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Deck steps for spa

Mr. Inspector

Mr. Inspector

SAWHORSE
Joined
Nov 28, 2009
Messages
4,107
Location
Poconos/eastern PA
From the 2015 ISPSC:
Definitions
Deck. An area immediately to or attached to a pool or spa that is specifically constructed or installed for sitting, standing, or walking.

306.4 Deck steps handrail required. Public pool and spa deck steps having three or more risers shall be provided with a handrail.

This packaged spa that sits on a deck has 3 risers inside.. It also has exterior steps that fold out from the side of the spa.

Is the handrail required for the exterior and the interior stairways?
Or the interior handrail is not needed because when you use the interior steps you are all ready off the deck?
 
While I am not familiar with the 2015 ISPSC, it seems to me that the deck steps that is called out could be the steps leading to the deck rather than steps from the deck into a spa. Is there a code manual for the 2015 ISPSC?

2015 ISPSC requires hand rail for stairs with three or more risers and that is at odds with the CRC:

R311.7.8 Handrails.
Handrails shall be provided on not less than one side of each flight of stairs with four or more risers.
 
Not using CRC here. The ISPSC is code here and it is stricter so I go with stricter. Never thought of it as meaning the stairway to go onto the deck from the ground but only for the stairway to get from deck to pool or spa. Maybe it means both? Clear as mud.
 
Given that the spa comes with steps that fold down for entry to the spa and there is a listing organization that evaluated the spa, there is precedence to allow it. And if the spa did not come with fold down stairs a step ladder would solve the issue.

Then there is the ISPSC and wet steps to consider.

We need to hear other voices here.
 
306.4 is only for public pools and spas, but ICE mentioned the CRC (residential). So first question. Is this a public or private spa?

I represented NADRA.org in successfully changing 306.3 in the 2024 ISPSC to eliminate the provisions for residential deck stairs and instead reference the IRC.

In my experiences with this code, the intent is not to require anything special for stairs in IRC sites and I would extend that to handrails since they are a subsection under "stairways" in the IRC and there are no specific provisions in the ISPSC.
 
They want to install a hot tub on a patio at a hotel. It is for public but I failed the plan review for other reasons anyway. The fold out steps and no landing on top would not pass besides accessibility. No electrical plan. Once they get me the manufactures instructions I have a feeling It might say for residential only.
 
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