Guard Shack Accessibility Requirements

[Mech]

2018 IBC

Proposed guard shack at a parking lot for tractor trailers. The guard shack is the only building on the site. Its floor area is less than 300 sf.

I am being told by the GC that it will be 7" above grade and therefore the entire guard shack is exempt from accessibility requirements per 1103.2.2.

1103.2.2 Employee work areas. Spaces and elements within employee work area shall only be required to comply with Sections 907.5.2.3.1, 1009 and 1104.3.1 and shall be designed and constructed so that individuals with disabilities can approach, enter and exit the work area. Work areas , or portions of work areas, other than raised courtroom stations in accordance with Section 1108.4.1.4, that are less than 300 square feet in area and located 7 inches or more above or below the ground or finished floor where the change in elevation is essential to the function of the space shall be exempt from all requirements.

The definition of "employee work area" specifically states toilet rooms are not an employee work area, which means the toilet room must be accessible.

I have not seen a site plan, but I do not think a guard shack raised 7" above adjacent grade is essential for a tractor trailer storage lot.

Q1. Am I correct stating that even if the work area is exempt, the toilet room must be accessible?

Q2. If the work area is exempt, could the toilet room also be exempt if the shack is not open to anyone other than employees?

Q3. If the toilet room is accessible, would I be correct to state that the building must be accessible and requires and accessible entrance and exit?

Q4. The last sentence of section 1103.2.2 above " . . .shall be exempt from all requirements." What requirements would be exempt? Anything referenced in Section 1103 or the entire Chapter 11?

Q5. Could section 1103.2.6 Raised areas be used to exempt accessibility requirements?

1103.2.6 Raised areas. Raised areas used primarily for purposes of security, life safety or fire safety including, but not limited to, observation galleries, prison guard towers, fire towers or lifeguard stands are not required to comply with this chapter.

I think trying to use section 1103.2.6 is a stretch, but if it can legitimately be used . . .


Thanks for any insight. I do not try to exempt accessibility requirements except janitor closets, electrical and machinery rooms, and pathways to floors or mezzanines less than 3,000 sf, so these sections are new to me.

 

[ICE]

I have not seen a site plan, but I do not think a guard shack raised 7" above adjacent grade is essential for a tractor trailer storage lot.

The driveway is most likely sloped to drain rainwater and the guard shack is raised to keep the water out. I’ve seen them where the guard is elevated to the level of the truck driver.

 

[north star]

@ ~ @

Yikes, ...Yes, there are Guard Shacks for trailer lots and
everything else in between.........IMO, your listed Sections
of 1103.2.6 & 1108.4.1.4 exempts the structure from
Accessibility requirements [ e.g - security ].........Isn't
there an exemption also for "able bodied persons only" ?

@ ~ @

 

[Yikes]

1103.2.6 can be used, and it’s not a stretch. Here’s the same language in the ADA Standards 203.3:
”Areas raised primarily for purposes of security, life safety, or fire safety, including but not limited to, observation or lookout galleries, prison guard towers, fire towers or life guard stands shall not be required to comply with these requirements or to be on an accessible route.”

There is no requirement that the raising for the security area be related to observation vs. drainage, or anything else. The only requirement is that it be used primarily for purposes of security, or life safety, or fire safety. "Security" can have multiple meanings. For example, if it is used by a parking lot attendant who watches for vehicles entering the lot, then collects money and hands out receipts, that a person who is securing the site against the theft of income when someone tries to park and leave without paying.

 

[RLGA]

I agree, it is exempt.

To @north star, there is no exemption for able-bodied persons in ANSI A117.1, the 2004 ADA-ABA Accessibility Guidelines, or the 2010 ADA Standards. The 1984 UFAS has such a requirement for military facilities; however, the DOD has adopted the ABA portion of the 2004 ADA-ABA Accessibility Guidelines. The only federal agency that I know of that has adopted the UFAS is HUD, so the "able-bodied" exemption is essentially gone from the world of accessible design and replaced by somewhat more specific exemptions.

 

[north star]

@ ~ @ ~ @

Ron, are you familiar with the Unified Facilities Criteria ( UFC's )
for each branch of the Armed Forces ?.....Some A.F. Branches
use these Standards as part of their designs for new construction.

Also, do you know when the DoD officially adopted the ADA - ABA
Guidelines ?........Are any of the new MilCon Projects currently in
design, or already contracted, required to comply with full
Accessibility ?

Thank you !

@ ~ @ ~ @

 

[tbz]

I always thought the DOD adopted latest in Oct, 2008, as noted from the memorandum on the Access Board's website.

U.S. Access Board - Dod Policy Memo

The U.S. Access Board is a federal agency that promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards for the built environment, transportation, communication, medical diagnostic equipment, and...

www.access-board.gov

 

[RLGA]

@ ~ @ ~ @

Ron, are you familiar with the Unified Facilities Criteria ( UFC's )
for each branch of the Armed Forces ?.....Some A.F. Branches
use these Standards as part of their designs for new construction.

Also, do you know when the DoD officially adopted the ADA - ABA
Guidelines ?........Are any of the new MilCon Projects currently in
design, or already contracted, required to comply with full
Accessibility ?

Thank you !

@ ~ @ ~ @

Yes, I am familiar with the UFC. I was an active duty Air Force architect for four years, two of which were managing MilCon projects on my base. The rest of my 23-year career was as a reservist in the civil engineering career field and retired as an O-5.

The DOD adopted the ABA Accessibility Guidelines in October 2008. Although the ABA Accessibility Guidelines do not mention "able-bodied," the DOD policy has made some exclusions:

"3. EXCLUSIONS. The following facilities need not comply with these DoD Standards:​

​

"(a) Facilities, or portions of facilities, on a military installation that are designed and constructed for use exclusively by able-bodied military personnel.​

​

"(b) Reserve and National Guard facilities, or portions of such facilities, owned by or under the control of the Department of Defense, that are designed and constructed for use exclusively by able-bodied military personnel.​

​

"(c) Facilities obtained in emergencies such as natural disasters or in an area where contingency operations are being conducted.​

​

"Nevertheless, since the intended use of such excluded facilities may change with time or in emergencies, compliance with these DoD Standards is recommended to the maximum extent that is reasonable and practicable without degrading the facility’s military utility."​

​

The last part means designers should try to comply with the ABA Accessibility Guidelines unless it is exempted above and is unfeasible or would impair its military function.

 

[north star]

@ ~ @ ~ @

O.K., thanks Ron for the info !......In the past I was reviewing some
plans for renovations at a very large National Guard Training Center,
and Leadership used the "able bodied personnel" exemption on the
plans.

And "Thank You" for your service !

@ ~ @ ~ @