Egress and Accessibility in Existing Buildings

[arwat23]

arwat23, I may sound crazy, but I'm inclined to agree with you that 11B-202.4 requires a path of travel "to" the space, not "to and from" the space.

However, I would also note that you have not described the nature of the alteration. Are you planning on altering the existing exterior entry door itslef?
11B-202.3 states that any existing element that gets altered must comply with the scoping of division 2.
So if the door currently functions as both an entry and a Chapter 10-required exit (user passage from the interior to the exterior), AND you are altering the door itself, perhaps 11B-206.5.2 would trigger compliance in direction of exit travel (as well as entry travel).
If you are not altering the door itself, then per the limitations in 202.4 maybe an accessible landing on the interior side is not required.

At least I'm not alone in my crazy thoughts lol.

Alterations are strictly interior, other than required path of travel improvements. Door alterations are limited to what's required by CBC 11B-202.4 (only new hardware). There's another existing door in the space that could easily serve as an exit. Only one exit is required for the space by Ch 10.

 

[Yikes]

One other caveat. I've had some AHJ's take a generous, perhaps expansive, view of the CBC 202 definition of "path of travel".
Whereas 11B-202.4 only describes the accessible path of travel as being TO (not FROM) the specific area of alteration, CBC 202 describes the path as having the means to approach, enter, and exit.

PATH OF TRAVEL. [DSA-AC] An identifiable accessible route within an existing site, building or facility by means of which a particular area may be approached, entered and exited, and which connects a particular area with an exterior approach (including sidewalks, streets and parking areas), an entrance to the facility, and other parts of the facility. When alterations, structural repairs or additions are made to existing buildings or facilities, the term "path of travel" also includes the toilet and bathing facilities, telephones, drinking fountains and signs serving the area of work.​

Now, this definition is meant to be inclusive, but in my experience the AHJ's have mistakenly considered it a prescriptive scoping requirement. For example, when was the last time you remodeled a private office interior and were required to make a "street" accessible? A path connecting to a public sidewalk? Yes. Street? No.
Or if your project had no parking lot, do you think the intent of this CBC 202 definition is to require you to construct a parking lot, just because the wording says "including parking"? I think the answer is "no".

But in your particular case, I could see how an AHJ could interpret the wording of this CBC 202 definition as establishing a prescriptive scoping requirement to provide the landing on both sides of the door, and it probably would not be worth fighting over it.

(12:09pm - edited last sentence)

 

[Mr. Inspector]

Looks like a CA thing. But if the only thing you are doing on this project is the changing the hardware on the door does CA have this (exceptions 2 & 4):

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.
Exceptions:
1. The costs of providing the accessible route are not
required to exceed 20 percent of the costs of the
alterations affecting the area of primary function.
2. This provision does not apply to alterations limited
solely to windows, hardware, operating controls,
electrical outlets and signs.
3. This provision does not apply to alterations limited
solely to mechanical systems, electrical systems,
installation or alteration of fire protection systems
and abatement of hazardous materials.
4. This provision does not apply to alterations undertaken
for the primary purpose of increasing the
accessibility of a facility.
5. This provision does not apply to altered areas limited
to Type B dwelling and sleeping units.
305.8 Scoping for alterations. The provisions of Sections

305.8.1 through 305.8.15 shall apply to alterations to existing
buildings and facilities.
305.8.1 Entrances. Where an alteration includes alterations
to an entrance that is not accessible, and the facility
has an accessible entrance, the altered entrance is not
required to be accessible unless required by Section 305.7.
Signs complying with Section 1111 of the International
Building Code shall be provided.

 

[arwat23]

Looks like a CA thing. But if the only thing you are doing on this project is the changing the hardware on the door does CA have this (exceptions 2 & 4):

Well, no, there's a lot more to it than that. We're doing a full interior remodel (new walls, new equipment, a new restroom, etc.).

The only changes to the exterior door are what's required by CBC 11B-202.4. If that section didn't exist, we wouldn't be touching the door.

What code are the sections you're referencing from? They don't look like California code (we don't use "area of primary function").

 

[Mr. Inspector]

Well, no, there's a lot more to it than that. We're doing a full interior remodel (new walls, new equipment, a new restroom, etc.).

The only changes to the exterior door are what's required by CBC 11B-202.4. If that section didn't exist, we wouldn't be touching the door.

What code are the sections you're referencing from? They don't look like California code (we don't use "area of primary function").

2018 IEBC

 

[arwat23]

2018 IEBC

Not applicable unfortunately. One of those "California is different" situations.

 

[JPohling]

Chapter 10 would require the level landing on both sides of a door. Exterior landing can have 2% slope for drainage. The maneuvering space requirements from 11B are specific to how the door will be approached and used. If this was an entry only door with no hardware on the interior I could see your point and only the exterior approach would need to be compliant. But this will be an exit door as well with the approach from the interior. That would need to comply from my perspective.

 

[arwat23]

Chapter 10 would require the level landing on both sides of a door. Exterior landing can have 2% slope for drainage. The maneuvering space requirements from 11B are specific to how the door will be approached and used. If this was an entry only door with no hardware on the interior I could see your point and only the exterior approach would need to be compliant. But this will be an exit door as well with the approach from the interior. That would need to comply from my perspective.

That I understand, but what compels an existing door, one that provides an accessible entry (not an accessible egress) to become accessible / to provide a level landing?

I understand that if this was a new door or a required exit, we'd need to follow Ch 10 requirements. But in an existing building, what section of code forces us to upgrade all existing exits? I should have been more clear in my original post - this is not a required exit door.

Also, how would 11B-207.1, exception 3 work in this? I'm still unclear how to determine if something is considered an "existing building". I've gotten at least three different answers across a few posts lol.

 

[Yikes]

Chapter 10 would require the level landing on both sides of a door. Exterior landing can have 2% slope for drainage. The maneuvering space requirements from 11B are specific to how the door will be approached and used. If this was an entry only door with no hardware on the interior I could see your point and only the exterior approach would need to be compliant. But this will be an exit door as well with the approach from the interior. That would need to comply from my perspective.

CBC 1010.1.2 says a level landing is min. 44" deep. CBC 11B-404 will have that landing at more like 48-60" deep, depending on door swing direction and approach. So relying on Ch 10 to supply an answer, even if it turns out to apply to an existing building, still won't be sufficient to fully address arwat23's initial accessibility question.

 

[JPohling]

It sounds to me that this door was added without a permit. This non permitted door was never in compliance for exiting due to the non level landing within the maneuvering space when the door is approached from the interior as an exit door. I am assuming it is in compliance for an entry approach. Now you are doing a permitted interior improvement and want to use this door as an entry door and a "non required exit". 99% of user's in an emergency will seek out the door they entered in order to escape. If you truly do not want to use the door as an exit then remove the operable door hardware from the interior of the door and any exit signage above it. That would eliminate any need for the maneuvering space from the interior. Provide exit signage leading to the compliant exit door. Is that a good solution? No

 

[Yankee Chronicler]

In IEBC- if the renovation is Alteration level 1 or 2 you can use the provisions of IEBC, but if alteration level 3 which is alteration to more than 50% of the building, then it's not an existing building anymore. You'll have to treat it as a new building with all the requirements that apply to IBC including egress, accessibility, etc.. All doors will have to have the maneuvering clearance requirements for egress on both sides whether they are accessible or not accessible.

This is absolutely incorrect. Even in a Level 3 alteration using the Work Area Method of compliance (which is the only method to which Level 1, Level 2, and Level 3 apply), you have to refer to IBC requirements for new construction only where and when the IBC specifically refers you to the IBC. The IEBC has a blanket exemption for accessible means of egress in existing buildings, and accessibility in existing buildings is address in Chapter 3 of the IEBC.

2021 IEBC:

306.7.2 Accessible means of egress. Accessible means of
egress required by Chapter 10 of the International Building
Code are not required to be added in existing
facilities.

Existing accessibility cannot be reduced by alterations:

306.3 Maintenance and repair. A facility that is
constructed or altered to be accessible shall be maintained
accessible during occupancy. Required accessible means of
egress shall be maintained during construction, demolition,
remodeling or alterations and additions to any occupied
building.

Exception: Existing means of egress need not be maintained
where approved temporary means of egress and
accessible means of egress systems and facilities are
provided.

306.3.1 Prohibited reduction in accessibility. An alteration
that decreases or has the effect of decreasing
accessibility of a building, facility or element, thereof,
below the requirements for new construction at the time
of the alteration is prohibited. The number of accessible
elements need not exceed that required for new construction
at the time of alteration.

This means if there's an old building that doesn't have any accessible means of egress -- nothing in the IEBC requires an alteration to create accessible means of egress where none existed previously. However, existing accessible means of egress cannot be removed unless there are more than what is required for new construction.

 

[Yankee Chronicler]

Back to the original question/problem: I think you're getting hung up on whether or not the door is an "egress" door. The code (whether you use the ADAS or A117.1) establishes maneuvering clearances for approaching a door from the pull side and from the push side. Those maneuvering clearances apply to anyone using that door, whether it's for ingress, egress, or internal circulation. If people can walk through the door, the maneuvering clearances have to be provided.

 

[Yankee Chronicler]

Can you explain how it's incorrect in your world? which part is incorrect? In my world- I learned from different code discussions with building officials, that almost everything will need to comply with IBC if a building goes under alteration level 3- The only thing that may not be much affected is the existing structural components because they're already built.
That's my understanding.

Just because you heard something from a code official doesn't mean it's correct, or that said code official knows what he/she is talking about.

In the old days, pre-ICC, my corner of the USA used the BOCA code. There was no Existing Building Code -- alterations fell under the BOCA Building Code. The general rule in the BOCA code was for alterations less than 25% of the building valuation, you could use materials the same as the original construction. For alterations between 25% and 50% of the building valuation, existing construction could remain unchanged and all new work had to comply with the current building code. For alterations exceeding 50% of the building value, the entire building bad to be upgraded to comply with the current code.

It sounds to me very much like your code official mentor is still applying the old 0%/25%/50% approach -- which is NOT reflected in the IEBC.

 

[Yankee Chronicler]

Correction to post #35, above. Typo. I typed "This is absolutely incorrect. Even in a Level 3 alteration using the Work Area Method of compliance (which is the only method to which Level 1, Level 2, and Level 3 apply), you have to refer to IBC requirements for new construction only where and when the IBC specifically refers you to the IBC."

That should have been "This is absolutely incorrect. Even in a Level 3 alteration using the Work Area Method of compliance (which is the only method to which Level 1, Level 2, and Level 3 apply), you have to refer to IBC requirements for new construction only where and when the IEBC specifically refers you to the IBC."

Unfortunately, our fearless leader has the editing time-out set for such a short duration that by the time I noticed the typo, I wasn't allowed to correct it.

 

[arwat23]

Back to the original question/problem: I think you're getting hung up on whether or not the door is an "egress" door. The code (whether you use the ADAS or A117.1) establishes maneuvering clearances for approaching a door from the pull side and from the push side. Those maneuvering clearances apply to anyone using that door, whether it's for ingress, egress, or internal circulation. If people can walk through the door, the maneuvering clearances have to be provided.

YES, this is the issue. The way I read code (ADAS, A117.1, and CBC 11B), the maneuvering clearance only applies to the approach side of a door. If an accessible means of egress isn't required in existing buildings (CBC 11B-207.1, exception 3 - assuming this even applies - and IEBC 306.7.2, which technically doesn't apply because California is built different), why would the maneuvering clearance be required?

Scenario 1: Those exceptions do NOT apply and an accessible means of egress is required. I don't see any possible argue against the maneuvering space requirement in this scenario.

Scenario 2: Those exceptions apply, but the way I read the maneuvering space sections is wrong and the "approach" clearances are still required on the opposite side for the door.

Scenario 3: The exceptions apply. No accessible egress required. As long as there is an accessible route that get's you into the space, that's all that's technically required. The maneuvering clearance on the interior side can be exempt because an accessible means of egress is flat out not required.

Scenario 4: None of the above matters. The door leads to an accessible space and needs maneuvering clearances on both sides if both sides are operable. While not always correct according to DSA-AC, maybe I'm missing something.

 

[Yankee Chronicler]

YES, this is the issue. The way I read code (ADAS, A117.1, and CBC 11B), the maneuvering clearance only applies to the approach side of a door. If an accessible means of egress isn't required in existing buildings (CBC 11B-207.1, exception 3 - assuming this even applies - and IEBC 306.7.2, which technically doesn't apply because California is built different), why would the maneuvering clearance be required?

You DO understand that the federal Americans with Disabilities Act is not a building code, but civil rights/anti-discrimination legislation -- right? I hope you understand that, because that's what it is.

Are you arguing that no one will ever be allowed to use that door to leave the building? That's what you're saying. Maneuvering clearances are to allow all people who have disabilities the same (or as nearly the same as possible) ability to get around a building as the able-bodied. And not all mobility impairments require the use of a wheelchair. Most doors allow people to pass through them in both directions, which means that both sides are "approach" sides, depending on which direction a person happens to be walking.

 

[Mr. Inspector]

This means if there's an old building that doesn't have any accessible means of egress -- nothing in the IEBC requires an alteration to create accessible means of egress where none existed previously. However, existing accessible means of egress cannot be removed unless there are more than what is required for new construction.

This was always a problem for me since a lot of the existing buildings I inspect never had a C. O. or there is no information, and the codes just started 20 years ago. I cannot tell if the building or space ever a had an accessible means of egress to begin with. So, I have to assume it never had an accessible means of egress and it is not required now.

 

[Yankee Chronicler]

IMHO it doesn't matter whether or not this door is an accessible means of egress. It requires a level landing on both sides because of chapter 10.

1010.1.4 Floor Elevation
There shall be a floor or landing on each side of a door. Such floor or landing shall be at the same elevation on each side of the door. Landings shall be level except for exterior landings, which are permitted to have a slope not to exceed 0.25 unit vertical in 12 units horizontal (2-percent slope).

1010.1.5 Landings at Doors
Landings shall have a width not less than the width of the stairway or the door, whichever is greater. Doors in the fully open position shall not reduce a required dimension by more than 7 inches (178 mm). Where a landing serves an occupant load of 50 or more, doors in any position shall not reduce the landing to less than one-half its required width. Landings shall have a length measured in the direction of travel of not less than 44 inches (1118 mm).

 

[arwat23]

You DO understand that the federal Americans with Disabilities Act is not a building code, but civil rights/anti-discrimination legislation -- right? I hope you understand that, because that's what it is.

Are you arguing that no one will ever be allowed to use that door to leave the building? That's what you're saying. Maneuvering clearances are to allow all people who have disabilities the same (or as nearly the same as possible) ability to get around a building as the able-bodied. And not all mobility impairments require the use of a wheelchair. Most doors allow people to pass through them in both directions, which means that both sides are "approach" sides, depending on which direction a person happens to be walking.

Yes, I understand. That's not my question. My question is in regards to what the inspector brought up, which involved CBC 11B (ADAS) and CBC Ch 10, neither of which seem to required an accessible means of egress in existing buildings.

Like you said, any existing accessible means of egress need to remain / cannot be removed. I get that. That's not the issue.

But fine, let's look at the 2010 ADAS and follow exactly what that says for comparison. ADAS 207.1 states that an accessible means of egress shall comply with the 2000 IBC section 1003.2.13. That section of IBC has an exception for existing buildings.


What you're saying makes complete logical sense. I won't deny that. Providing an accessible entry without an accessible exit seems wrong. I just can't find anything to justify the requirement in existing buildings.

 

[arwat23]

IMHO it doesn't matter whether or not this door is an accessible means of egress. It requires a level landing on both sides because of chapter 10.

I missed 1010.1... My bad on that. The inspector only referenced accessibility code, so I didn't bother checking other sections. My bad.