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Janitor Closet Accessibility

nealderidder

Sawhorse
Joined
Dec 7, 2010
Messages
431
Location
Sacramento, CA
I did a search on this topic and found a 14 year old thread. I guess my thinking is stuck in the past because one of the replies is how I still treat it today. I consider the Janitor Closet as an employee work area and don't believe anything in it needs to be accessible. This would include push-pull side clearance for the entry door. Any contrary thoughts or clarifications since 2010?
 
Not so fast....

1103.2.2​

Spaces and elements within employee work areas 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.

Seems like ICC has clamped down on their Pastability...Not super happy about that....
 
Not so fast....

1103.2.2​

Spaces and elements within employee work areas 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.

Seems like ICC has clamped down on their Pastability...Not super happy about that....
Forgot to mention I'm in CA.
 
As a follow up - CBC states that Employee Workstations spaces shall only be required to comply with.... (several sections included) the only division 4 section in that list is 11B-404.2.3 which requires a 32" opening width. What's absent from that list is 11B-404.2.4 Maneuvering Clearances.

So I win, right? No push pull clearances required.
 
Dunno if that helps, but we'd consider that area in relation to the ability levels of the person employed to perform the function.

We do this, for example, for lobster pounds. Those commercial facilities require able-bodies individuals. If the don't have offices, we're not going to force barrier-free requirements on them, and our code/reg allows us to make that interp.

Pop an office into that lobster pound .... now we've got a different discussion.
 
Have you ever read Janis Kent's "Stepping thru Accessibility" blog? She is a California CASp, and she usually has pretty stringent application of the codes and regs. I don't always agree with her interpretation, but I think it is safe to say if she say's something is OK, you'll be hard pressed to find someone who will disagree with her.

Regarding janitor sinks, she says: https://www.steppingthruaccessibility.com/sinks-sinks-sinks-lavs-done/
Mop Sinks
A mop sink is usually a floor mounted sink, although there are also free-standing varieties as well. These are typically used by janitorial staff and have no requirements for access.
So the sink itself doesn't need to be accessible (reach range, knee and toe clearance, etc.).
If you consider the mop sink or the shelves associated with it to be an employee workstation, the next question is whether the workstation is required to have an accessible route leading up to and touching the edge of it.

CBC 11B-206.2.8 says that if the workstation is served by a common use circulation path", then the path must be accessible per 402 (accessible route components). CBC 202 defines "common use" as "interior or exterior circulation paths, rooms, spaces or elements that are not for public use and are made available for the shared use of two or more people".

So now the question becomes, can the entire janitor closet (not just the sink itself) be considered an "employee workstation", so that the required accessible route to this workstation stops at the hallway where it adjoins the face of the janitor closet door?

Again, from CBC 202 definition of "workstation", as approved by DSA/ Access Compliance:
[F] WORKSTATION. A defined space or an independent principal piece of equipment using HPM within a fabrication area where a specific function, laboratory procedure or research activity occurs. Approved or listed hazardous materials storage cabinets, flammable liquid storage cabinets or gas cabinets serving a workstation are included as part of the workstation. A workstation is allowed to contain ventilation equipment, fire protection devices, detection devices, electrical devices and other processing and scientific equipment.​
[DSA-AC] An area defined by equipment and/or work surfaces intended for use by employees only, and generally for one or a small number of employees at a time. Examples include ticket booths; the employee side of grocery store check stands; the bartender area behind a bar; the employee side of snack bars, sales counters and public counters; guardhouses; toll booths; kiosk vending stands; lifeguard stations; maintenance equipment closets; counter and equipment areas in restaurant kitchens; file rooms; storage areas; etc.​

So here we see that for the purposes of access compliance a "maintenance equipment closet" (which I believe to be another word for "janitor closet", is itself a single workstation. Therefore the accessible route stops in the hallway/corridor/room outside of the closet, and neither the door nor the mop sink nor the other elements inside the closet need to be accessible.

I have seen exceptions to this, where it needed to be accessible. This included:
  • Very large maintenance room that functioned like a repair workshop, and could clearly accommodate more than two people.
  • A maintenance room in a preschool where the teachers started to take over portions of it to save their teaching materials. At that point, it was no longer a workstation.
I knew of a church that had remodeled a sound and video control booth at the rear of their auditorium. It was elevated 18" so they could see over the heads of the congregation. It was about 6' deep x 12' long and had 3 chairs for (1) sound control, (2) video control, and (3) lighting control. there was a single set of stairs leading up into the elevated booth. 3 chairs = 3 workstations.
The building inspector said that because there were 3 seats and one set of stairs, it was obviously a common use circulation path, and to the booth needed a ramp (18' long plus top and bottom landing = 29' = too much space).
The owner responded by installing two more sets of stairs, so that each workstation had its own individualized circulation path. Problem solved.
 
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A janitors closet would not be an occupiable space and therefore not required to be accessible. He might get his supplies and equipment from that space and maybe wash his mop there. However, he is engaged in janitorial labor through out the building.

[BG] OCCUPIABLE SPACE. A room or enclosed space designed for human occupancy in which individuals congregate for amusement, educational or similar purposes or in which occupants are engaged at labor, and which is equipped with means of egress and light and ventilation facilities meeting the requirements of this code.
 
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