Necessary threshold for updating existing restrooms with ADA clearances.

[Ryan Schultz]

We have a client that would like to renovate all the restrooms located on all 9 floors of a mid-rise building. Scope to include new fixtures, stalls, and vanities, as well as new wall/floor/ceiling finishes.

It's a Business occupancy, with each floor plate around 8,400sf.

The project is in a 2009 IBC justification--Wisconsin.

As you'll see, from the following PDF, most of these existing restrooms do not have the necessary ADA clearances.

https://www.dropbox.com/s/saqhsz8hk0wjf7a/Existing%20Restrooms.pdf?dl=0

Due to the constraints of the building, updating them to ADA complaint dimensions is not very feasible.

Main question: With the proposed renovation scope above, will we be required to update these restrooms with ADA clearances? Or is there some grandfathering, or hardship clause that we could appeal to, in either IBC or IEBC, that would allow us to maintain these existing dimensions?

Thanks Much, Ryan

 

[steveray]

There is no relief from ADA....If you mean accessibility under the building code, there may be some. Here is the main code section to look at:

3411.7 Alterations affecting an area containing a primary function. Where an alteration affects the accessibility to, 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 an existing building, facility or element.

You need to spend 20% towards upgrading accessibility...Unless you can claim #4

 

[clear as mud]

Per WCBC, SPS 62.3400, the requirements of IBC Chapter 34 are excluded from adoption. Wisconsin instead adopts the 2009 IEBC for alterations to existing buildings.

Your proposal would be a Level 1 Alteration, Chapter 6, Section 605. Matters of technical infeasibility are addressed.

Technical Infeasibility is defined in Chapter 2.

 

[mtlogcabin]

IBC chapter 34 is word for word included in the IEBC and as a designer you have 3 options to use under the IEBC

301.1.1 Prescriptive compliance method.

Repairs, alterations, additions and changes of occupancy complying with Chapter 4 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code.

301.1.2 Work area compliance method.

Repairs, alterations, additions, changes in occupancy and relocated buildings complying with the applicable requirements of Chapters 5 through 13 of this code shall be considered in compliance with the provisions of this code.

301.1.3 Performance compliance method.

Repairs, alterations, additions, changes in occupancy and relocated buildings complying with Chapter 14 of this code shall be considered in compliance with the provisions of this code.

If these are public restrooms accessed from a common area how about taking every other floor and reducing the number of fixtures in order to provide ADA compliant restrooms on every other floor. Loosing a few fixtures will probably not even be noticed among the occupants.

 

[ADAguy]

Correct to a point but what of ADAS - 2010 compliance, state code is not certified by DOJ as a safe harbor.

 

[north star]

= # = # =



ADAguy ( and others ),

For my own clarity, ...so Mr. Schultz' client could potentially comply

with the Wisconsin Building Code for compliance up to a point, but

regardless, ...the client would still have to comply with the Federal

ADA regulations...........To what degree of compliancy does the Federal

regulations require [ please cite the applicable Federal ADA sections ].

Another question I would be asking is, ...what about Federal ADA

compliance for the rest of the entire bldg. ?.......What stage is that

in ?



= # = # =

 

[Ryan Schultz]

Thanks Guys.

@mtlogcabin that's a good idea. Is there a provision somewhere that outlines that accessible restrooms can only be one floor away, up or down?

... or are you more generically saying that 20% of the budget might potentially equate to an ADA compliant restroom at every other floor.

Thanks, Ryan

 

[Ryan Schultz]

Viewed another way, do I even need to satisfy 605.2 since these restrooms, as indicated in the definition below, are not considered 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.

 

[steveray]

Read all the way to the end of 3411.7....This is one area where the definition will mess you up....

 

[mark handler]

Thanks Guys. @mtlogcabin that's a good idea. Is there a provision somewhere that outlines that accessible restrooms can only be one floor away, up or down?

... or are you more generically saying that 20% of the budget might potentially equate to an ADA compliant restroom at every other floor.

Thanks, Ryan

Provide signage, at the noncomplying restroom, directing the user to the complying restroom.

 

[mark handler]

Viewed another way...

L a w s u i t

 

[clear as mud]

Wisconsin does not adopt IEBC or the IBC in it's entirety making it somewhat difficult to apply the code correctly. There are a myriad of deletions, additions, amendments, etc. Entire chapters are sometimes omitted from adoption and replaced with alternate language or reference. A designer must always cross reference with the Wisconsin Administrative Code. Not doing so will end up costing you time and money.