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Elevators required after overall building has a total of 3000sf of mezzanines.

Ryan Schultz

Ryan Schultz

SAWHORSE
Joined
Apr 2, 2012
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283
Location
Madison, WI
If you have a scenario, like the following, in an existing, sprinkled, 1 story building, where (3) business suite have existing 1000sf mezzanines without an elevator, can the 4th business suite add a mezzanine without adding an elevator?

Per 1104.4 I would think they could not, because the overall building already has a max 3000sf that is not accessible.

Assume no firewalls, or fire barriers.

Thank you for your interpretation.


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Generally speaking, if it were new construction and following the provisions of the IBC, I would agree that an elevator is required. Simple reference being 1104.4 as indicated.

Speaking from the IEBC, it is a bit more gray.

Initially, one must decide if the construction of the mezzanine is an addition or an alteration.
  • As an addition, IEBC 306.6 would require conformance to the IBC and thus 1104.4.
  • As an alteration, IEBC 306.7 again requires conformance to the IBC, but provides exceptions for technically infeasible and provides requirements and exceptions for areas containing a primary function.
To differentiate between an addition and an alteration, I'd go to the definition of each (as follows). Herein I have encountered multiple views regarding mezzanines as they relate to additions. Under IBC 505.2 (Mezzanines), we know that mezzanines are not included in building area, but are included in fire area; however, floor area is not specified, nor is floor area a defined term for other than gross/net OLF. Therefore, where I've seen distinction, does a mezzanine increase floor area?
  • [A] ADDITION. An extension or increase in floor area, number of stories, or height of a building or structure.
  • [A] ALTERATION. Any construction or renovation to an existing structure other than a repair or addition.
If you are in the camp that a mezzanine does not increase the floor area, then you may point towards applying Exception #1 to IEBC 306.7.1 (the 20% rule). Under this exception, "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."

However, if you are in the camp that would include the mezzanine's area within floor area, then you'd follow the route of an addition, feeding back to IBC 1104.4 that limits mezzanines to an aggregate area of not more than 3,000sf.

Personally, I have been in the camp that the erection of a mezzanine constitutes an increase in floor area and is therefore an addition. My basis being that the mezzanine has an occupant load that is included in the occupant load area calculations and contributes to the area where people or commodities may congregate or be stored. Basically, I take the meaning of floor area to be the measurement of usable area within a building. A mezzanine contributes to the usable area, and therefore would be included in measuring floor area.
 
The other issue to consider is regarding goods and services available.

1108.2.1 Services.
If a service or facility is provided in an area that is not accessible, the same service or facility shall be provided on an accessible level and shall be accessible.

If this is retail sales area then you would need to duplicate the goods available on the mezzanine on the accessible floor or provide accessibility to the mezzanine regardless of the square footage. If storage mezzanine then your back to the 3,000 SF trigger
 
JPohling said:
The other issue to consider is regarding goods and services available.

1108.2.1 Services.
If a service or facility is provided in an area that is not accessible, the same service or facility shall be provided on an accessible level and shall be accessible.

If this is retail sales area then you would need to duplicate the goods available on the mezzanine on the accessible floor or provide accessibility to the mezzanine regardless of the square footage. If storage mezzanine then your back to the 3,000 SF trigger
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Had to take a look because I was curious about the reference you provided. In the 2021 IBC, 1108 is Dwelling and Sleeping units, but I was able to figure out that you are using the 2018 code and the sections were changed up a bit.

I'm going to post the 2021 code, but the language is the same.

I think that you need to take a look at the preceding section, 1109.2, as it is dealing with assembly area seating. Given that the question herein is related to a mezzanine for a Group B occupancy, I do not agree with looking to this section for making the requirement indicated. It is not applicable given the lack of assembly area seating.

2021 IBC 1109.2 Assembly Area Seating (2018 IBC 1108.2)​

A building, room or space used for assembly purposes with fixed seating shall comply with Sections 1109.2.1 through 1109.2.5. Lawn seating shall comply with Section 1109.2.6. Assistive listening systems shall comply with Section 1109.2.7. Performance areas viewed from assembly seating areas shall comply with Section 1109.2.8. Dining areas shall comply with Section 1109.2.9.

1109.2.1 Services (2018 IBC 1108.2.1)​

If a service or facility is provided in an area that is not accessible, the same service or facility shall be provided on an accessible level and shall be accessible.​
 
Good catch Classic. I will need to look further. We have called out many times for not having the same "goods and services" within a B occupancy office suite where we may have a break room only located on the second non accessible floor. Break room relocated or duplicated to avoid an elevator. Typically California. I have recently had an Arizona BO using the 2018 IBC indicate that "goods and services" requirement specifically on a M occupancy mezzanine. more research needed
 
Ryan Schultz said:
can the 4th business suite add a mezzanine without adding an elevator?
Click to expand...
Yes, an elevator would not be required since they are separate tenant spaces. The aggregated size of a mezzanine is limited to the size of the room they are located in.
EXAMPLE: A new single-story mall with over 100 stores. Some have a mezzanine, and some do not. Those that do are less than 1,000 Sq Ft. the 3 anchor stores have mezzanines exceeding 3,500 each. The 4th has 2 mezzanines within the sales floor area that exceed 1,600 sq ft each.
Are elevators required for every mezzanine within the mall building?

505.2.1 Area limitation.
The aggregate area of a mezzanine or mezzanines within a room shall be not greater than one-third of the floor area of that room or space in which they are located.
 
mtlogcabin said:
Yes, an elevator would not be required since they are separate tenant spaces. The aggregated size of a mezzanine is limited to the size of the room they are located in.
EXAMPLE: A new single-story mall with over 100 stores. Some have a mezzanine, and some do not. Those that do are less than 1,000 Sq Ft. the 3 anchor stores have mezzanines exceeding 3,500 each. The 4th has 2 mezzanines within the sales floor area that exceed 1,600 sq ft each.
Are elevators required for every mezzanine within the mall building?

505.2.1 Area limitation.
The aggregate area of a mezzanine or mezzanines within a room shall be not greater than one-third of the floor area of that room or space in which they are located.
Click to expand...
Mtlogcabin, it appears that you are conflating the mezzanine area limits in Ch. 5 with the accessibility requirements in Ch. 11.

I wholeheartedly disagree with you trying to use Ch. 5 to negate a Ch. 11 requirement. Remember that Ch. 11 is structured for compliance with federal law (ADA/FHA/HUD/etc.).
 
mtlogcabin said:
EXAMPLE: A new single-story mall with over 100 stores.
Click to expand...
Regarding malls, take note of Exception #1, Condition 1.1.

2021 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.
    5. Structures with four or more dwelling units.
  2. Stories, mezzanines or occupied roofs that do not contain accessible elements or other spaces as determined by Section 1108 or 1109 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.
 
mtlogcabin said:
Not a mezzanine but a floor level.

Okay it is a strip shopping center, and we will reduce the number of tenants to 25 and 15 have mezzanines in them. Do you require each tenant that has a mezzanine to install an elevator?

What is the intent behind the 3,000 sq ft exception?


View attachment 11568
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Your mall example was completely speculative, no real conditions provided. So, my answer was yes, a mall with a tenant count greater than 5 with a tenant space that is above or below the accessible level requires an elevator if the aggregate area exceeds 3000sf.

Regarding the interpretation from ICC, I am intrigued. The interpretation does not align with the text of the code. Given that the interpretation is from 2005 and addressing the 2003 edition, I am not sure I would put much merit behind it. If this was really an issue that needed clarified, then why has the code not been revised over the course of 6+ editions? Something amiss there.
 
I wonder whether the interpretation was cleared with Dept. of Justice for complying with the intent of ADA. ADA allows 3000 SF per floor before requiring an elevator, while the IBC tightened the exception to 3000 SF aggregate.
 
but what if the mezzanines are not located below another accessible level?

“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. “
 
MADrkTEK said:
but what if the mezzanines are not located below another accessible level?

“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...
I'm going to retract this inquiry. I confused myself with the double negatives "not required..." and "...not more than...."
 
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