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How to reconcile the "OR" for elevators in alterations

Discussion in 'Commercial Building Codes' started by DTBarch, Feb 13, 2020.

  1. DTBarch

    DTBarch Registered User

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    Existing 200,000sf warehouse has an existing 2-story office space in corner. Total area on 2nd floor is approx. 5,000sf, about 2,800sf of which is private offices and the balance is product development workspace mezzanine open to the warehouse. This 2nd floor is currently served by (3) stairs, and no elevator. Jurisdiction is utilizing 2018 IBC, 2010 ADA Standards for Accessible Design & ICC ANSI A117.1-2009.

    Existing tenant wishes to expand his office space on the 2nd floor into the existing open work area on that level by approx. 1,500sf, which would bring his 2nd floor office area to approx 4,300sf of the 5,000sf total 2nd floor area.

    No change of use is involved.

    IBC Section 1104.4.1 speaks to an exemption from accessible route for stories and mezzanines with an aggregate area of not more than 3,000sf.

    2010 ADA Section 36.404 give an exemption in alterations specifically from elevators in an altered facility that is less than 4 stories OR has less than 3,000sf per story.

    The space is not in use as a healthcare provider, passenger transportation, shopping center or mall, nor a government building.

    Total Valuation of 2nd floor alteration buildout would be $120,000

    ADA appears to provide clear exemption since it's less than 4 stories, and you only need to be less than 4 stories OR less than 3,000sf

    IBC appears to require the elevator, or as previously stated, "a very long ramp"

    How would you interpret and reconcile these seemingly opposing codes, given the circumstances listed above? Through researching and reviewing past forum threads on this topic, I know this has been hashed out, in some form or another, a hundred times on this forum, often leading into the 20% rule or other black holes, so I apologize in advance for the redundancy, but I'm curious in a limited scope alteration how this is mitigated. I appreciate your feedback.
     
  2. steveray

    steveray Sawhorse

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    The IBC does not nullify ADA, and vice versa..... but compliance with both is required, just not by me...

    [A] 102.2 Other laws. The provisions of this code shall not be deemed to nullify any provisions of local, state or federal law.

    Just like a "private club" is exempt from ADA, but not the building code, so make it accessible when you remodel...:)
     
    ADAguy likes this.
  3. Tim Mailloux

    Tim Mailloux Registered User

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    The IEBC (and I think ANSI) has a 20% cap on accessibility upgrades. Once you sped 20% of your project budget on accessibility upgrades your done for that project. In your case that spending cap would be $12,000, not nearly enough to add an elevator.
     
  4. steveray

    steveray Sawhorse

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    $24000...Unless it would be considered an addition....

    [A] ADDITION. An extension or increase in floor area, number of stories, or height of a building or structure.

    1105.1 Minimum requirements. Accessibility provisions
    for new construction shall apply to additions.
    An addition that
    affects the accessibility to, or contains an area of, primary
    function shall comply with the requirements of Sections 705,
    806 and 906, as applicable.
     
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  5. ADAguy

    ADAguy Registered User

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    Don't fight it, if necessary use a LULA.
     

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