Lockers vs. locker room

[Sifu]

A proposal for am A-2/A3 has come in. Within the space is a storage/mech. room. However within the room are employee lockers. It is largely an employee workspace for storage and equipment such as the water heater, CO2 tanks, and soda racks, but with a bank of employee lockers, ergo it is a room, with lockers. I see no way around the fact that at least 5% of the lockers must be accessible per 2018 IBC 1109.9. But would it be considered a "locker room" in the context of ANSI 117.1 803? The issue is that the room does not allow room for the bench required by ANSI 803/903 without some reconfiguration. Happy to cite that requirement, just want to be sure of the distinction between a locker being accessible vs. a designated "locker room".

 

[Sifu]

Related....the A2/A3 is a golf simulator and bar establishment. IBC speaks generically to recreational facilities, and specifically to miniature golf facilities. I think this is further away from a miniature golf facility than a recreational facility. As a recreational facility, an accessible route to the edge of the play area is required, and a W/C space in the player seating area. 2018 IBC 1110.4.1 requires "each" area of sport activity. Not 5% or not less than 1 as identified for bowling lanes. There are 5 identical simulator bays. Could this be viewed a single area of sport activity so that 1 bay meets the requirements? Or, would it be required that "each" bay meet the requirements?

Here is their depiction of a simulator bay. You will note that they indicate a 3' accessibler oute, even though it is covered by furniture. Easy enough to remove a chair which would provide both the AR and W/C space, but less palatable if they must do it all bays.

 

[Mr. Inspector]

The IBC does not require a bench in a locker room.

 

[Sifu]

The IBC does not require a bench in a locker room.

The IBC says 5% must be accessible, and in order to be accessible it must comply with ANSI 117.1, and ANSI requires a bench within the room.

 

[walker.t]

But would it be considered a "locker room" in the context of ANSI 117.1 803?

Before checking to see what the commentary said I was thinking this was not a “locker room” in the sense of a place where athletes, for example, are changing out of their uniforms, bathing, and putting on their street clothes. What you described sounds to me like a place where each employee is given access to a locker where they can secure their personal items for the day instead of keeping them at their work station.

Changing of clothes seems to be the deciding factor, whether or not bathing is involved as I mentioned above:

Commentary on A117.1-2017 Section 803 Dressing, Fitting and Locker Rooms (partial quote)
The intent of this section is to provide requirements that allow a person using a mobility aid to have the ability to change clothes. Examples of these types of facilities include…locker rooms were staff persons change from street clothes to uniforms.

The IBC does not require a bench in a locker room.

Looks like A117.1-2017 8.3.4 does: “A bench complying with Section 903 shall be provided within the room.”

 

[Sifu]

Before checking to see what the commentary said I was thinking this was not a “locker room” in the sense of a place where athletes, for example, are changing out of their uniforms, bathing, and putting on their street clothes. What you described sounds to me like a place where each employee is given access to a locker where they can secure their personal items for the day instead of keeping them at their work station.

Changing of clothes seems to be the deciding factor, whether or not bathing is involved as I mentioned above:

This is the heart of the question. If not a "locker room" then the bench wouldn't necessarily come into play, although the locker itself could still be accessible.

 

[Yankee Chronicler]

A proposal for am A-2/A3 has come in. Within the space is a storage/mech. room. However within the room are employee lockers. It is largely an employee workspace for storage and equipment such as the water heater, CO2 tanks, and soda racks, but with a bank of employee lockers, ergo it is a room, with lockers. I see no way around the fact that at least 5% of the lockers must be accessible per 2018 IBC 1109.9. But would it be considered a "locker room" in the context of ANSI 117.1 803? The issue is that the room does not allow room for the bench required by ANSI 803/903 without some reconfiguration. Happy to cite that requirement, just want to be sure of the distinction between a locker being accessible vs. a designated "locker room".

If the store room holds only employee lockers, and no toilet and/or bathing facilities, I **might** be inclined to accept an argument that the lockers are not available to the public, they are employee only, so any accessibility should be addressed as individual employee "reasonable accommodations" on a case-by-case basis rather than throwing the entire ADA and A117.1 at it.

Note: **might**

 

[Yankee Chronicler]

Related....the A2/A3 is a golf simulator and bar establishment. IBC speaks generically to recreational facilities, and specifically to miniature golf facilities. I think this is further away from a miniature golf facility than a recreational facility. As a recreational facility, an accessible route to the edge of the play area is required, and a W/C space in the player seating area. 2018 IBC 1110.4.1 requires "each" area of sport activity. Not 5% or not less than 1 as identified for bowling lanes. There are 5 identical simulator bays. Could this be viewed a single area of sport activity so that 1 bay meets the requirements? Or, would it be required that "each" bay meet the requirements?

Here is their depiction of a simulator bay. You will note that they indicate a 3' accessibler oute, even though it is covered by furniture. Easy enough to remove a chair which would provide both the AR and W/C space, but less palatable if they must do it all bays.

View attachment 16537

IMHO each simulator bay must be on an accessible route.

Reason -- each bay is rented out separately.

2021 IBC Commentary:

 

[walker.t]

It is largely an employee workspace for storage and equipment

If the store room holds only employee lockers

IBC Definition of “Employee Work Area” (partial quote, emphasis added)
All or any portion of a space used only by employees and only for work.

Is this [storage] room really an employee work area? Fast food place where I worked in high school had an area with paper goods, the soda racks, and an ice machine. The only “work” done in that room was to stock it on truck days, get paper goods as needed, change the soda bags, and fill up the ice bin on wheels which was kept by the soda fountain at the front of the store. There was no food prep, mop sink, or even a table for employees to do anything on.

 

[Gregg Harris]

By the description, I do not think it meets the criteria for "required accessible space."

 

[Yankee Chronicler]

By the description, I do not think it meets the criteria for "required accessible space."

ALL spaces are required to be accessible. The question is whether or not the lockers need to be accessible and then -- by entension -- if a bench is required for the accessible lockers.

 

[Sifu]

IMHO each simulator bay must be on an accessible route.

Reason -- each bay is rented out separately.

2021 IBC Commentary:

View attachment 16542

I can't argue the "each" part spelled out in the code text, but I can wonder why it would be treated differently than a bowling lane. I stipulate the code makes the distinction for them and not golf simulator bays, I just can't see why it would be different. The commentary for bowling lanes includes "Since bowling lanes repeat each other" as a reason for the 5% threshold, which would apply to the simulator bays.

 

[Yankee Chronicler]

Possibly the building codes haven't caught up to the times. There's no mention in there of axe throwing bays, either, but they exist -- we have an axe throwing emporium in town. We also have a karaoke studio, which has six or seven (don't remember exactly) individual karaoke rooms. No exception in the code, so they each had to be made accessible.

 

[Sifu]

I think it will be easy enough to provide the route and W/C space to each bay by moving/removing a chair. If they can't they can state their case.

 

[Yankee Chronicler]

I think it will be easy enough to provide the route and W/C space to each bay by moving/removing a chair. If they can't they can state their case.

The architect in me looks at it and says "Move the sofa and wing wall off-center, close up the spacing between the chairs and the sofa, and that should leave enough room to drive a wheelchair through."

But when I'm wearing my building official hat, I can't say that. Because, invariably, "Have you considered doing X?" becomes "He told me I had to do X."

 

[Gregg Harris]

ALL spaces are required to be accessible. The question is whether or not the lockers need to be accessible and then -- by entension -- if a bench is required for the accessible lockers.

Accessible route to and from the outdoors and the rental area, the storage room with lockers for storage is not a "required accessible space." Accessible to the public does not come into play. It does not fit the definition in IBC for locker room.

 

[Yankee Chronicler]

Accessible route to and from the outdoors and the rental area, the storage room with lockers for storage is not a "required accessible space." Accessible to the public does not come into play. It does not fit the definition in IBC for locker room.

So your argument is that the intent of the ADA doesn't include the possibility that an employee (perhaps a supervisor) may become temporarily or permanently disabled and need access to the rooms where his/her employees work?

My state building inspector's office does not agree with you. I've been an inspector on multiple projects on which they enforced that.

 

[Sifu]

The architect in me looks at it and says "Move the sofa and wing wall off-center, close up the spacing between the chairs and the sofa, and that should leave enough room to drive a wheelchair through."

But when I'm wearing my building official hat, I can't say that. Because, invariably, "Have you considered doing X?" becomes "He told me I had to do X."

View attachment 16556

Agree. I will simply make the comment to demonstrate accessibility and cite the code. There are simple ways to do it, but that is up to them. Fair chance they take the less simple way and just complain to the CBO. I anticipate them arguing the bowling lane path for 5% or one, as they have already used the bowling lane as the basis for an OL at each bay. If the code requires only an accessible path to the edge of the area of sport activity and a wheelchair space, and the furniture is not fixed as I imagine, it is simple. It seems they already realize the requirement since they show a 36" clear path, but for some reason they cover it up with their furniture.

 

[Gregg Harris]

My contention is that after reviewing IBC, and ADA it looks like it boils down to what the room is primarily used for. Concerning the lockers, are they used for employees to place their personal items for safekeeping while working, and they happen to have put them in a storage room and not a locker room, where changing of clothes, showering, and using the bathroom would require it to be accessible?

 

[steveray]

If they are changing clothes completely it’s a locker room….if just keeping their stuff and maybe putting on something like an apron, no…

 

[Yankee Chronicler]

My contention is that after reviewing IBC, and ADA it looks like it boils down to what the room is primarily used for. Concerning the lockers, are they used for employees to place their personal items for safekeeping while working, and they happen to have put them in a storage room and not a locker room, where changing of clothes, showering, and using the bathroom would require it to be accessible?

And my contention is that if the room is a room, rather than a shallow closet that is exempted from requiring accessibility, the room itself has to be accessible but the lockers probably don't have to be accessible.

 

[Jean Tessmer-HI]

Is this [storage] room really an employee work area? Fast food place where I worked in high school had an area with paper goods, the soda racks, and an ice machine. The only “work” done in that room was to stock it on truck days, get paper goods as needed, change the soda bags, and fill up the ice bin on wheels which was kept by the soda fountain at the front of the store. There was no food prep, mop sink, or even a table for employees to do anything on.

The lockers are in a room that all the employees use commonly to secure the items they want to stow. It is not a work room but the lockers are common elements and the room they are in would be used commonly by the employees to get to the lockers. The ADA under 803 requires rooms with lockers, fitting rooms, changing rooms to have bench seats. Which does not make send if no one will be changing? Or will they be?

 

[Yankee Chronicler]

The lockers are in a room that all the employees use commonly to secure the items they want to stow. It is not a work room but the lockers are common elements and the room they are in would be used commonly by the employees to get to the lockers. The ADA under 803 requires rooms with lockers, fitting rooms, changing rooms to have bench seats. Which does not make send if no one will be changing? Or will they be?

That is what the actual language of the standard says, but the advisory seems to imply something different. 803 covers dressing rooms, fitting rooms, and locker rooms. That would seem to include any room with lockers in it. I once worked at a Barnes & Noble bookstore. We had a room in the back, in which each employee had a locker. It was not a dressing room or a changing room. We didn't have uniforms. It was just a place where each employee had a locker in which to hang coats during winter or inclement weather, and where the females could lock up their purse or pocketbook while working. The advisory to 803.1 talks only about dressing rooms and fitting rooms, with no mention of rooms that just have a locker for hanging an outer coat.



Yet 803.4 then says that a bench shall be provided within "the" room, without qualifying what the room will actually be used for. IMHO, it's an area where the ADAS isn't clear on the intended scope.

I think it's clear, however, that the room itself has to be accessible, regardless of whether the presence of a couple of lockers requires a bench.

 

[Sifu]

I am considering this as not a "locker room". The room itself is accessible, I am requiring 5% of the lockers to be accessible and on an accessible route, but I am not requiring the bench. They have bigger problems so this should be an easy win for them.