• Welcome to the new and improved Building Code Forum. We appreciate you being here and hope that you are getting the information that you need concerning all codes of the building trades. This is a free forum to the public due to the generosity of the Sawhorses, Corporate Supporters and Supporters who have upgraded their accounts. If you would like to have improved access to the forum please upgrade to Sawhorse by first logging in then clicking here: Upgrades

Do I need an elevator?

S

Scott F

Registered User
Joined
Oct 23, 2023
Messages
21
Location
Florida Panhandle
We have a client who is interested in exploring the possibility of adding a mezzanine or second floor level above an existing area in a large multi-story assembly building. The area we would be working on is 3,088 square feet. While there are existing elevators in the building, they wouldn't be able to service this new space. The current space, which is a rarely-used open reception room, is set to be repurposed into offices. To meet the required number of offices, we must consider vertical expansion. However, given both a mezzanine or intermediate floor scenario, would ADA requirements necessitate the construction of a new elevator? We are in Florida.

For reference, below is a rough sketch of a single idea. The darker gray represents a mezzanine.

1706562291934.png
 
Last edited:
It is our professional opinion that vertical accessibility should always be provided. At the same time, it is our responsibility to present the owner with various options and potential exceptions, should they exist. I also plan to seek advice from our local building official for their input.
 
Mr. Inspector said:
I don't know ADA but the 2018 IBC would not require an elevator unless if there is no basement or other floors, or a health care area.
Click to expand...
How so? The 2018 IBC does in fact require an elevator, irrespective if there is no basement or other floors, or a health care area.

Given that the OP indicated this area is 3,088sf and that other portions already have elevators, what exception to the required accessible route do you believe they qualify for? Yes, an elevator is not the only method of an accessible route, but how many ramps have you seen for provide access to an upper floor level?

See 2018 IBC Section 1104.4.

2018 IBC 1104.4 Multistory Buildings and Facilities​

At least one accessible route shall connect each accessible story, mezzanine and occupied roofs in multilevel buildings and facilities.
Exceptions:
  1. An accessible route is not required to stories, mezzanines and occupied roofs that have an aggregate area of not more than 3,000 square feet (278.7 m2) and are located above and below accessible levels. This exception shall not apply to:
    1. Multiple tenant facilities of Group M occupancies containing five or more tenant spaces used for the sales or rental of goods and where at least one such tenant space is located on a floor level above or below the accessible levels.
    2. Stories or mezzanines containing offices of health care providers (Group B or I).
    3. Passenger transportation facilities and airports (Group A-3 or B).
    4. Government buildings.
  2. Stories, mezzanines or occupied roofs that do not contain accessible elements or other spaces as determined by Section 1107 or 1108 are not required to be served by an accessible route from an accessible level.
  3. In air traffic control towers, an accessible route is not required to serve the cab and the floor immediately below the cab.
  4. Where a two-story building or facility has one story or mezzanine with an occupant load of five or fewer persons that does not contain public use space, that story or mezzanine shall not be required to be connected by an accessible route to the story above or below.
 
classicT said:
How so? The 2018 IBC does in fact require an elevator, irrespective if there is no basement or other floors, or a health care area.

Given that the OP indicated this area is 3,088sf and that other portions already have elevators, what exception to the required accessible route do you believe they qualify for? Yes, an elevator is not the only method of an accessible route, but how many ramps have you seen for provide access to an upper floor level?

See 2018 IBC Section 1104.4.

2018 IBC 1104.4 Multistory Buildings and Facilities​

At least one accessible route shall connect each accessible story, mezzanine and occupied roofs in multilevel buildings and facilities.
Exceptions:
  1. An accessible route is not required to stories, mezzanines and occupied roofs that have an aggregate area of not more than 3,000 square feet (278.7 m2) and are located above and below accessible levels. This exception shall not apply to:
    1. Multiple tenant facilities of Group M occupancies containing five or more tenant spaces used for the sales or rental of goods and where at least one such tenant space is located on a floor level above or below the accessible levels.
    2. Stories or mezzanines containing offices of health care providers (Group B or I).
    3. Passenger transportation facilities and airports (Group A-3 or B).
    4. Government buildings.
  2. Stories, mezzanines or occupied roofs that do not contain accessible elements or other spaces as determined by Section 1107 or 1108 are not required to be served by an accessible route from an accessible level.
  3. In air traffic control towers, an accessible route is not required to serve the cab and the floor immediately below the cab.
  4. Where a two-story building or facility has one story or mezzanine with an occupant load of five or fewer persons that does not contain public use space, that story or mezzanine shall not be required to be connected by an accessible route to the story above or below.
Click to expand...
classicT said:
Yes, required.
Click to expand...
Is the requirement being driven by the figure of 3,000 square feet? We could attempt to maintain the second floor area under this size, given that the mezzanine level would be around 1,030 square feet. Essentially, if we manage to keep the total area under 3,000 square feet, would the elevator still be a requirement?

III-6.3000 Alterations: Elevator exemption. As under new construction, elevators are not required to be installed during alterations in facilities under three stories or with fewer than 3,000 square feet per floor, unless the building is a shopping center or mall; professional office of a health care provider; public transit station; or airport passenger terminal. As discussed below, "shopping center or mall" is defined differently for alterations than it is for new construction.
 
Scott F said:
Is the requirement being driven by the figure of 3,000 square feet? We could attempt to maintain the second floor area under this size, given that the mezzanine level would be around 1,030 square feet. Essentially, if we manage to keep the total area under 3,000 square feet, would the elevator still be a requirement?

III-6.3000 Alterations: Elevator exemption. As under new construction, elevators are not required to be installed during alterations in facilities under three stories or with fewer than 3,000 square feet per floor, unless the building is a shopping center or mall; professional office of a health care provider; public transit station; or airport passenger terminal. As discussed below, "shopping center or mall" is defined differently for alterations than it is for new construction.
Click to expand...
In the IBC, the 3000sf requirement pertains to aggregate area of all spaces not on the level of accessible access. Meaning you would need to calculate the total area of both this area and any other basement or upper story or mezzanine.

Scott F said:
III-6.3000 Alterations: Elevator exemption. As under new construction, elevators are not required to be installed during alterations in facilities under three stories or with fewer than 3,000 square feet per floor, unless the building is a shopping center or mall; professional office of a health care provider; public transit station; or airport passenger terminal. As discussed below, "shopping center or mall" is defined differently for alterations than it is for new construction.
Click to expand...
I'm not sure where you have pulled this reference from. I'd need to dive further into FL code.
 
Scott F said:
We have a client who is interested in exploring the possibility of adding a mezzanine or second floor level above an existing area in a large multi-story assembly building. The area we would be working on is 3,088 square feet. While there are existing elevators in the building, they wouldn't be able to service this new space. The current space, which is a rarely-used open reception room, is set to be repurposed into offices. To meet the required number of offices, we must consider vertical expansion. However, given both a mezzanine or intermediate floor scenario, would ADA requirements necessitate the construction of a new elevator? We are in Florida.

For reference, below is a rough sketch of a single idea. The darker gray represents a mezzanine.

View attachment 12766
Click to expand...

How is it in any way a mezzanine? What exiting space would this proposed "mezzanine" be in? Is it between the floor and the ceiling of an existing space?

Can you post a cross-section showing how it might qualify as a mezzanine?
 
Looking into the FL code...

2020 FL Existing Building Code​

1105.1 Minimum Requirements​

Accessibility provisions for new construction shall apply to additions. An addition that affects the accessibility to, or contains an area of, primary function shall comply with the requirements of the Florida Building Code, Accessibility.
 
Yankee Chronicler said:
How is it in any way a mezzanine? What exiting space would this proposed "mezzanine" be in? Is it between the floor and the ceiling of an existing space?

Can you post a cross-section showing how it might qualify as a mezzanine?
Click to expand...
OP did not limit it to being a mezzanine and has not likely seen the other threads where you have discussed the topic of what constitutes a mezzanine.
Scott F said:
a mezzanine or second floor level
Click to expand...
Scott F said:
given both a mezzanine or intermediate floor scenario
Click to expand...
 
classicT said:
An accessible route is not required to stories, mezzanines and occupied roofs that have an aggregate area of not more than 3,000 square feet (278.7 m2) and are located above and below accessible levels.
Click to expand...
Why doesn't the proposed 1030 SF 2nd floor addition not fit in this?
 
Scott F said:
Is the requirement being driven by the figure of 3,000 square feet? We could attempt to maintain the second floor area under this size, given that the mezzanine level would be around 1,030 square feet. Essentially, if we manage to keep the total area under 3,000 square feet, would the elevator still be a requirement?

III-6.3000 Alterations: Elevator exemption. As under new construction, elevators are not required to be installed during alterations in facilities under three stories or with fewer than 3,000 square feet per floor, unless the building is a shopping center or mall; professional office of a health care provider; public transit station; or airport passenger terminal. As discussed below, "shopping center or mall" is defined differently for alterations than it is for new construction.
Click to expand...
There are a few things to consider here:

  1. III-6.3000 is from Title III ADA, which address areas of Public Accommodation. Are the offices meant to be accessed by the public in course of transacting business in the building? Or are they employee offices?
  2. If they are not places of public accommodation, and are employee offices, then they do meet the elevator exemption rule you quote.
  3. However, you should inform your client that they could be subject to Title I requirements in the future (i.e. providing equal accommodations to employees).
 
bill1952 said:
Why doesn't the proposed 1030 SF 2nd floor addition not fit in this?
Click to expand...
Below is taken from new construction, but it still applies to alterations.

III-5.4000 Elevator exemption. Elevators are the most common way to provide access in multistory buildings. Title III of the ADA, however, contains an exception to the general rule requiring elevators. Elevators are not required in facilities under three stories or with fewer than 3000 square feet per floor, unless the building is a shopping center or mall; professional office of a health care provider; public transit station; or airport passenger terminal.

ILLUSTRATION 1: A two-story office building has 40,000 square feet on each floor. Because the building is less than three stories, an elevator is not required. (To qualify for the exemption, a building must either be under three stories or have fewer than 3000 square feet per floor; it need not meet both criteria.)

BUT: A two-story shopping center with 40,000 square feet on each floor is required to have an elevator, because shopping centers are not entitled to the exemption.

ILLUSTRATION 2: A four-story building has 2900 square feet per floor. An elevator is not required because each floor has less than 3000 square feet.

ILLUSTRATION 3: A four-story office building has 3500 square feet on the first floor and 2500 square feet on each of the other floors. An elevator is required. (All of the stories must be under 3000 square feet to qualify for the exemption.)
 
@classicT - are you saying because there is another floor in another part of the building that is accessible, that this 1000 SF floor has to be accessible? Even if no where near each other in plan or section?
 
bill1952 said:
@classicT - are you saying because there is another floor in another part of the building that is accessible, that this 1000 SF floor has to be accessible? Even if no where near each other in plan or section?
Click to expand...

The OP wrote that this is a large, multi-story assembly facility. He didn't say how many stories or what the floor area of the other stories is, and that could make a difference. He also wrote that there are elevators -- but the plan doesn't show any elevators. That suggests that we are not seeing a complete floor plan.
 
JMarsh said:
There are a few things to consider here:

  1. III-6.3000 is from Title III ADA, which address areas of Public Accommodation. Are the offices meant to be accessed by the public in course of transacting business in the building? Or are they employee offices?
  2. If they are not places of public accommodation, and are employee offices, then they do meet the elevator exemption rule you quote.
  3. However, you should inform your client that they could be subject to Title I requirements in the future (i.e. providing equal accommodations to employees).
Click to expand...
This is a church....Does ADA apply? Let's start there.....
 
Yankee Chronicler said:
How is it in any way a mezzanine? What exiting space would this proposed "mezzanine" be in? Is it between the floor and the ceiling of an existing space?

Can you post a cross-section showing how it might qualify as a mezzanine?
Click to expand...
We have not been given approval to proceed with any drawing development. We were asked to produce an abbreviated feasibility assessment concerning the potential addition of a mezzanine or intermediate second floor level. There is roughly 25 feet between the floor and underside of structure above in this particular area.
 
JMarsh said:
There are a few things to consider here:

  1. III-6.3000 is from Title III ADA, which address areas of Public Accommodation. Are the offices meant to be accessed by the public in course of transacting business in the building? Or are they employee offices?
  2. If they are not places of public accommodation, and are employee offices, then they do meet the elevator exemption rule you quote.
  3. However, you should inform your client that they could be subject to Title I requirements in the future (i.e. providing equal accommodations to employees).
Click to expand...
Yes, the offices are intended for employees.
 
Yankee Chronicler said:
The OP wrote that this is a large, multi-story assembly facility. He didn't say how many stories or what the floor area of the other stories is, and that could make a difference. He also wrote that there are elevators -- but the plan doesn't show any elevators. That suggests that we are not seeing a complete floor plan.
Click to expand...
The new floor level that we are creating in this space is unique and does not align with any other floors in the building, served by the existing elevators.
 
You must log in or register to reply here.
Top