Multistory accessibility

[Sifu]

A school building has 2 stories. The spaces on the 2nd story include a receiving area via a large overhead door, athletic equipment and book storage and some mechanical equipment spaces and electrical rooms. The mechanical spaces are exempt from accessibility. The storage MAY be limited to staff and considered an employee workspace, but would not be exempt from an accessible route. Or is there some exception I am missing? This occurs in two different areas on the same overall building. Below is one of the spaces in question.

 

[steveray]

I don't think it is exempt, but open to the concept of someone coming up with a code section...

 

[Yankee Chronicler]

Not exempt. Accessibility is required by IBC 1103.1, and the space described doesn't appear to fall within any of the exemptions in 1104 thru 1112.

 

[Yikes]

Where is this located - - or more specifically, what is the applicable code (besides ADA)?

 

[Sifu]

Where is this located - - or more specifically, what is the applicable code (besides ADA)?

2021 IBC and and 2017 ANSI 117.1. I can't fit it into any exemption other than the mechanical side per 1103.2.9, but the story would require a route since 1/2 the story is not exempt per that section. Maybe.....if it was not a school, someone might consider the area that is not exempted as mechanical access space as a story unto itself and less than 3,000sf², but the exception for the 3,000sf² doesn't apply to schools.

I was just searching to make sure I wasn't missing anything that would permit this.

 

[Sifu]

Would exception #2 work if they provided similar storage on the accessible level since 1108 doesn't appear to require special accessibility?

 

[Yankee Chronicler]

Would exception #2 work if they provided similar storage on the accessible level since 1108 doesn't appear to require special accessibility?

Are you referring to IBC 1103.2.2? Employee work areas? That doesn't get you out of accessibility to the space, it only gets you out of accessibility to employee-specific elements within the space.

1103.2.2 Employee work areas. 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. Work areas, or portions
of work areas, other than raised courtroom stations in accordance
with Section 1109.4.1.4, that are less than 300 square
feet (30 m2) in area and located 7 inches (178 mm) or more
above or below the ground or finished floor where the change
in elevation is essential to the function of the space shall be
exempt from all requirements.

The 2021 Commentary:

This section states that elements within individual work areas are not required to be fully accessible, but must
be provided with accessible means of egress (see Section 1009) and accessible circulation paths (see
Section 1104.3.1). In addition, these spaces must be provided with visible alarms (see Section 907.5.2.3.1)
where required. The assumption is that the employment nondiscrimination requirements of the ADA will
provide for “reasonable accommodations” to the disability of the employee and the area in which they
work. In other words, employers will modify individual work areas for the specific requirements of the individual
utilizing the space. An accessible route will be required to each work area. An example of this is an
individual work station in a laboratory. Installing sinks and built-in counters at accessible levels (see commentaries,
Sections 1110.3 and 1110.12) could make the station impractical for use by a person who is
standing. Ergonomic researchers used to recommend a standing counter at a minimum of 36 inches (914
mm), but are now advising even higher counters to reduce fatigue. When a station is required to be
adapted for an individual, it would be revised based on the individual’s needs and abilities. An accessible
route to each work station in the laboratory would be required so that access to and from that station would
be available. Note that the 36-inch (914 mm) clear width for the accessible route is the same as the minimum
required width of an exit access aisle. For exceptions to the route to work areas, see Section 1104.3.1.

There is an additional exception for work areas that are required to be raised or lowered 7 inches (178
mm) or more above the floor and have an area of less than 300 square feet (30 m2). The key word is
“required” to be raised, not just that someone decided to make that work station raised. Examples of work
areas required to be raised would include an area around a metal stamping machine, a safety manager’s
observation station on a production line or the pulpit area in a church. Raised courtroom areas are specifically
addressed in Section 1109.4.1.4. An example of a work area required to be lowered might be a pit
under a car in a car-repair station.

An employee’s work area can be something as simple as an office or cubicle, or it can extend over a
much wider area. For example, an office space might include copy rooms, file rooms, mail rooms, etc., or a
nurse or doctor in a clinic would have part of their work area in each exam room as well as at a central station.
In addition, not all employee-only spaces are considered work areas. Areas used by employees not for
work (i.e., break rooms, bathrooms, corridors) would not fall under this exception (see the definition for
“Employee work area”).

 

[Sifu]

No, should have made it more clear. Exception #2 to 1104.4, which says if 1108 or 1109 doesn't require special accessibility provisions then the 2nd level does not need to be on an accessible route. The code itself has always perplexed me a bit. Is it that if 1108 and 1109 does not require any accessibility, then the story is exempt from the route? So if there is an equivalent storage area on the accessible level is this the exception that permits the upper storage area without an accessible route? Or do I have this backwards, and does it mean that everything must be accessible EXCEPT the items specifically covered in 1108 & 1109?

From 2021 IBC:
2.Stories, mezzanines or occupied roofs that do not contain accessible elements or other spaces as determined by Section 1108 or 1109 are not required to be served by an accessible route from an accessible level.

Since nothing in 1108 or 1109 determines accessibility is the story exempt? Or is it that only the items in 1108 or 1109 can be considered to eliminate the accessible route?

From 2021 IBC commentary:
Exception 2 is a direct reference to the specific items addressed in Sections 1108 and 1109. It is not a general exception for Groups A, I, R and S. The purpose of Exception 2 is to address areas within specific occupancies where a single element would be repeated multiple times on a level. Where Sections 1108 and 1109 would allow construction of a floor level with no accessible features, this section is not intended to trigger an accessible route to that otherwise inaccessible level. For example, an accessible route would not be required to upper levels in a hotel with all public spaces and all Accessible sleeping units (see Section 1108.6.1.1) located on the ground floor. Another example: Section 1109.2 requires wheelchair spaces on different levels, and access to all services. ICC A117.1 requires dispersion of the wheelchair space locations. Once those criteria are met, the tiers that do not contain wheelchair space locations or the associated services are not required to be served by an accessible route. This exception does not have a square footage limitation.

Note that educational occupancies are not included in the commentary as a specific occupancy. So does the commentary say that this is a general exception for an E (or B), or that nothing in the section applies to an E (or a B)? This section has always made me scratch my head.

From an equal access view why would a similar storage space on the accessible level not offer equal access? But from an intent viewpoint, this section could be used to exempt a lot more than a storage space, so I wonder if this is the intent.

 

[Jean Tessmer-HI]

A school building has 2 stories. The spaces on the 2nd story include a receiving area via a large overhead door, athletic equipment and book storage and some mechanical equipment spaces and electrical rooms. The mechanical spaces are exempt from accessibility. The storage MAY be limited to staff and considered an employee workspace, but would not be exempt from an accessible route. Or is there some exception I am missing? This occurs in two different areas on the same overall building. Below is one of the spaces in question.

View attachment 15365

Do kids circulate on the second level where the utility areas are? If yes, then yes is the answer. I don't see a ramp or elevators to access the second story level. Since this is a school, I am assuming it is under title II state or government agency funded project, an elevator or ramp, would be required. Each utility room will need ADA hardware, Braille and tactile signage indicating it is for employees only with the label identity of the rooms.

 

[Sifu]

The room is labeled "athletic storage", it has individual chain link dividers sectioned off for various sports. Hard to imagine a gym class where the teacher goes and gets all the equipment. When I was in school the students were the gophers. So, I think it is intended for student access. The elevator to the student areas is in a different part of the building, disconnected from this story. This story is dedicated to the gymnasium spaces below and has no accessible route. The school would be a title II facility under the ADA, though I am not charged with enforcement of that law. I am charged with administration of the IBC and ANSI 117.1, but I don't think it makes a difference from a compliance standpoint.