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Mezzanine accessibility - CBC 11B-206.2.3?

J

JPohling

Sawhorse
Joined
Aug 16, 2011
Messages
1,590
Location
San Diego
I have a plan reviewer that has taken the position that mezzanines need to be connected by an accessible route and that we cannot take the exception for an elevator, 11B-206.2.3 exception 1.1 or 1.2 since a mezzanine is considered a single story building and not a multi-storied building, therefore the exception is not valid as it refers to a multi-story building.

Have you heard of this interpretation before?
 
Not a California examiner, but the reading of the code section does appear to indicate that accessible route to the mezzanine is required.

11B-206.2.3 Multi-story buildings and facilities
At least one accessible route shall connect each story and mezzanine in multi-story buildings and facilities.
Exceptions:
  1. The following types of privately funded multistory buildings do not require a ramp or elevator above and below the first floor:
    1. 1.1. Multi-storied office buildings (other than the professional office of a health care provider) and passenger vehicle service stations less than three stories high or less than 3,000 square feet (279 m2) per story.
    2. 1.2. Any other privately funded multi-storied building that is not a shopping center, shopping mall or the professional office of a health care provider, or a terminal, depot or other station used for specified public transportation, or an airport passenger terminal and that is less than three stories high or less than 3,000 square feet (279 m2) per story if a reasonable portion of all facilities and accommodations normally sought and used by the public in such a building are accessible to and usable by persons with disabilities.
  2. Reserved.
  3. In detention and correctional facilities, an accessible route shall not be required to connect stories where cells with mobility features required to comply with Section 11B-807.2, all common use areas serving cells with mobility features required to comply with Section 11B-807.2, and all public use areas are on an accessible route.
  4. In residential facilities, an accessible route shall not be required to connect stories where residential dwelling units with mobility features required to comply with Sections 11B-809.2 through 11B-809.4, residential dwelling units with adaptable features complying with Chapter 11A, Division IV, all common use areas serving residential dwelling units with mobility features required to comply with Sections 11B-809.2 through 11B-809.4, all common use areas serving residential dwelling units with adaptable features complying with Chapter 11A, Division IV, and public use areas serving residential dwelling units are on an accessible route.
  5. Within multi-story transient lodging guest rooms with mobility features required to comply with Section 11B-806.2, an accessible route shall not be required to connect stories provided that spaces complying with Section 11B-806.2 are on an accessible route and sleeping accommodations for two persons minimum are provided on a story served by an accessible route.
  6. In air traffic control towers, an accessible route shall not be required to serve the cab and the equipment areas on the floor immediately below the cab.
  7. Reserved.
The interesting change is in the alteration between the IBC and CBC for item #1. Per IBC 1104.4 #1, "An accessible route is not required to stories and mezzanines that have an aggregate area of not more than 3,000 square feet (278.7 m2) and are located above and below accessible levels. This exception shall not apply to: ..." The CBC removed the reference to mezzanines and only refers to multistory buildings (mezzanines do not constitute a story), which seems to remove to 3000sf exemption for mezzanines.
 
I think the key element is found in the very first sentence:

"At least one accessible route shall connect each story and mezzanine in multi-story buildings and facilities."
​
If the building is not a multi-story building, then the section does not apply. A single-story building with a mezzanine is not a multi-story building; thus, an accessible route would not be required to the mezzanine.

This is the advisory from the 2010 ADA Standards, which seems to support this interpretation:

"Advisory 206.2.3 Multi-Story Buildings and Facilities. Spaces and elements located on a level not required to be served by an accessible route must fully comply with this document. While a mezzanine may be a change in level, it is not a story. If an accessible route is required to connect stories within a building or facility, the accessible route must serve all mezzanines."
​
This seems to indicate that if a multi-story building is required to have an accessible route to other stories, then the mezzanines must be included, too.
 
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