Locating mobility units in a multi-story alteration project

[Redmund]

Regarding alterations to an existing transient lodging building (per ADAS 224.1.1), designers will often want to locate all the units that will be upgraded into mobility units on the ground floor, especially if the existing building predates any accessibility requirements. They propose doing this because they want to make it easier for disabled occupants to exit the building quickly.

However, locating all the mobility units on the ground floor is not in keeping with the dispersion needed by ADAS 224.5 (i.e.: the ADAS advisory to 224.5 does include views as a factor to consider), and it would also seem to be a type of segregation to have all of the mobility units on only the ground floor.

However, the designers will point out an older building (built in 1955) will have no accessible means of egress measures such as area of refuge, etc., and the Building Code will not require upgrades to the existing egress system.

Is it o.k. to distribute the mobility units on all floors, even when the existing non-accessible egress system will not be upgraded?

 

[RLGA]

Dispersion is only applicable to the types of units—not the location of units. You can have all accessible (Type A) units on the ground floor. If there is no accessible route to the other stories, then you cannot locate a required Type A unit on those stories.

 

[Redmund]

I should have mentioned that the existing building does have an elevator.

 

[Builder Bob]

Is the elevator accessility friendly ??? That may be the driving force

 

[steveray]

Alterations rarely require an accessible means of egress......

 

[Yikes]

 

[Yikes]

Redmund, is the proposed alteration in the same state as you, California?

You asked about alterations, which triggers the building code, enforced at time of permit.
But you quoted ADAS, which has similar technical requirements but different scoping requirements, and is enforced via civil litigation. Even when there is no alteration proposed, ADAS still requires “readily achievable barrier removal” and “reasonable accommodation” at existing facilities.

Which regulation are you asking about? Building Code, or ADA, or both?

 

[Redmund]

It's actually the California Building Code as far as enforcing regulations that are triggered by a building permit application (although the building owner should really have fixed accessibility issues over the years outside of the building permit process). I quoted the ADAS to try to make the question more generic, but that really wasn't the best way to ask it. When I called the Access Board they said that the accessibility requirements are really separate from the potential safety requirements, and that from their standpoint they would expect to see the mobility units distributed on all floors of the building.