Existing Restroom walls and door

[Mech]

2009 IBC w/ 2012 IBC Chapter 11

2009 ANSI / ICC A117.1

ADA

2000 NFPA 101 - Life Safety Code

I am trying to establish a 30 minute fire rated smoke partition in an existing nursing home to comply with the 2000 Life Safety Code.

Ideally, a non-accessible single user restroom door and wall (not currently rated) would be upgraded to provide part of the fire rated smoke partition. The drawings for this previous renovation are dated January 1990; ADA was not signed into law until later in the year. The only item that might be accessible in this restroom is the light switch. The room is too small (maybe 5' x 4'-6") to relocate either the plumbing fixtures or the door to provide all the necessary clearances.

Can the drywall be changed without requiring the restroom to be made accessible?

Can the existing door and frame be changed without enlarging it to provide 34" clearance when the door is open? I understand the door knobs would be replaced with levers. I think there is sufficient room to install a compliant door, but there will not be adequate maneuvering space inside the restroom.

Can a door closer be added to the door without making the restroom accessible? If not, can an electrically operated door opener / closer be added without making the restroom accessible?

If there were sufficient room to reconstruct the restroom as 100% compliant, I would not be opposed to it.

Thanks

 

[ICE]

I think there is sufficient room to install a compliant door, but there will not be adequate maneuvering space inside the restroom.

It's not just about wheelchair space. 34" isn't much when using crutches or being fatboy.

 

[Mr. Inspector]

Existing Restroom walls and door

If the restroom was not accessible to begin with and you are not relocating the walls it does not need to be accessible now. Code requires that at least 20% be spent only on the accessible route when doing alterations, not the restrooms.

 

[JBI]

Are you using the Existing Building Code or are you using Chapter 34/Appendix K in the IBC? Those are the starting points for work in existing buildings.

Using Chapter 11 of the IBC will not give you any breaks for an existing condition...

That's what EBC and Chapter34/Appendix K are intended to do.

 

[Mech]

Are you using the Existing Building Code or are you using Chapter 34/Appendix K in the IBC?

I am attempting to use Chapter 34 in the 2009 IBC. Appendix K appears to be electrical.

 

[steveray]

I wouldn't let you swap in a noncompliant door...I'd go with 20% upgrade, make you fill out the form below and move on with my day......If you change an element, it complies. I do not believe if you change one sheet of drywall that the whole room needs to comply...And I would let the owner know that they may be meeting the code, but that does not get them off the hook with ADA....

 

[JPohling]

I would guess that a fully complying toilet room would be a nice amenity in a nursing home. That being said I do not believe that you need to provide one. Was this fire rating not required previously? Why now? Fully agree with 20% towards improving accessibility.

 

[Mech]

Was this fire rating not required previously? Why now?

Yes, a fire rated smoke partition was required. Somewhere in the past 20 years, the continuity was broken and it must be restored. Logistically, it is more desirable to re-route / create the smoke partition through an office area and some other rooms that are not occupied by many people than to restore the original partition in a building portion vital to day-to-day operations.

 

[Mech]

Steveray: I get confused by Chapter 34. :banghd

3404.1 General. Except as provided by Section 3401.4 or this section, alterations to any building or structure shall comply with the requirements of the code for new construction. Alterations shall be such that the existing building or structure is no less complying with the provisions of this code than the existing building or structure was prior to the alteration.

Exceptions:

1. An existing stairway shall not be required to comply with the requirements of Section 1009 where the existing space and construction does not allow a reduction in pitch or slope.

2. Handrails otherwise required to comply with Section 1009.12 shall not be required to comply with the requirements of Section 1012.6 regarding full extension of the handrails where such extensions would be hazardous due to plan configuration.

The underlining is mine. Does that portion indicate a new non-compliant door can replace the existing door (not considered compliant by today's codes?)

 

[mtlogcabin]

Can the drywall be changed without requiring the restroom to be made accessible?

Yes, However if you are removing gypsum board you should install backing and appropriate grab bars and maybe a higher WC. Remember you are only required to spend 20% of the cost of your improvements. Although the existing restroom may not be "wheelchair" accessible it could be "ambulatory" and therefore it would be an improvement.

Are there restrooms nearby that are wheelchair accessible?

 

[JPohling]

The goal is to increase accessibility and in the future have a complying sanitary facility. I would not replace a non complying door with anything other than a fully complying one.

 

[JBI]

A few selected sections of Chapter 34 that are applicable, I believe...

If it is in fact 'technically infeasible' then 4311.6 could be a saving grace.

3411.8 on the other hand would cause you tribulations if it is not truly 'technically infeasible'. Pay attention to the thresholds in these sub-sections.It's a shame you've not adopted the Existing Building Code... much more comprehensive than Chapter 34.

3411.3 Extent of application. An alteration of an existing element, space or area of a building or facility shall not impose a requirement for greater accessibility than that which would be required for new construction.

Alterations shall not reduce or have the effect of reducing accessibility of a building, portion of a building or facility.

3411.6 Alterations. A building, facility or element that is altered shall comply with the applicable provisions in Chapter 11 of this code and ICC A117.1, unless technically infeasible. Where compliance with this section is technically infeasible, the alteration shall provide access to the maximum extent technically feasible

3411.8 Scoping for alterations. The provisions of Sections 3411.8.1 through 3411.8.14 shall apply to alterations to existing buildings and facilities.

3411.8.7 Accessible dwelling or sleeping units. Where Group I-1, I-2, I-3, R-1, R-2 or R-4 dwelling or sleeping units are being altered or added, the requirements of Section 1107 for Accessible units apply only to the quantity of spaces being altered or added.

3411.8.8 Type A dwelling or sleeping units. Where more than 20 Group R-2 dwelling or sleeping units are being added, the requirements of Section 1107 for Type A units apply only to the quantity of the spaces being added.

3411.8.9 Type B dwelling or sleeping units. Where four or more Group I-1, I-2, R-1, R-2, R-3 or R-4 dwelling or sleeping units are being added, the requirements of Section 1107 for Type B units apply only to the quantity of the spaces being added.

3411.8.11 Toilet rooms. Where it is technically infeasible to alter existing toilet and bathing facilities to be accessible, an accessible family or assisted-use toilet or bathing facility constructed in accordance with Section 1109.2.1 is permitted. The family or assisted-use facility shall be located on the same floor and in the same area as the existing facilities.

 

[Mech]

Although the existing restroom may not be "wheelchair" accessible it could be "ambulatory" and therefore it would be an improvement.

Agreed. I do not recall what type of faucet is on the lav, but there may be room for improvement just by changing it to an accessible one.

Are there restrooms nearby that are wheelchair accessible?

Unfortunately, it does not appear so.

I would not replace a non complying door with anything other than a fully complying one.

Noted; I can call out a 36" door on the plans. Would the addition of a door closer be considered a reduction in accessibility? I am thinking it does reduce accessibility because it may be more difficult to exit the rest room.

 

[steveray]

If you don't have manuvering clearance, I would not add the closer.....IMO

 

[JPohling]

If this is a toilet room used by the folks that are living in the nursing home I would also highly recommend that the new door swing out if possible. Typical health care design.

 

[Mech]

Toilet room is for the staff. Swinging the door outward would be better for the restroom user, but it would swing into the path of egress in the hallway / corridor / passageway.

I am looking at running the smoke partition around the restroom (replace drywall on three walls instead of one wall and the need to replace the door.)

The easiest option might be to tear down the building and start over.

 

[ADAguy]

Staff you say? That makes it a Title I accommodation unless there are no other staff accessible RR's. Changes accommodating ambulatory persons are a good thing, disabilities come in many flavors not all requiring wheelchairs.

 

[peach]

at some point, the facility is going to probably be forced to add an accessible staff restroom (maybe by way of a lawsuit); it might be the right time for them to carve out some space for one. In the past few months, I've grown a healthier appreciation for accessible/ambulatory restrooms in commercial buildings.