Dentist Office

[VLADIMIR LEVIN]

Does every treatment room, on the same level in a dentists office have to be accessible (turning space, door clearances, etc)?

 

[Yikes]

Where is the project located? More specifically, what is the applicable code?

 

[VLADIMIR LEVIN]

CT, IBC

 

[Sifu]

I have asked this many times. I don't think the IBC has any specific provisions for scoping, and the ANSI has no direction. But, it makes sense that not every one would be if the exact same services are provided in other rooms and the ADA tends to agree.

Below is an FAQ from here: https://www.ada.gov/resources/medical-care-mobility/#part-2:--commonly-asked-questions

 

[steveray]

Does every treatment room, on the same level in a dentists office have to be accessible (turning space, door clearances, etc)?

Do you have an exception in 1103 or 1104?

 

[Yikes]

Sorry, I don't know about the IBC, as we have a different code in CA.

I do note that in order to make a dentist office ADA Title III compliant, an accessible route must be provided to every employee workstation that is accessed via a common circulation path, unless it meets one of the exceptions. There is no specific requirement in ADA regarding accessible dental equipment, nor a definition of what makes a dental chair accessible. Dentistry is a service, and ADA would require reasonable accommodation to provide the service regardless of the equipment. For example, if you could provide dental service to someone while they were sitting in a wheelchair, and if that person had an accessible route to where you were going to perform the service, then your equipment probably meets the intent of ADA.

 

[Sifu]

I should have added, because I just went through this...

I did not comment that the 1 treatment room out of 12 that was not "accessible" be made accessible. I did this based on the reasoning I posted above. HOWEVER, it was still an employee work-space, so it did still require the ability to enter and exit the space. They lacked the maneuvering clearance at the door. If it was a space that did not permit entry where the door closed behind you before you might realize and then not have an accessible approach to then exit the space I might not see this as part of the ability to exit, but this was not the case.

(Sometimes I read a post and shoot from the hip without reading the entire post.)

 

[VLADIMIR LEVIN]

I should have added, because I just went through this...

I did not comment that the 1 treatment room out of 12 that was not "accessible" be made accessible. I did this based on the reasoning I posted above. HOWEVER, it was still an employee work-space, so it did still require the ability to enter and exit the space. They lacked the maneuvering clearance at the door. If it was a space that did not permit entry where the door closed behind you before you might realize and then not have an accessible approach to then exit the space I might not see this as part of the ability to exit, but this was not the case.

(Sometimes I read a post and shoot from the hip without reading the entire post.)

So, does every treatment room has to have the required door clearances and space to turn around to enter and exit , but not every treatment room has to have a dental chair that is accessible?

 

[VLADIMIR LEVIN]

Sorry, I don't know about the IBC, as we have a different code in CA.

I do note that in order to make a dentist office ADA Title III compliant, an accessible route must be provided to every employee workstation that is accessed via a common circulation path, unless it meets one of the exceptions. There is no specific requirement in ADA regarding accessible dental equipment, nor a definition of what makes a dental chair accessible. Dentistry is a service, and ADA would require reasonable accommodation to provide the service regardless of the equipment. For example, if you could provide dental service to someone while they were sitting in a wheelchair, and if that person had an accessible route to where you were going to perform the service, then your equipment probably meets the intent of ADA.

View attachment 15501

IBC has the same section (1104.3.1).
IBC section 1103.2.2 says that "... spaces and elements within employee work areas ... shall be designed and constructed so that individuals with disabilities can approach, enter and exist the work area". This sounds like every exam room would need to have door clearances and turn around space. Right?

 

[VLADIMIR LEVIN]

So, does every treatment room has to have the required door clearances and space to turn around to enter and exit , but not every treatment room has to have a dental chair that is accessible?

I think I found the answer.
IBC section 1103.2.2 says that "... spaces and elements within employee work areas ... shall be designed and constructed so that individuals with disabilities can approach, enter and exist the work area". This sounds like every exam room would need to have door clearances and turn around space. Right?

 

[jc_ks]

I think I found the answer.
IBC section 1103.2.2 says that "... spaces and elements within employee work areas ... shall be designed and constructed so that individuals with disabilities can approach, enter and exist the work area". This sounds like every exam room would need to have door clearances and turn around space. Right?

That would be my interpretation.

 

[Sifu]

So, does every treatment room has to have the required door clearances and space to turn around to enter and exit , but not every treatment room has to have a dental chair that is accessible?

Without any specific exception to the general concept that all spaces are required to be accessible it is difficult to say that every space not excepted does not need to be, I have allowed some not to be based on my own research, and at my own risk. The most conclusive research I found was posted. I would say that it is an employee workspace, and must meet those requirements whether the room is "accessible" or not.

FWIW, the code section you cite is the one, however even within it, it does not specify the individual elements required to meet the "approach, enter and exit" guidance. For that I just apply my own metric, which includes things like hardware, maneuvering space etc. Turning space has been a question, which is where I believe the elasticity can be had if the door does not close behind them and they could back out, which would likely not be the case for an exam room. FWIW, some of these conclusions were arrived at by discussion on this forum, so you are in the right place IMHO.

 

[arwat23]

I think I found the answer.
IBC section 1103.2.2 says that "... spaces and elements within employee work areas ... shall be designed and constructed so that individuals with disabilities can approach, enter and exist the work area". This sounds like every exam room would need to have door clearances and turn around space. Right?

Turning space is only required where specifically stated. For example, A117.1 603.2.1 specifically calls for a turning space in toilet and bathing rooms.

You need the door clearances since that's how you exit the room. Even if a turning space isn't required, it's a good idea to provide that space if possible. Providing more than the minimum requirements is usually a good idea.

In CA, a turning space is required in dentist offices by CBC 11B-805.5, and it applies to all treatment rooms. Not sure if IBC has something similar.

 

[walker.t]

I think I found the answer.
IBC section 1103.2.2 says that "... spaces and elements within employee work areas ... shall be designed and constructed so that individuals with disabilities can approach, enter and exist the work area"

This would not apply because the treatment rooms are not employee work areas as defined in IBC Chapter 2:

IBC 2021 Definition of “Employee Work Area” (emphasis added)
All or any portion of a space used only by employees and only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.

Does every treatment room, on the same level in a dentists office have to be accessible (turning space, door clearances, etc)?

Per 1104.3 Connected Spaces: “Where a building or portion of a building is required to be accessible, at least one accessible route shall be provided to each portion of the building…”. Doors are a component of an accessible route per A117.1-2017 402.2 Components. In order for a door to be considered accessible, door maneuvering clearances on both sides of the door are required per A117.1-2017 404.2.3.2 Swinging Doors and Gates.

I could not readily find anything addressing if a turning space is required in every room. Considering that we have to approach and use a door by facing it, I would say it is implied that a turning space must be provided inside the room so a person can turn to face the door to operate the door.

 

[Sifu]

In the recent review I looked at the plans labeled it as "flex office/treatment room. I guess they are hedging their bets. They have 12 others, all accessible. I still required the maneuvering space.

I can only shake my head at myself for missing the "only" part of the definition.

 

[VLADIMIR LEVIN]

IBC 2021 Definition of “Employee Work Area” (emphasis added)
All or any portion of a space used only by employees and only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.

Per 1104.3 Connected Spaces: “Where a building or portion of a building is required to be accessible, at least one accessible route shall be provided to each portion of the building…”.

“Where a building or portion of a building is required to be accessible, at least one accessible route shall be provided to each portion of the building…”.
By the above requirement it seams that every exam room needs to be accessible. However is that really the intent of the code, if they are all providing the same service? I would argue that they don't all need to be accessible; just like every toilet fixture, counter, kitchenette, parking space doesn't need to be accessible.
I think that conclusion is within the spirit of accessibility, as Sifu pointed out in the ada.gov resource above.

Whether an exam room is required to be accessible for employees is, as pointed out by walker.t, in the dentition of "employee work area" and is not required.

For my dental office project, my final conclusion is that not every single room within the whole space that provides the same dental service needs to be accessible as long as a reasonable amount of those spaces are accessible, e.g. I out of 4 exam room, 1 out of 2 imaging rooms.

 

[walker.t]

By the above requirement it seams that every exam room needs to be accessible. However is that really the intent of the code, if they are all providing the same service?

The U.S. Access Board technical guide for new construction indicates that every exam room needs to be accessible, here’s an image from Page 3 of the PDF:



Here’s a link to that technical guide: https://www.access-board.gov/ada/guides/chapter-2-new-construction/

I would argue that they don't all need to be accessible; just like every toilet fixture, counter, kitchenette, parking space doesn't need to be accessible.

I had a similar thought, how not every toilet stall has to be accessible. But providing accessible access into a room is different than making every element in the restroom accessible, Sifu’s #4 post provides commentary supporting why not every element needs to be accessible, and the image above notes that elements used only by employees do not need to be accessible.

my final conclusion is that not every single room within the whole space that provides the same dental service needs to be accessible as long as a reasonable amount of those spaces are accessible, e.g. I out of 4 exam room, 1 out of 2 imaging rooms.

I would be curious to hear if your building department agrees and lets you provide rooms that don’t have door maneuvering clearances on both sides of the door into the space.

 

[VLADIMIR LEVIN]

I had a similar thought, how not every toilet stall has to be accessible. But providing accessible access into a room is different than making every element in the restroom accessible, Sifu’s #4 post provides commentary supporting why not every element needs to be accessible, and the image above notes that elements used only by employees do not need to be accessible.

Here's my analogy to the bathroom:
The entire dentist space is the bathroom, each exam room is a toilet...

The link to the access-board.gov is very helpful. In he end, I can and probably will have an accessible route to every exam room; nevertheless this is an interesting discussion.

 

[Yankee Chronicler]

“Where a building or portion of a building is required to be accessible, at least one accessible route shall be provided to each portion of the building…”.
By the above requirement it seams that every exam room needs to be accessible. However is that really the intent of the code, if they are all providing the same service? I would argue that they don't all need to be accessible; just like every toilet fixture, counter, kitchenette, parking space doesn't need to be accessible.
I think that conclusion is within the spirit of accessibility, as Sifu pointed out in the ada.gov resource above.

Whether an exam room is required to be accessible for employees is, as pointed out by walker.t, in the dentition of "employee work area" and is not required.

For my dental office project, my final conclusion is that not every single room within the whole space that provides the same dental service needs to be accessible as long as a reasonable amount of those spaces are accessible, e.g. I out of 4 exam room, 1 out of 2 imaging rooms.

I don't agree with your analysis, and the guidance cited by walker.t confirms this. In the dental office where I go and in the dental offices I have reviewed as a plans examiner, each exam/treatment room or cubicle has a dentist or a dental hygienist assigned to it. They don't "float. The same is true for the dental clinic at the VA hospital near me.

And you have to remember that it's impossible to predict when anyone may become mobility impaired. We should all remember that we are, in essence, the "temporarily able-bodied" population. A number of years ago the deputy building official in the city near me fell off a ladder while cleaning his gutters and shattered his heel. He was in a wheelchair for six months. Legend has it that enforcement of accessibility requirements was followed MUCH more stringently in that city as a result.

 

[ICE]

person can turn to face the door to operate the door.

Somebody's going to be wheeling them in so the door is not an issue.

During a final inspection for a TI that created individual office spaces that would be rented out, I asked the two owners where the "wheelchair guy" was. They were like "What????" So I explained that a person in a wheelchair has to test all of the ADA stuff. They talked for a few minutes and then one of them said, "I have a cousin that's wheelchair bound and we can have him here next time." So I said, "Make sure to have boxing gloves too." They were like, "What????"