, and I see no mention of paint color at all. Federal ADA also has no mention of blue color.

So where are they getting blue from? I think it's just a mistake. But, maybe there's some other guideline that I don't know about...

For question two I would be a lot more hesitant. I don't think an AHJ's determination is any protection for a lawsuit. Technically the AHJ has the authority to render interpretations, and many jurisdictions have an access appeals board to challenge rulings by the AHJ (authority from HSC 19957.5) but as I understand it neither of those matter if a lawyer can convince a judge or jury that there's a violation and someone has to pay.

 

[JPohling]

Thanks Joe! I agree on both counts. Typically I have no knowledge if the AHJ actually approved the installation without the exit signage. Someone needing the tactile signage may not be able to "clearly identify" the exit in any case. But I also do not know how they will find the tactile signage when needed. hopefully someone will guide them.

 

[ICE]

1013.1 Where required. Exits and exit access doors shall be marked by an approved exit sign readily visible from any direction of egress travel.
EXCEPTION:
1. Exit signs are not required in rooms or areas that require only one exit or exit access.
2. Main exterior exit doors or gates that are obviously and clearly identifiable as exits need not have exit signs where approved by the building official.

If you invoke exception #2 to 1013.1 the clear implication is that you have complied with 1013.1. If you have complied with 1013.1.....was that due to a requirement? Most assuredly, the answer to that question is yes. Furthermore, the AHJ can waive the exit sign if there's no mistaking the actual exit as in, it is visibly so. Tactile exit signs are required.

1013.4 Raised character and braille exit signs. Tactile exit signs shall be required at the following locations:

1. Each grade-level exterior exit door that is required to comply with Section 1013.1, shall be identified by a tactile exit sign with the word, “EXIT”.

2. Each exit door that is required to comply with Section1013.1, and that leads directly to a grade-level exterior exit by means of a stairway or ramp shall be identified by a tactile exit sign with the following words as appropriate:

2.1. “EXIT STAIR DOWN”
2.2. “EXIT RAMP DOWN”
2.3. “EXIT STAIR UP”
2.4. “EXIT RAMP UP”

3. Each exit door that is required to comply with Section1013.1, and that leads directly to a grade-level exterior exit by means of an exit enclosure or an exit passageway shall be identified by a tactile exit sign with the words, “EXIT ROUTE.”

4. Each exit access door from an interior room or area to a corridor or hallway that is required to comply with Section 1013.1, shall be identified by a tactile exit sign with the words “EXIT ROUTE.”

5. Each exit door through a horizontal exit that is required to comply with Section 1013.1, shall be identified by a sign with the words, “TO EXIT.”


As to how are vision impaired individuals are supposed to find the sign... I suppose you would have to ask them.

 

[Yikes]

For question #2:

If you invoke exception #2 to 1013.1 the clear implication is that you have complied with 1013.1.

1. Each grade-level exterior exit door that is required to comply with Section 1013.1, shall be identified by a tactile exit sign with the word, “EXIT”.

ICE, you nailed it!
Stated conversely, invoking exception #2 does not mean that the exit was not required to comply with 1013.1. It only describes HOW the exit complied.

 

[mark handler]

I get the pleasure of reviewing many Casp produced accessibility surveys. These are clearly California facilities. They are typically produced by one company and I see a couple items that keep coming up on the reports that I cannot corroborate the code necessity of the violations that are indicated. This is just a sample of two that are on my mind currently.

#1) The first "violation" I will discuss has to do with the paint stripes marking the accessible parking spaces. In this particular instance my accessible parking spaces are bound by a single curbs on one side and the shared access aisle on the other. The violation indicates that the stall needs a stripe on the side with the curb and the stripe should be "blue".

First question is do you believe that a stripe is needed in addition to the curb in order to define the space? And do you believe that this stripe needs to be blue.

Code sections 11B-502.2 is quoted. Code indicates that the space is to be "marked to define the width" For this condition I have seen numerous examples of only the curb being provided to mark the space as well as the much less seen curb painted blue. California code is silent about any color being used to mark the parking space. See 11B-502.1 and 502.2

California code is very specific about specifying the color blue to be used for the striping of the shared access aisle. 11B-502.3.3. "Blue painted borderline around the perimeter"

That is very clear. Blue marking is code required for the Access Aisle, but silent on the color of the actual space itself. We almost always see the striping between spaces being done in blue as well, but that seems to be a convenience for those striping. It may make some sense, but it does not seem to be required by code. What do you think?



#2) Here is another one that we see tagged a lot. This has to do typically with a building lobby and the primary double door exits. These are all typically all glass storefront/curtainwalls where the exit is obvious as there are 30 feet wide expanses of glass with double doors in the middle. The violation is typically to provide tactile exit signage at these doors.

CBC 1013.1 Exception #2 allows the elimination of exit signs in this condition if approved by the AHJ. Main exits and clearly identifiable.
CBC 1013.4 regarding the tactile exit signs indicate that the tactile signage is required on doors that are required to comply with 1013.1.

My thought is if the exit signs have been eliminated by AHJ approval then tactile exit signage would no longer be required either. What do you think?

CALIFORNIA ACCESS COMPLIANCE ADVISORY REFERENCE MANUAL

Access Compliance Reference Materials

www.dgs.ca.gov

 

[mark handler]

#2) Here is another one that we see tagged a lot. This has to do typically with a building lobby and the primary double door exits. These are all typically all glass storefront/curtainwalls where the exit is obvious as there are 30 feet wide expanses of glass with double doors in the middle. The violation is typically to provide tactile exit signage at these doors.

CBC 1013.1 Exception #2 allows the elimination of exit signs in this condition if approved by the AHJ. Main exits and clearly identifiable.
CBC 1013.4 regarding the tactile exit signs indicate that the tactile signage is required on doors that are required to comply with 1013.1.

My thought is if the exit signs have been eliminated by AHJ approval then tactile exit signage would no longer be required either. What do you think?

SECTION 1013
EXIT SIGNS
1013.4 Raised character and braille exit signs. Tactile exit signs shall be required at the following locations:
1. Each grade-level exterior exit door that is required to comply with Section 1013.1, shall be identified by a
tactile exit sign with the word, “EXIT”.
2. Each exit door that is required to comply with Section 1013.1, and that leads directly to a grade-level
exterior exit by means of a stairway or ramp shall be identified by a tactile exit sign with the following
words as appropriate:
2.1. “EXIT STAIR DOWN”
2.2. “EXIT RAMP DOWN”
2.3. “EXIT STAIR UP”
2.4. “EXIT RAMP UP”
3. Each exit door that is required to comply with Section 1013.1, and that leads directly to a grade-level
exterior exit by means of an exit enclosure or an exit passageway shall be identified by a tactile exit sign
with the words, “EXIT ROUTE”.
4. Each exit access door from an interior room or area to a corridor or hallway that is required to comply with
Section 1013.1, shall be identified by a tactile exit sign with the words “EXIT ROUTE”.
5. Each exit door through a horizontal exit that is required to comply with Section 1013.1, shall be identified
by a sign with the words, “TO EXIT”
Raised character and Braille exit signs shall comply with Chapter 11A, Section 1143A or Chapter 11B,
Sections 11B-703.1, 11B-703.2, 11B-703.3 and 11B-703.5.

IMPO Tactile signs are still required, because the door location may not be readily apparent to a visually impaired person. you may see the exit, but they may not.

 

[JPohling]

I think we are all in agreement on the tactile signage. One pesky detail remains on the parking areas. Who believes that a curb can "mark" the accessible space? who believes that a stripe is necessary to do that? Anyone think paining the curb blue is appropriate, although not necessarily code required.

I am fine with a non painted curb marking the parking space. I believe the perimeter of the shared aisle needs to be blue. the cross hatch striping can be blue or white, whichever provides the most contrast.

 

[Joe.B]

I think we are all in agreement on the tactile signage. One pesky detail remains on the parking areas. Who believes that a curb can "mark" the accessible space? who believes that a stripe is necessary to do that? Anyone think paining the curb blue is appropriate, although not necessarily code required.

I am fine with a non painted curb marking the parking space. I believe the perimeter of the shared aisle needs to be blue. the cross hatch striping can be blue or white, whichever provides the most contrast.

11B 502.1 ... Where parking spaces are marked with lines, width measurements of parking spaces and access aisles shall be made from the centerline of the markings.

If spaces always required lines then you wouldn't need this qualifying statement.