How does IBC define new work in regards to Accessibility?

[Stanovby]

One question I always have when reviewing work in a commercial toilet room is that I am told that if you are doing new work in a toilet room you have to make it accessible. My question is what is meant by new work? If you are putting new floor tile & new wall tile does that mean you have to make everything totally 100% accessible? I know there is an argument about it not being feasible. For instance they are not going to make you move a bearing wall to make everything work, but otherwise does everything need to be accessible? If an existing water closet is 5'-0" wide with walls going from the floor to the ceiling it will not have the required toe clearance that ADA & ANSI specifies, but if we are not doing work in there we do not have to address that. Obviously if we are moving walls & totally remodeling the toilet rooms we need to address that, but if we are removing the fixtures so that we can put new finishes in & reinstalling fixtures in the same location, does the water closet stall need to be 5'-8" wide as at least one version of ANSI specifies?

 

[Yankee Chronicler]

Unless you are working in a jurisdiction that doesn't adopt the International Existing Building Code (IEBC), you shouldn't be looking at the IBC unless the IEBC sends you there, and then you only look at the section(s) or chapter(s) the IEBC sends you to. For most of the country, IEBC section 306 is where to start looking for accessibility requirements in existing buildings.

However ... you are in Maryland. According to UpCodes (which is not infallible -- we found another entire section of our state's version of the IBC that UpCodes completely omitted just last week -- neither Maryland nor Virginia has adopted the IEBC, so I'm afraid you are more or less on your own.

 

[Stanovby]

Unless you are working in a jurisdiction that doesn't adopt the International Existing Building Code (IEBC), you shouldn't be looking at the IBC unless the IEBC sends you there, and then you only look at the section(s) or chapter(s) the IEBC sends you to. For most of the country, IEBC section 306 is where to start looking for accessibility requirements in existing buildings.

However ... you are in Maryland. According to UpCodes (which is not infallible -- we found another entire section of our state's version of the IBC that UpCodes completely omitted just last week -- neither Maryland nor Virginia has adopted the IEBC, so I'm afraid you are more or less on your own.

That's a good point about IEBC. I don't have an account at upcodes so I might not have access to some things. I am in Maryland, but much of our work is in New York, New Jersey, North Carolina, & Pennsylvania. New York City would be the NYC building code, but everything else would be some sort of adoption of the IBC in most cases. I will look at the IEBC more closely to see what that says. It is a question that always comes up. Obviously if you gut everything & install new you have to make everything accessible, but if you just upgrade the finishes sometimes i am not so sure.

 

[steveray]

306.7 Alterations.​

A facility that is altered shall comply with the applicable provisions in Chapter 11 of the International Building Code, ICC A117.1 and the provisions of Sections 306.7.1 through 306.7.16, unless technically infeasible. Where compliance with this section is technically infeasible, the alteration shall provide access to the maximum extent technically feasible.

❖ The code approaches the application of accessibility provisions to a facility that is altered by broadly requiring full conformance, meaning full accessibility is expected. Exceptions are then provided to indicate the conditions under which less than full accessibility is permitted.
The circumstance under which full compliance with accessibility provisions is not required is when it is deemed to be technically infeasible (see the commentary for the definition of “Technically infeasible” in Section 202). This is considered reasonable since, if not provided for, plans for alterations may be otherwise abandoned by the building owner; the opportunity to upgrade and increase the current level of accessibility in an existing building would then be lost. This concern is also embodied in the requirement that an altered element or space is expected to be made accessible to the extent to which it is technically feasible to do so. In this manner, the code accomplishes the greatest degree of accessibility while recognizing the justifiable difficulties that may be involved in providing full accessibility. Alterations are not required to exceed new construction requirements (see Section 306.4).

 

[Stanovby]

306.7 Alterations.​

A facility that is altered shall comply with the applicable provisions in Chapter 11 of the International Building Code, ICC A117.1 and the provisions of Sections 306.7.1 through 306.7.16, unless technically infeasible. Where compliance with this section is technically infeasible, the alteration shall provide access to the maximum extent technically feasible.

❖ The code approaches the application of accessibility provisions to a facility that is altered by broadly requiring full conformance, meaning full accessibility is expected. Exceptions are then provided to indicate the conditions under which less than full accessibility is permitted.
The circumstance under which full compliance with accessibility provisions is not required is when it is deemed to be technically infeasible (see the commentary for the definition of “Technically infeasible” in Section 202). This is considered reasonable since, if not provided for, plans for alterations may be otherwise abandoned by the building owner; the opportunity to upgrade and increase the current level of accessibility in an existing building would then be lost. This concern is also embodied in the requirement that an altered element or space is expected to be made accessible to the extent to which it is technically feasible to do so. In this manner, the code accomplishes the greatest degree of accessibility while recognizing the justifiable difficulties that may be involved in providing full accessibility. Alterations are not required to exceed new construction requirements (see Section 306.4).

Thank you, I will look at those sections more closely. Also I want to look again at how they define alteration. If I remove fixtures & accessories and put new finishes in & then replace the fixtures and accessories in the same location is that still considered an alteration?

 

[Paul Sweet]

Virginia has adopted the IEBC, but has drastically amended it so there's not much left but the chapter titles.

 

[Yankee Chronicler]

Virginia has adopted the IEBC, but has drastically amended it so there's not much left but the chapter titles.

And they changed those from the ICC IEBC.

 

[Stanovby]

I read through IEBC and it does seem that my situation either falls under Level 1 Alteration which is the removal of finishes and fixtures or Level 2 which would be the total amount of work that we are usually doing. The toilet rooms are only part of the work being done. Either way it looks like it is pointing me to chapter 11 of IBC and therefore ANSI. The only thing would be if we can argue that making the existing water closet compartment 5'-8" wide for instance would be technically infeasible.

 

[Yankee Chronicler]

I read through IEBC and it does seem that my situation either falls under Level 1 Alteration which is the removal of finishes and fixtures or Level 2 which would be the total amount of work that we are usually doing. The toilet rooms are only part of the work being done. Either way it looks like it is pointing me to chapter 11 of IBC and therefore ANSI. The only thing would be if we can argue that making the existing water closet compartment 5'-8" wide for instance would be technically infeasible.

Remember that under the IEBC (unless the jurisdiction has royally screwed it up, as Virginia appears to have done), there are three methods on compliance. The applicant/designer gets to choose which path to follow. Option 3, the Performance Method, is the equivalent safety points scoresheet approach. Very few applicants choose that, but it is available to you.

Far too many architects get confused between the Prescriptive Method and the Work Area Method. The concept of Level 1, Level 2, and Level 3 applies ONLY to the Work Area Method.

Start with the definitions. You mentioned replacing finishes and fixtures. The classification of Work i Chapter 6 uses some of those words, but the definition of "Repair" also uses those words:

REPAIR. The reconstruction, replacement or renewal of
any part of an existing building for the purpose of its maintenance
or to correct damage.

Direct replacement of finishes and/or fixtures is typically a repair. The IEBC Commentary adds this to the definition of "Repair":

As indicated in Section 105.2.2, the repair of an item
typically does not require a permit. This definition
makes it clear: repair is limited to work on the item
and does not include complete or substantial replacement
or other new work. Note that the definition deals
with repair both as it relates to maintenance and to
fixing damage inflicted on a building for various reasons.
For example, the replacement of stairs due to
daily wear and tear is related to the maintenance of a
building, whereas a wall hit by a forklift or damage as
a result of an earthquake would be considered damage.

So what is an "Alteration"?

ALTERATION. Any construction or renovation to an
existing structure other than a repair or addition

Commentary on the definition of "Alterations":

The code utilizes this term to reflect construction
operations intended for an existing building, but not in
the scope of an addition or repair (see the definitions
of “Addition” and “Repair”).

So then we go to Chapter 3, "Provisions for all Compliance Methods." Note that per 301.1, repairs, alterations, changes of occupancy, and additions are subject to one of the subsections of 301, and to sections 302 through 309. However, section 301.3 says that only alterations, changes of use, and additions are subject to one of the methods in 301.3.1, 301.3.2, and 301.3.3. So "Repairs" are not subject to the classification of work, and are not considered to be alterations.

I don't know where to look for it under the new (2010) ADAS but, when the ADA and the original ADAAG first came out in 1994, most states had had accessibility requirements under UFAS and/or some edition of A117.1 for close to 20 years. There was a provision, either in the ADA itself or in the ADAAG, that a facility which had been made accessible under a previous standard did not have to be upgraded to comply with a newer accessibility standard. I don't know if this provision is still in the ADAS, or how it might impact state accessibility requirements under the IEBC and A117.1.

There appears to be considerable overlap[ between a "Repair" and a Level 1 Alteration. It may come down to the scope. If you have to patch the tile in a toilet room, that's a repair. If you strip it ALL out and replace it with all-new tile, that's a Level 1 Alteration. Ditto for fixtures. If you replace one fixture in a multi-fixture toilet room because it broke, that's clearly a repair. If you replace ALL the fixtures because they're shabby or outdated, that's a Level 1 Alteration. If you
add or eliminate any door or window, reconfigure or extend any system, or install any additional equipment, it becomes at least a Level 2 Alteration.

I don't think you can mix Level 1, Level 2, and Level 3 within a project. This, in an office alteration, even if all you're doing in the toilet rooms in replacing finishes and fixtures but NOT moving any walls, doors, or windows, but in the office areas you ARE adding or removing walls, doors, and/or windows, the entire project becomes a Level 2 Alteration. If the work area exceeds 50% of the floor area of the building, it rises to a Level 3 Alteration.

 

[Yankee Chronicler]

I read through IEBC and it does seem that my situation either falls under Level 1 Alteration which is the removal of finishes and fixtures or Level 2 which would be the total amount of work that we are usually doing. The toilet rooms are only part of the work being done. Either way it looks like it is pointing me to chapter 11 of IBC and therefore ANSI. The only thing would be if we can argue that making the existing water closet compartment 5'-8" wide for instance would be technically infeasible.

How is it technically infeasible? Are the walls enclosing the toilet compartment structural (load-bearing)? The ADA definition of "technically infeasible" is:

Technically Infeasible. With respect to an alteration of a building or a facility, something that has
little likelihood of being accomplished because existing structural conditions would require removing
or altering a load-bearing member that is an essential part of the structural frame; or because other
existing physical or site constraints prohibit modification or addition of elements, spaces, or features
that are in full and strict compliance with the minimum requirements.

Classifying something as technically infeasible is based on more than just "I don't feel like doing it." In my state, any request to invoke technical infeasibility requires a formal application to and approval by the State.

 

[Stanovby]

Remember that under the IEBC (unless the jurisdiction has royally screwed it up, as Virginia appears to have done), there are three methods on compliance. The applicant/designer gets to choose which path to follow. Option 3, the Performance Method, is the equivalent safety points scoresheet approach. Very few applicants choose that, but it is available to you.

Far too many architects get confused between the Prescriptive Method and the Work Area Method. The concept of Level 1, Level 2, and Level 3 applies ONLY to the Work Area Method.

Start with the definitions. You mentioned replacing finishes and fixtures. The classification of Work i Chapter 6 uses some of those words, but the definition of "Repair" also uses those words:



Direct replacement of finishes and/or fixtures is typically a repair. The IEBC Commentary adds this to the definition of "Repair":



So what is an "Alteration"?



Commentary on the definition of "Alterations":



So then we go to Chapter 3, "Provisions for all Compliance Methods." Note that per 301.1, repairs, alterations, changes of occupancy, and additions are subject to one of the subsections of 301, and to sections 302 through 309. However, section 301.3 says that only alterations, changes of use, and additions are subject to one of the methods in 301.3.1, 301.3.2, and 301.3.3. So "Repairs" are not subject to the classification of work, and are not considered to be alterations.

I don't know where to look for it under the new (2010) ADAS but, when the ADA and the original ADAAG first came out in 1994, most states had had accessibility requirements under UFAS and/or some edition of A117.1 for close to 20 years. There was a provision, either in the ADA itself or in the ADAAG, that a facility which had been made accessible under a previous standard did not have to be upgraded to comply with a newer accessibility standard. I don't know if this provision is still in the ADAS, or how it might impact state accessibility requirements under the IEBC and A117.1.

There appears to be considerable overlap[ between a "Repair" and a Level 1 Alteration. It may come down to the scope. If you have to patch the tile in a toilet room, that's a repair. If you strip it ALL out and replace it with all-new tile, that's a Level 1 Alteration. Ditto for fixtures. If you replace one fixture in a multi-fixture toilet room because it broke, that's clearly a repair. If you replace ALL the fixtures because they're shabby or outdated, that's a Level 1 Alteration. If you
add or eliminate any door or window, reconfigure or extend any system, or install any additional equipment, it becomes at least a Level 2 Alteration.

I don't think you can mix Level 1, Level 2, and Level 3 within a project. This, in an office alteration, even if all you're doing in the toilet rooms in replacing finishes and fixtures but NOT moving any walls, doors, or windows, but in the office areas you ARE adding or removing walls, doors, and/or windows, the entire project becomes a Level 2 Alteration. If the work area exceeds 50% of the floor area of the building, it rises to a Level 3 Alteration.

Thanks. that's very helpful. I did not know about the different paths. I would probably be using the work area path. Typically we would be replacing all of the finishes in the toilet room with new finishes. I was thinking this was more of an alteration than a repair. I never know if they replace the accessories and toilet fixtures such as water closets and sinks with new or if they reinstall the existing ones. I leave that up to the project manager. We work for McDonalds and other restaurant chains and they have a project manager that works with the owner/operator of the restaurant. McDonald's has a décor company that supplies new seating and toilet room finishes. We are in charge of making sure everything is accessible. It would be costly for the owner to have to replace a water closet stall because we would in some cases have to remodel the entire toilet room to make everything work if we have to provide the toe clearance.

 

[Yankee Chronicler]

Thanks. that's very helpful. I did not know about the different paths. I would probably be using the work area path. Typically we would be replacing all of the finishes in the toilet room with new finishes. I was thinking this was more of an alteration than a repair. I never know if they replace the accessories and toilet fixtures such as water closets and sinks with new or if they reinstall the existing ones. I leave that up to the project manager. We work for McDonalds and other restaurant chains and they have a project manager that works with the owner/operator of the restaurant. McDonald's has a décor company that supplies new seating and toilet room finishes. We are in charge of making sure everything is accessible. It would be costly for the owner to have to replace a water closet stall because we would in some cases have to remodel the entire toilet room to make everything work if we have to provide the toe clearance.

If you are not the licensed design professional in responsible charge, then you need to coordinate with whoever that is to find out which method is being followed. There is only ONE method applicable for a project/permit. They don't get to use the Prescriptive Method for the dining room and you use the Work Area Method for the toilet rooms. And you can't mix and match between methods for portions of a project.

I have reviewed two McD's projects in the three years I've been at my current job. Neither passed the first plan review. IMHO, whoever does their construction documents doesn't have a clue about code compliance. We also have most of the other major fast food chains in town. Their design professionals don't have a clue, either.

Several years ago, the McD's nearest my home did a full interior make-over. It all arrived in a couple of trucks and was installed by workers who didn't speak much English. As part of the project, they replaced a compliant handicapped parking sign with a new one that was blue letters on white (our state law requires white lettering on a blue field), and (I kid you not) it read "Handiccapped Boat Ramp," complete with a graphic of a boat being launched at a ramp. They don't know and they don't care.

 

[Stanovby]

If you are not the licensed design professional in responsible charge, then you need to coordinate with whoever that is to find out which method is being followed. There is only ONE method applicable for a project/permit. They don't get to use the Prescriptive Method for the dining room and you use the Work Area Method for the toilet rooms. And you can't mix and match between methods for portions of a project.

I have reviewed two McD's projects in the three years I've been at my current job. Neither passed the first plan review. IMHO, whoever does their construction documents doesn't have a clue about code compliance. We also have most of the other major fast food chains in town. Their design professionals don't have a clue, either.

Several years ago, the McD's nearest my home did a full interior make-over. It all arrived in a couple of trucks and was installed by workers who didn't speak much English. As part of the project, they replaced a compliant handicapped parking sign with a new one that was blue letters on white (our state law requires white lettering on a blue field), and (I kid you not) it read "Handiccapped Boat Ramp," complete with a graphic of a boat being launched at a ramp. They don't know and they don't care.

Wow! We are licensed architects and we handle accessibility issues. For some project types we do not do anything outside, only interior work. There are some other project types where we do exterior work. It depends on the scope of the project. We are not physically at the site unless there is a problem, but we tell the project manager whether there is an accessibility issue or not. McDonald's hires a survey company so we rely on them for existing condition dimensions. Occasionally there is an outside form that does an ADA report but not always.

 

[Yankee Chronicler]

Wow! We are licensed architects and we handle accessibility issues.

Who handles everything else? Most McDonald's remodeling projects I have seen around the state (as a customer, not as a plan reviewer) are at least Level 2 alterations, and if the kitchen is involved they become Level 3. If your work is limited to accessibility, who does everything else? Who is the licensed design professional in responsible charge?

 

[Stanovby]

Who handles everything else? Most McDonald's remodeling projects I have seen around the state (as a customer, not as a plan reviewer) are at least Level 2 alterations, and if the kitchen is involved they become Level 3. If your work is limited to accessibility, who does everything else? Who is the licensed design professional in responsible charge?

We handle all of that. The level of work depends on our scope. McDonald's has a program where the focus is on the front counter area where we remodel part of the kitchen, usually the service area in front of the draft curtain or menu board soffit. There are other projects where we do a whole new kitchen. Sometimes we don't touch the kitchen at all. If the entire dining area is being remodeled with new seating we have to check for accessibility in the interior. If we only work in the counter area we don't do that. We do other projects where we have to do the exterior accessibility. One thing that I was wondering is do they look at the levels based on the entire amount of work being done or do they look at the area in question? If I'm only changing finishes in the toilet room do I have to do more if the overall scope is a higher level?

 

[Yankee Chronicler]

We handle all of that. The level of work depends on our scope. McDonald's has a program where the focus is on the front counter area where we remodel part of the kitchen, usually the service area in front of the draft curtain or menu board soffit. There are other projects where we do a whole new kitchen. Sometimes we don't touch the kitchen at all. If the entire dining area is being remodeled with new seating we have to check for accessibility in the interior. If we only work in the counter area we don't do that. We do other projects where we have to do the exterior accessibility. One thing that I was wondering is do they look at the levels based on the entire amount of work being done or do they look at the area in question? If I'm only changing finishes in the toilet room do I have to do more if the overall scope is a higher level?

Read the definitions of the three levels under Classification of Work. Just changing finishes in the toilet rooms is Level 1 work. As soon as you add, remove, or move any walls, doors, or windows it becomes Level 2. When Level 2 work occurs in more than 50% of the building, it becomes Level 3.

I don't understand this question:

If I'm only changing finishes in the toilet room do I have to do more if the overall scope is a higher level?

If you are only changing the finishes in the toilet rooms, that's the scope. If there is an overall scope of a project that includes more than changing finishes in the toilet rooms, then you are not "only" changing finishes in the toilet rooms.

We recently reviewed a McD's alteration. It was basically limited to the counter area and moving the indoor ordering kiosks. The counter area changes included moving a wall -- so it became a Level 2 alteration. Once any part of the work pushes it into Level 2, the entire project is Level 2. It's not Level 2 in the couter area and Level 1 in the toilet rooms.

But the requiremements for Accessibility in chapter 3 apply to all methods of compliance.

 

[Mr. Inspector]

Classifying something as technically infeasible is based on more than just "I don't feel like doing it." In my state, any request to invoke technical infeasibility requires a formal application to and approval by the State.

This is the same in PA. I like this as a plan/reviewer because I don't have to make a decision on this.

There are ways around using level 3. For example, I had a 3-story apartment house where they did alterations on one floor at a time using level 2. It saved them a lot of money by doing it this way.

 

[Stanovby]

I don't understand this question:



If you are only changing the finishes in the toilet rooms, that's the scope. If there is an overall scope of a project that includes more than changing finishes in the toilet rooms, then you are not "only" changing finishes in the toilet rooms.

We recently reviewed a McD's alteration. It was basically limited to the counter area and moving the indoor ordering kiosks. The counter area changes included moving a wall -- so it became a Level 2 alteration. Once any part of the work pushes it into Level 2, the entire project is Level 2. It's not Level 2 in the couter area and Level 1 in the toilet rooms.

But the requiremements for Accessibility in chapter 3 apply to all methods of compliance.

Read the definitions of the three levels under Classification of Work. Just changing finishes in the toilet rooms is Level 1 work. As soon as you add, remove, or move any walls, doors, or windows it becomes Level 2. When Level 2 work occurs in more than 50% of the building, it becomes Level 3.

I don't understand this question:



If you are only changing the finishes in the toilet rooms, that's the scope. If there is an overall scope of a project that includes more than changing finishes in the toilet rooms, then you are not "only" changing finishes in the toilet rooms.

We recently reviewed a McD's alteration. It was basically limited to the counter area and moving the indoor ordering kiosks. The counter area changes included moving a wall -- so it became a Level 2 alteration. Once any part of the work pushes it into Level 2, the entire project is Level 2. It's not Level 2 in the couter area and Level 1 in the toilet rooms.

But the requiremements for Accessibility in chapter 3 apply to all methods of compliance.

That's what I was wondering and you answered that. You don't mix and match. If you are doing level 2 work in the entire project everything is subject to Level 2 requirements. I was looking for a YouTube vide explaining the methods that you had brought up and could only find a part of a video on the subject. It would be nice to find a webinar that goes into detail about the different methods. I found one but it was only 6 minutes long, it wasn't the full lecture.

 

[Yankee Chronicler]

That's what I was wondering and you answered that. You don't mix and match. If you are doing level 2 work in the entire project everything is subject to Level 2 requirements. I was looking for a YouTube vide explaining the methods that you had brought up and could only find a part of a video on the subject. It would be nice to find a webinar that goes into detail about the different methods. I found one but it was only 6 minutes long, it wasn't the full lecture.

Still not right.

You can be doing Level 1 work over 90% of a building, and Level 2 work in 5% of the building -- the project is classified as a Level 2 alteration.

Once the scope of Level 2 work exceeds 50% of the building (not story) area, the entire project is classified as Level 3.

 

[Stanovby]

So let me ask you guys this. Say in a hypothetical situation I am doing a Level 2 alteration in a McDonald's restaurant. It is a full décor remodel which would be providing new seating and finishes, but also relocating some kiosks & also modifications to the front counter area which would require moving existing walls & doors, or adding new walls & doors. There is some kitchen equipment relocating behind the front counter area. There is no work beyond the draft curtain/ Menuboard area so the scope would not meet the 50% threshold. In this situation I would have to check the existing toilet rooms for accessibility. Outside of the accessibility requirements, the scope of the toilet room is a repair of the accessories, fixtures & the finishes. If the only thing in the toilet rooms that is non compliant; is that the accessible stalls are not wide enough for the required toe clearance of 68 inches; in your opinion, would I have to modify the stalls to comply with the required toe clearance? I would be using the work area method of compliance.

 

[jar546]

So let me ask you guys this. Say in a hypothetical situation I am doing a Level 2 alteration in a McDonald's restaurant. It is a full décor remodel which would be providing new seating and finishes, but also relocating some kiosks & also modifications to the front counter area which would require moving existing walls & doors, or adding new walls & doors. There is some kitchen equipment relocating behind the front counter area. There is no work beyond the draft curtain/ Menuboard area so the scope would not meet the 50% threshold. In this situation I would have to check the existing toilet rooms for accessibility. Outside of the accessibility requirements, the scope of the toilet room is a repair of the accessories, fixtures & the finishes. If the only thing in the toilet rooms that is non compliant; is that the accessible stalls are not wide enough for the required toe clearance of 68 inches; in your opinion, would I have to modify the stalls to comply with the required toe clearance? I would be using the work area method of compliance.

In this project, you are handling a Level 2 alteration at a McDonald's, which involves a full décor remodel, moving kiosks, modifying the front counter, and some kitchen equipment relocation. Since this doesn't extend beyond the draft curtain/menu board area, it doesn't hit the 50% threshold that would require more comprehensive changes (Level 3). However, we still need to address accessibility requirements.

For the existing toilet rooms, even though the scope is just to repair accessories, fixtures, and finishes, we must ensure they comply with current accessibility standards. The issue here is that the accessible stalls don't provide the required toe clearance. According to the International Building Code (IBC) and the Americans with Disabilities Act (ADA), any alteration affecting the usability of the building must meet current accessibility standards. Therefore, despite the repairs being minor, if the accessible stalls are non-compliant with the required toe clearance, we must modify them.

 

[Stanovby]

In this project, you are handling a Level 2 alteration at a McDonald's, which involves a full décor remodel, moving kiosks, modifying the front counter, and some kitchen equipment relocation. Since this doesn't extend beyond the draft curtain/menu board area, it doesn't hit the 50% threshold that would require more comprehensive changes (Level 3). However, we still need to address accessibility requirements.

For the existing toilet rooms, even though the scope is just to repair accessories, fixtures, and finishes, we must ensure they comply with current accessibility standards. The issue here is that the accessible stalls don't provide the required toe clearance. According to the International Building Code (IBC) and the Americans with Disabilities Act (ADA), any alteration affecting the usability of the building must meet current accessibility standards. Therefore, despite the repairs being minor, if the accessible stalls are non-compliant with the required toe clearance, we must modify them.

Thanks. This is what I have been wondering. Thank you to everyone that has responded to this post, you have been very helpful. This is a great resource to have and it is helping me to become more educated on this subject. I really do want to do the right thing and provide a finished product that complies with accessibility standards. The owner/operator of the restaurant may not be happy about the cost, but at least I am more educated in regards to what is required. This has been a great learning experience and I appreciate everyone's help.

 

[steveray]

There is no pointer in the IEBC for accessible upgrades for a repair, just maintenance...You are always on the hook for ADA accessibility....