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Existing Building Bathroom Accessibility

R

rosegamble

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Jul 9, 2021
Messages
67
Location
South Carolina
Working with an old CPA's office, turning it into a coffee shop. Level 2 or Level 3 alteration (TBD), no change of occupancy classification (B to B). There is an existing bathroom which will be renovated with new plumbing fixtures. It is not accessible (clearances). Does it need to be made accessible? The 2021 Existing Building Code is the code enforced. I know Chapter 3 applies in entirety to the project.

Thoughts? There seems to be a lot of gray area in the accessibility code. Thanks!
 
Definitions:

[A] CHANGE OF OCCUPANCY. Any of the following shall be considered as a change of occupancy where the current International Building Code requires a greater degree of safety, accessibility, structural strength, fire protection, means of egress, ventilation or sanitation than is existing in the current building or structure:

  1. Any change in the occupancy classification of a building or structure.
  2. Any change in the purpose of, or a change in the level of activity within, a building or structure.
  3. A change of use.
[A] CHANGE OF USE. A change in the use of a building or a portion of a building, within the same group classification, for which there is a change in application of the code requirements.

It is still a change of occupancy according to the IEBC.
 
Yes, I see that! Thanks. I guess I should be more clear that 1011 would not apply, but the rest of 10 would. I don't think that affects the bathroom question though, does it? 306.7 applies to the project regardless of the occupancy change within the same group classification. It seems like the only possible workaround to updating the bathroom would be the 306.7.1 (Exception 1).
RLGA said:
Definitions:

[A] CHANGE OF OCCUPANCY. Any of the following shall be considered as a change of occupancy where the current International Building Code requires a greater degree of safety, accessibility, structural strength, fire protection, means of egress, ventilation or sanitation than is existing in the current building or structure:

  1. Any change in the occupancy classification of a building or structure.
  2. Any change in the purpose of, or a change in the level of activity within, a building or structure.
  3. A change of use.
[A] CHANGE OF USE. A change in the use of a building or a portion of a building, within the same group classification, for which there is a change in application of the code requirements.

It is still a change of occupancy according to the IEBC.
Click to expand...
 
This particular topic confounds me every time. By definition, as RLGA points out, the IEBC considers the change of use to be a change of occupancy. However, chapter 10, TITLED CHANGE OF OCCUPANCY then says this:

1001.2.1 Change of use. Any work undertaken in
connection with a change in use that does not involve a
change of occupancy classification or a change to another
group within an occupancy classification shall conform to
the applicable requirements for the work as classified in
Chapter 6 and to the requirements of Sections 1002
through 1010.

So in ch. 2; DEFINITIONS, a change of use is a change of occupancy, but in ch. 10; CHANGE OF OCCUPANCY, a change of use that is not a change of occupancy classification is not a change of occupancy. This then seems to not require compliance with 1011 if there is a change in use, without a change of occupancy classification. I know they have been trying to improve this. I think they went the other direction. JMHO.

I digress though. I think 306 applies no matter what, and you are altering an area of primary function. I don't see 306.7.1 as a work around, just a cap on the amount.
 
Rosegamble, I know you are focused on what the building department will require via the IEBC.
But separately from that, aren't you also already also required under civil law to comply with 2010 ADA Standards 202.3 for alterations, unless you have a technical infeasibility?
 
rosegamble said:
Working with an old CPA's office, turning it into a coffee shop. Level 2 or Level 3 alteration (TBD), no change of occupancy classification (B to B). There is an existing bathroom which will be renovated with new plumbing fixtures. It is not accessible (clearances). Does it need to be made accessible? The 2021 Existing Building Code is the code enforced. I know Chapter 3 applies in entirety to the project.

Thoughts? There seems to be a lot of gray area in the accessibility code. Thanks!
Click to expand...

IEBC 306.7.1. IMHO, the toilet rooms need to be made accessible unless an amount equal to or exceeding 20% of the total construction cost has been spent on other accessibility upgrades.

The entire intent of the ADA and, as a result, the IEBC and ICC/ANSI A117.1 is eventual upgrades of existing structures for as close to 100% accessibility as is technically feasible. While it is understood that requiring a small project to bear the entire cost of all improvements needed to make an existing building or tenant area accessible may be an undue burden, the application of "the 20% rule" results in a bit more accessibility with each subsequent alteration, with the hope and expectation being eventual full accessibility.

What's the project cost, and where are you spending 20% of that on accessibility improvements?
 
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