Florida Accessibility Scoping Requirements and Structural Impracticability

[jar546]

Florida removed Chapter 11 of the FBC (IBC) and placed the scoping in the ANSI A117.1 but call it the FBC Accessibility. Under the scoping requirements, there is a section called Structural Impracticability. Here is what it means. This is not the code verbatim, but explained.

Section 203.15 titled "Structural Impracticability" in a building or accessibility code outlines guidelines for situations where full compliance with certain accessibility requirements is not feasible due to unique structural constraints. Here's a breakdown of what each subsection means:

1. 203.15.1: This part states that full compliance with accessibility requirements is not mandatory if it can be demonstrated that meeting these requirements is structurally impracticable. This means that due to unique characteristics of the terrain or the specific structural aspects of a building, it might not be possible to incorporate all accessibility features. The term "structurally impracticable" is reserved for rare circumstances where the physical environment significantly hinders accessibility modifications.
2. 203.15.2: If it's determined that full compliance is structurally impracticable, the entity must still comply with the accessibility requirements to the extent that is structurally feasible. Essentially, this means that any part of the building or facility that can be reasonably modified to enhance accessibility should be altered, even if full compliance is not possible.
3. 203.15.3: This part addresses the scenario where providing full accessibility for individuals with certain disabilities (like those using wheelchairs) is structurally impracticable. In such cases, the entity should still ensure accessibility for people with other types of disabilities (like those using crutches or those with visual, hearing, or mental impairments) as per the code requirements. This ensures that even if complete accessibility is not feasible, the needs of a broader range of disabilities are still considered and accommodated to the greatest extent possible.

Overall, this section of the code acknowledges that while striving for full accessibility is the goal, there may be rare instances where structural limitations make this unachievable. In such cases, the requirement is to make the facility as accessible as possible within the constraints of the existing structure. This approach ensures a balance between practical construction limitations and the need to provide accessibility to individuals with disabilities.

 

[Yankee Chronicler]

This is consistent with the ADA, which has always recognized the reality that requiring major structural alterations in order to achieve accessibility is not practical. Hence the term "technically infeasible."

Technical Infeasibility

Compliance in an alteration is not required where it is “technically infeasible.” The term is defined as “something that has little likelihood of being accomplished because existing structural...

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