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Do All Offices Need To Be Accessible

A

arwat23

Registered User
Joined
Sep 19, 2023
Messages
106
Location
California
I'm working on a small TI project in California. I'm remodeling an office suite for a new tenant. The tenant is a therapist. The suite will consist of a small waiting room, a short corridor connecting the waiting room and offices, and three offices. Each office will be used for in-person therapy.

Do all of the offices need to be accessible? My understanding is that they all need to be accessible, but the landlord wants a certain layout that makes one office door not have the required maneuvering clearance within the office (push side from the corridor is complaint, but pull side within the office is not compliant).
 
As JPohling indicated, yes. See 1104.3.

2021 IBC 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, to accessible building entrances connecting accessible pedestrian walkways and to the public way.
Exceptions:
  1. Stories and mezzanines exempted by Section 1104.4.
  2. In a building, room or space used for assembly purposes with fixed seating, an accessible route shall not be required to serve levels where wheelchair spaces are not provided.
  3. Vertical access to elevated employee work stations within a courtroom complying with Section 1109.4.1.4.
  4. An accessible route to recreational facilities shall only be required to the extent specified in Section 1111.
 
steveray said:
Put the furniture in after CO....
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Not a furniture issue unfortunately. The wall is 4" from the strike side of the door. We need 18" minimum. Also, furniture can't technically be within the maneuvering clearance of a door (multiple CASp inspections have called out one of our clients for this). Technically not our issue since we don't spec the furniture, but I try to prevent this as much as possible.
 
classicT said:
As JPohling indicated, yes. See 1104.3.

2021 IBC 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, to accessible building entrances connecting accessible pedestrian walkways and to the public way.
Exceptions:
  1. Stories and mezzanines exempted by Section 1104.4.
  2. In a building, room or space used for assembly purposes with fixed seating, an accessible route shall not be required to serve levels where wheelchair spaces are not provided.
  3. Vertical access to elevated employee work stations within a courtroom complying with Section 1109.4.1.4.
  4. An accessible route to recreational facilities shall only be required to the extent specified in Section 1111.
Click to expand...
Unfortunately, the CBC does not have that specific language, at least as far as I see. There is no "Connected Spaces" section of CBC Chapter 11B or the 2010 ADAS (what CBC Ch11B is based off) either. CA loves to make things as clear as mud haha.
 
arwat23 said:
Unfortunately, the CBC does not have that specific language, at least as far as I see. There is no "Connected Spaces" section of CBC Chapter 11B or the 2010 ADAS (what CBC Ch11B is based off) either. CA loves to make things as clear as mud haha.
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2022 CBC 11B-206.2.4 Spaces and Elements​

At least one accessible route shall connect accessible building or facility entrances with all accessible spaces and elements within the building or facility, including mezzanines, which are otherwise connected by a circulation path unless exempted by Section 11B-206.2.3 Exceptions 1 through 7.
Exceptions:
  1. Reserved.
  2. In assembly areas with fixed seating required to comply with Section 11B-221, an accessible route shall not be required to serve fixed seating where wheelchair spaces required to be on an accessible route are not provided.
  3. Reserved.
 
If a theater is existing with fixed seating would this IEBC section over ride 1104.3?

305.7 Alterations affecting an area containing a primary
function. Where an alteration affects the accessibility to, or
contains an area of primary function, the route to the primary
function area shall be accessible. The accessible route to the
primary function area shall include toilet facilities and drinking
fountains serving the area of primary function.
 
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Also, given CA, be aware of the definition of medical care as it applies to CBC 11B-223 Medical Care and Long-Term Care Facilities.

[BG] MEDICAL CARE. Care involving medical or surgical procedures, nursing or for psychiatric purposes.
 
arwat23, if the office room in question has any remodeling being done to it, then CBC 11B-202.3 requires that alteration to be accessible, and CBC 11B-202.4 requires an accessible path of travel (APOT) to the area of alteration. an APOT includes the door clearances etc.
If this is a new door, then I don't see an exception.

If the alteration is "technically infeasible", then you negotiate with your building department. See definition in CBC chapter 2 of "technically infeasible". Note that adding a new wall and a noncompliant door swing is not "technically infeasible".

CBC 202.4 exception #8 says there's an upper limit on how much your client needs to spend for accessible path of travel improvements.

As others have mentioned, your client will be responsible for ADA compliance regardless of whether or not compliance falls within the scope of alterations CBC-11B.
 
classicT said:

2022 CBC 11B-206.2.4 Spaces and Elements​

At least one accessible route shall connect accessible building or facility entrances with all accessible spaces and elements within the building or facility, including mezzanines, which are otherwise connected by a circulation path unless exempted by Section 11B-206.2.3 Exceptions 1 through 7.
Exceptions:
  1. Reserved.
  2. In assembly areas with fixed seating required to comply with Section 11B-221, an accessible route shall not be required to serve fixed seating where wheelchair spaces required to be on an accessible route are not provided.
  3. Reserved.
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True, but that just leads me back to the start. Are all of the offices required to be accessible? Is the space required to be a "accessible space"? For example, I know only a certain amount of changing rooms need to be accessible where changing rooms are provided. Is there something similar for offices? I'm guessing no since I've never seen that, but my coworkers assure me there is something (although no one has ever pointed to a section of code of course).
 
If it is one doctor and multiple patients, I would find a way to approve it....If they are individual specific rooms it gets a little dicey...
arwat23 said:
True, but that just leads me back to the start. Are all of the offices required to be accessible? Is the space required to be a "accessible space"? For example, I know only a certain amount of changing rooms need to be accessible where changing rooms are provided. Is there something similar for offices? I'm guessing no since I've never seen that, but my coworkers assure me there is something (although no one has ever pointed to a section of code of course).
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Kind of like I always thought there should be some scoping/ % of accessible sinks in exam rooms....

And let me clarify....The office may get some type of pass as an employee work area, but when you bring in patients, that goes away...
 
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arwat23 said:
True, but that just leads me back to the start. Are all of the offices required to be accessible? Is the space required to be a "accessible space"? For example, I know only a certain amount of changing rooms need to be accessible where changing rooms are provided. Is there something similar for offices? I'm guessing no since I've never seen that, but my coworkers assure me there is something (although no one has ever pointed to a section of code of course).
Click to expand...
Generally everything must be accessible unless there is an exception.

11B-201.1 Scope​

All areas of newly designed and newly constructed buildings and facilities and altered portions of existing buildings and facilities shall comply with these requirements.
 
Rick18071 said:
If the building is existing would this IEBC section over ride 1104.3 because it is more strict?

305.7 Alterations affecting an area containing a primary
function. Where an alteration affects the accessibility to, or
contains an area of primary function, the route to the primary
function area shall be accessible. The accessible route to the
primary function area shall include toilet facilities and drinking
fountains serving the area of primary function.
Click to expand...
Nope. CBC Ch11B is used whenever anything is altered, at least for accessibility items.

Per CEBC 306, "Buildings or facilities where accessibility is required for applications listed in Title 24, Part 2, California Building Code, Chapter 1, Section 1.9.1 regulated by the Division of the State Architect-Access Compliance shall comply with Title 24, Part 2, California Building Code, Chapter 11A or Chapter 11B, as applicable." Most of the CEBC isn't even adopted by the state, and most of what's in the code just references IBC (for some reason...) or CBC.

Sorry for the small tangent. I find some of this stuff nonsensical when compared to how some other states do it.
 
arwat23 said:
I'm working on a small TI project in California. I'm remodeling an office suite for a new tenant. The tenant is a therapist. The suite will consist of a small waiting room, a short corridor connecting the waiting room and offices, and three offices. Each office will be used for in-person therapy.

Do all of the offices need to be accessible? My understanding is that they all need to be accessible, but the landlord wants a certain layout that makes one office door not have the required maneuvering clearance within the office (push side from the corridor is complaint, but pull side within the office is not compliant).
Click to expand...
11B-202.3 Alterations
Where existing elements or spaces are altered, each altered element or space shall comply with the applicable requirements of Division 2, including Section 11B-202.4.
11B-202.4 Path of Travel Requirements in Alterations, Additions and Structural Repairs
When alterations or additions are made to existing buildings or facilities, an accessible path of travel to the specific area of alteration or addition shall be provided. The primary accessible path of travel shall include:
1. A primary entrance to the building or facility,
2. Toilet and bathing facilities serving the area,
3. Drinking fountains serving the area,
4. Public telephones serving the area, and
5. Signs.
11B-203.9 Employee Workstations
Employee workstations shall be on an accessible route complying with Division 4. Spaces and elements within employee workstations shall only be required to comply with Sections 11B-207.1, 11B-215.3, 11B-302, 11B-303, 11B-308.1.1, 11B-308.1.2 and 11B-404.2.3 unless exempted by other parts of this code. Common use circulation paths within employee workstations shall comply with Section 11B-206.2.8.
11B-206.2.8 Employee Work Areas
Common use circulation paths within employee work areas shall comply with Section 11B-402.
 
arwat23 said:
Nope. CBC Ch11B is used whenever anything is altered, at least for accessibility items.

Per CEBC 306, "Buildings or facilities where accessibility is required for applications listed in Title 24, Part 2, California Building Code, Chapter 1, Section 1.9.1 regulated by the Division of the State Architect-Access Compliance shall comply with Title 24, Part 2, California Building Code, Chapter 11A or Chapter 11B, as applicable." Most of the CEBC isn't even adopted by the state, and most of what's in the code just references IBC (for some reason...) or CBC.

Sorry for the small tangent. I find some of this stuff nonsensical when compared to how some other states do it.
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Not CBC IBC and IEBC. Not in CA.
 
Joe.B said:
11B-202.3 Alterations
Where existing elements or spaces are altered, each altered element or space shall comply with the applicable requirements of Division 2, including Section 11B-202.4.
11B-202.4 Path of Travel Requirements in Alterations, Additions and Structural Repairs
When alterations or additions are made to existing buildings or facilities, an accessible path of travel to the specific area of alteration or addition shall be provided. The primary accessible path of travel shall include:
1. A primary entrance to the building or facility,
2. Toilet and bathing facilities serving the area,
3. Drinking fountains serving the area,
4. Public telephones serving the area, and
5. Signs.
11B-203.9 Employee Workstations
Employee workstations shall be on an accessible route complying with Division 4. Spaces and elements within employee workstations shall only be required to comply with Sections 11B-207.1, 11B-215.3, 11B-302, 11B-303, 11B-308.1.1, 11B-308.1.2 and 11B-404.2.3 unless exempted by other parts of this code. Common use circulation paths within employee workstations shall comply with Section 11B-206.2.8.
11B-206.2.8 Employee Work Areas
Common use circulation paths within employee work areas shall comply with Section 11B-402.
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Would a space that accessible to the public (patients) still be considered a work area?
11B-202.4 is a non-issue, as path of travel TO the space is fine. It's just leaving the space that's an issue.
 
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