Level 1 Alteration - Toilet Room Accessibility?

[Mech]

2009 IEBC

Work is limited to two public use toilet rooms - changing floor and wall tile, changing plaster ceiling to gyp board, replacing toilet partitions and plumbing fixtures, changing light fixtures, changing HVAC grilles, and adjusting electrical switch height. There is no floor space reconfiguration except the possibility of shifting plumbing fixtures and partitions to meet IPC requirements.

Must ICC A117.1-2009 be followed in its entirety if not providing an accessible family or assisted-use toilet room (605.1.10)? The water closet compartments do not have the required floor spaces and without tearing down walls, they cannot be made compliant; also, compartment doors swing into the insufficient toilet clear floor spaces. If the door swing is reversed, then there will not be 18" clearance on the latch side of the door to pull it open.

Thanks,

 

[jpranch]

Just went through this a few weeks ago with a very large assembly facility. Pretty much the same as your description and did it as a Level-1 using the IEBC. I did not make them do anything with accessibility. I'm sure I got it right but if I got it wrong someone please show me the error of my ways.

 

[mtlogcabin]

How many water closet/urinals in each toilet room?

 

[Mech]

Men's room - 1 WC, 2 Urinals, 2 Lavs
Women's room - 2 WC, 2 Lavs

 

[jpranch]

Rut-Row! 2018 IEBC Section 305.6 and Section 305.8.10? I received a lesson from one of the top ICC instructors just yesterday and it is now my understanding that Chapter-3 applies to all methods. Btw, a lot of sections have been moved from the 2015 edition to Chapter-3 in the 2018 edition.

 

[mtlogcabin]

I would look at dropping a lav or urinal from the total fixture count and see if it will work before I do nothing

 

[north star]

* * & * *

Mech,

FWIW, ...I agree with **mtlogcabin** !......IMO,
it [ might ] go better to the owner "IF" the DOJ
ever did any type of Accessibility compliance
inspection, and found at least One compliant
RR, for each gender, rather than "just barely"
out of compliance.

At least the owner will have tried to comply
with the applicable Accessibility standards,
albeit with less plbg. fixtures.

* * & * *

 

[steveray]

Who has the decision of technical infeasibility in your jurisdiction? Typically you have to spend the 20% no matter what, unless it is technically infeasible. Or you could possibly say that the purpose of the remodel is to increase accessibility and wiggle out that way...

705.1 General. A facility that is altered shall comply with the
applicable provisions in Sections 705.1.1 through 705.1.14,
and Chapter 11 of the International Building Code unless it is
technically infeasible. Where compliance with this section is
technically infeasible, the alteration shall provide access to
the maximum extent that is technically feasible.
A facility that is constructed or altered to be accessible
shall be maintained accessible during occupancy.

705.1.10 Toilet rooms. Where it is technically infeasible to
alter existing toilet and bathing rooms to be accessible, an
accessible family or assisted-use toilet or bathing room constructed
in accordance with Section 1109.2.1 of the International
Building Code is permitted. The family or assisted-use
toilet or bathing room shall be located on the same floor and
in the same area as the existing toilet or bathing rooms.

705.2 Alterations affecting an area containing a primary
function. Where an alteration affects the accessibility to a, or
contains an area of, primary function, the route to the primary
function area shall be accessible. The accessible route to the
primary function area shall include toilet facilities or drinking
fountains serving the area of primary function.
Exceptions:
1. The costs of providing the accessible route are not
required to exceed 20 percent of the costs of the
alterations affecting the area of primary function.
2. This provision does not apply to alterations limited
solely to windows, hardware, operating controls,
electrical outlets and signs.
3. This provision does not apply to alterations limited
solely to mechanical systems, electrical systems,
installation or alteration of fire protection systems
and abatement of hazardous materials.
4. This provision does not apply to alterations undertaken
for the primary purpose of increasing the
accessibility of a facility.

 

[Mr. Inspector]

Forget about 705.2. A toilet room is not a primary function.

PRIMARY FUNCTION. A primary function is a major
activity for which the facility is intended. Areas that contain a
primary function include, but are not limited to, the customer
services lobby of a bank, the dining area of a cafeteria, the
meeting rooms in a conference center, as well as offices and
other work areas in which the activities of the public accommodation
or other private entity using the facility are carried
out. Mechanical rooms, boiler rooms, supply storage rooms,
employee lounges or locker rooms, janitorial closets,
entrances, corridors and restrooms are not areas containing a
primary function.

In PA an inspector is not allowed to decide if something is technically infeasible. It must be decided by a state board.

 

[Mech]

Thanks for the responses so far.

I was able to reconfigure the two restrooms to make them comply with A117.1, except for the doors into the toilet rooms. If they want accessible doors, they need to frame out some new ugly walls and project them into the hallway to make the doors work. There is a structural column on one side of each toilet room door and what appears to be a plumbing / HVAC chase on the other side of each door.

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605.2 Alterations affecting an area containing a primary function. Where an alteration affects the accessibility to a, or contains an area of, primary function, the route to the primary function area shall be accessible. The accessible route to the primary function area shall include toilet facilities or drinking fountains serving the area of primary function.
Exceptions:
1. The costs of providing the accessible route are not required to exceed 20 percent of the costs of the alterations affecting the area of primary function.
2.
3.
4.

Is this saying that the accessible route includes the route to the toilet facilities and drinking fountains?
Is it saying that restrooms and drinking fountains are included in the definition of accessible route, which means 20% of the alteration cost can be spent bringing toilet rooms and drinking fountains into compliance?​

 

[steveray]

Thanks for the responses so far.



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Is this saying that the accessible route includes the route to the toilet facilities and drinking fountains?
Is it saying that restrooms and drinking fountains are included in the definition of accessible route, which means 20% of the alteration cost can be spent bringing toilet rooms and drinking fountains into compliance?​

Yep....Like Rick said, not primary function, but part of the accessible route for the primary function....Makes perfect sense...Right?

 

[Mech]

Clear as mud.

 

[ADAguy]

Just do it! Stop looking for "outs". Its Federal law for the building owner/tenant.

 

[Tim Mailloux]

Thanks for the responses so far.

I was able to reconfigure the two restrooms to make them comply with A117.1, except for the doors into the toilet rooms. If they want accessible doors, they need to frame out some new ugly walls and project them into the hallway to make the doors work.

​

​

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I recall that A117.1 or the IBC allows automatic door operators in leu of providing the required 18" pull side latch clearance, if that helps.

 

[mp25]

I recall that A117.1 or the IBC allows automatic door operators in leu of providing the required 18" pull side latch clearance, if that helps.

...with standby power so people can get out in case of an emergency - if manual clearances are not available from the egress side

 

[ADAguy]

mp and Tim "get it"! It can be done.

 

[steveray]

Screw federal law!....All the pot legalization states do!....Next you will want us to enforce immigration....