A platform lift is permissible under FBC-Accessibility Section 206.7.
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Do I need an elevator?
- Thread starter Scott F
- Start date
A platform lift is permissible under FBC-Accessibility Section 206.7.
A note for the OP (@Scott F) - You have so far asked about ADA compliance. I'd note that as a church, you may find exemption under ADA. However, FL has its own Accessibility Code. I have been pulling references from the building, existing building, and accessibility codes. Even if exempt from ADA, these will apply.
ADA and Accessibility Codes are parallel, but often the State's accessibility code should meet or exceed ADA.
ADA and Accessibility Codes are parallel, but often the State's accessibility code should meet or exceed ADA.
Scott F
GREENHORN
Newbie here, what does OP represent?
I truly appreciate everyone's input and the time you've invested to help out. We are preparing for a call with our local building official and will report back on their determination.
Original Poster
Paul Sweet
SAWHORSE
As others have noted, ADA Title III does not apply to churches. However, the International codes incorporate almost all of the ADA provisions and apply them to all buildings.
bill1952
SAWHORSE
And I still believe that the 1000 sf floor is exempt from the accessible route requirement.
Yankee Chronicler
SILVER MEMBER
It may be. But the starting point in the code is that all new spaces shall be accessible. So to determine that it's not required to be accessible, you have to find a specific provision in the code that makes it exempt.
An important consideration is whether it's a mezzanine or a story. I still haven't seen anything to convince me that it in any way qualifies as a mezzanine, so I think it's a story. And we still haven't been told how many stories the building has. In short -- we don't have enough information to answer the question.
steveray
SAWHORSE
bill1952
SAWHORSE
Do you aggregate two floor plates not near each other in plan nor section as the same story?
In buildings with assembly seating and used for presentations, floor plates in different parts of the building frequently don't align. A stair or elevator in one part of the building may serve floors 1, 3, and 5, whereas in another part 1, 2, 4, and 6. And who knows what story a seating bank is on that spans between floors 2 and 5.
It was a big problem with early accessibility requirements that assumed floors stacked up on atop another.
Yes. Any story or mezzanine not on the level of accessible access is included in calculating the aggregate area.
Yankee Chronicler
SILVER MEMBER
Definition of AGGREGATE
formed by the collection of units or particles into a body, mass, or amount : collective: such as; clustered in a dense mass or head; formed from several separate ovaries of a single flower… See the full definition
www.merriam-webster.com
steveray
SAWHORSE
Seems pretty clear to me if it is a mezz(s)...
1103.2.16 Mezzanines
Mezzanines having fewer than 3,000 square feet (278.7 m2) of gross floor area, either singly or in the aggregate for multiple mezzanines on any floor,
I don't design the buildings...I just tell those who do what they are doing wrong.....
Paul Sweet
SAWHORSE
The proposed upper level would have to be a second story instead of a mezzanine because it the existing floor is subdivided into several smaller spaces. It would be limited to 1/3 of the area of the space it opens into.
Since ADA Title III does not apply to churches, they could request a code modification of 1104.4 to allow this a small portion of the second floor that is separated from the rest of the accessible second floor to not have an accessible route to it.
Another possibility is1104.4 exception 4, as long as it's a 2 story building and the floor is no more than 750 SF (5 occupants at 150 SF).
In any case, they have to make reasonable accommodations for disabled people. A disabled employee would have to be given an office on an accessible level, and somebody working in the new upper level would have to come down to the conference room to meet with a disabled person.
Since ADA Title III does not apply to churches, they could request a code modification of 1104.4 to allow this a small portion of the second floor that is separated from the rest of the accessible second floor to not have an accessible route to it.
Another possibility is1104.4 exception 4, as long as it's a 2 story building and the floor is no more than 750 SF (5 occupants at 150 SF).
In any case, they have to make reasonable accommodations for disabled people. A disabled employee would have to be given an office on an accessible level, and somebody working in the new upper level would have to come down to the conference room to meet with a disabled person.
bill1952
SAWHORSE
Well, I thought the exception applied to the aggregate of the inaccessible areas. And it does according to the ICC staff person I work with often.
"Aggregate is the mezzanines and stories that don’t have an accessible route to them. You do not count any levels that do have a route to them."
Maybe I misunderstood you classicT or maybe I misunderstood the OP, but I thought he proposed a 1000 SF floor - a story - be inaccessible but the rest of the building, including at least a second story was accessible. So it would comply.
So did I misunderstand or were you aggregating all of the floors and mezzanines to say this small floor did not fit in the exception?
I agree this is needed to not discriminate.
bill1952
SAWHORSE
Just to address this, even thought it seems certain the op is not talking about a mezzanine, the interp I get is:
"If you have two mezzanines, both 2,000 sq.ft., you have to provide an accessible route to only 1. Once you get a route to one mezzanine, the total in the building is less than 3,000 sq.ft."
I believe the "aggregate" includes only the inaccessible mezzanines, not all mezzanines, accessible or not.
Did you get a formal interpretation, or verbal?
bill1952
SAWHORSE
Verbal (an email) from an ICC staff person I know through Access Board hearings and ICC A117.1 meetings since late 1990s.
I'm going to follow up with the access board and some others. I'm a little shocked that anyone would include accessible areas in the aggregate, especially from people who are as erudite and conscientious as this group. Clearly, whichever the intent is, it needs to be more clearly written. On my list for end of 2026 to submit a change proposal for the 2030 IBC - if I'm still around.
Not promising to make it to 80 (but trying).
I'm going to follow up with the access board and some others. I'm a little shocked that anyone would include accessible areas in the aggregate, especially from people who are as erudite and conscientious as this group. Clearly, whichever the intent is, it needs to be more clearly written. On my list for end of 2026 to submit a change proposal for the 2030 IBC - if I'm still around.
Not promising to make it to 80 (but trying).Scott F
GREENHORN
Our local building department has communicated that the only exception they will acknowledge is the third exception under the Vertical Accessibility section (201.1.1) of the 2023 Florida Building Code/Accessibility.
