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Blazer

Registered User
Joined
Jul 24, 2019
Messages
38
Location
North Kansas City
Does a projection room(Employee Work Area >1000sqft) in a new large movie theater have to have accessible routes or be an accessible space? Would it fall under Exception 2 of Employee Work Areas in Ch. 2 of ADA?

The section in IBC where I don't think the space is required to be accessible: Ch 11. Accessibility in IBC Equipment spaces. [Spaces frequented only by personnel for maintenance, repair or monitoring of equipment are not required to be accessible...]

The real question I'm trying to answer is "Can a door to the projection room be 30 inches?"
NFPA 101 states an exception to 32 inch in clear width: Minimum Door Leaf Width.[(3) Door openings serving a building or portion thereof not required to be accessible to persons with severe mobility impairments shall be permitted to be 28 inches in door leaf width.]
 
"No" it can't, you can't limit "who" can be employed or access by a mobility limited manager or supervisor.
 
ADAguy...I disagree. Discrimination is illegal, yes; however, the building codes may not require that the space be accessible. See the red font sections below for possible exceptions.

I would clarify that if the individual work area, particularly the area in question by the OP would be required to have accessible circulation paths; it would not have to be on an accessible route (thus no elevator/lift/ramp to upper floor) if the total area of the upper story/mezzanine is less than 3000sf or OL is less than 5.

1104.3 Connected Spaces
When a building or portion of a building is required to be accessible, at least one accessible route shall be provided to each portion of the building, to accessible building entrances connecting accessible pedestrian walkways and to the public way.

Exceptions:
1. Stories and mezzanines exempted by Section 1104.4.
2. In a building, room or space used for assembly purposes with fixed seating, an accessible route shall not be required to serve levels where wheelchair spaces are not provided.
3. Vertical access to elevated employee work stations within a courtroom complying with Section 1108.4.1.4.
4. An accessible route to recreational facilities shall only be required to the extent specified in Section 1110.

1104.3.1 Employee Work Areas
Common use circulation paths within employee work areas shall be accessible routes.
Exceptions:
1. Common use circulation paths, located within employee work areas that are less than 1,000 square feet (93 m2) in size and defined by permanently installed partitions, counters, casework or furnishings, shall not be required to be accessible routes.
2. Common use circulation paths, located within employee work areas, that are an integral component of equipment, shall not be required to be accessible routes.
3. Common use circulation paths, located within exterior employee work areas that are fully exposed to the weather, shall not be required to be accessible routes.
1104.4 Multistory Buildings and Facilities
At least one accessible route shall connect each accessible story and mezzanine in multilevel buildings and facilities.

Exceptions:
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:
1.1. Multiple tenant facilities of Group M occupancies containing five or more tenant spaces used for the sales or rental of goods and where at least one such tenant space is located on a floor level above or below the accessible levels;
1.2. Stories or mezzanines containing offices of health care providers (Group B or I);
1.3. Passenger transportation facilities and airports (Group A-3 or B); or
1.4. Government buildings.
2. Stories or mezzanines that do not contain accessible elements or other spaces as determined by Section 1107 or 1108 are not required to be served by an accessible route from an accessible level.
3. In air traffic control towers, an accessible route is not required to serve the cab and the floor immediately below the cab.
4.
Where a two-story building or facility has one story or mezzanine with an occupant load of five or fewer persons that does not contain public use space, that story or mezzanine shall not be required to be connected by an accessible route to the story above or below.
 
Accessibility has nothing to do with the minimum door width. You need a 32 inch clear width door opening

1008.1 Doors.
Means of egress doors shall meet the requirements of this section. Doors serving a means of egress system shall meet the requirements of this section
1008.1.1 Size of doors.
The minimum width of each door opening shall be sufficient for the occupant load thereof and shall provide a clear width of 32 inches


MEANS OF EGRESS. A continuous and unobstructed path of vertical and horizontal egress travel from any occupied portion of a building or structure to a public way

OCCUPIABLE SPACE. A room or enclosed space designed for human occupancy in which individuals congregate for amusement, educational or similar purposes or in which occupants are engaged at labor, and which is equipped with means of egress and light and ventilation facilities meeting the requirements of this code.
 
No where is there an exception for any work areas such as mechanical, electrical or other rooms that have limited access by employees or service personnel.

Exceptions:
1. The minimum and maximum width shall not apply to door openings that are not part of the required means of egress in Group R-2 and R-3 occupancies.
2. Door openings to resident sleeping units in Group I-3 occupancies shall have a clear width of not less than 28 inches (711 mm).
3. Door openings to storage closets less than 10 square feet (0.93 m2) in area shall not be limited by the minimum width.
4. Width of door leaves in revolving doors that comply with Section 1008.1.4.1 shall not be limited.
5. Door openings within a dwelling unit or sleeping unit shall not be less than 78 inches (1981 mm) in height.
6. Exterior door openings in dwelling units and sleeping units, other than the required exit door, shall not be less than 76 inches (1930 mm) in height.
7. In other than Group R-1 occupancies, the minimum widths shall not apply to interior egress doors within a dwelling unit or sleeping unit that is not required to be an Accessible unit, Type A unit or Type B unit.
8. Door openings required to be accessible within Type B units shall have a minimum clear width of 31.75 inches (806 mm).
 
Correctomundo MT. Ran in to this yesterday on a pre-ADA electric room (off a public corridor in a school) equipment change out (an alteration?). Its door opening was less than 32" clear. Transformer replacement (less than 800a service panel) so no panic hrdwr/outswinging door req'd but existing door must be widened/ or not?

As to employee work space (on a mezzanine vs 2nd floor - ADA T-1 (reasonable accommodation?) vs code requirement) in a movie theater, If theater is in a retail mall or building you may not qualify for a no elevator/lift exemption.
 
Blazer
1st forgive me for not welcoming you to the site. WELCOME
2nd why are you quoting NFPA 101 and referencing the IBC chapter 11 for this project?
3rd our hospitals/nursing homes are under both the IBC enforced by the local AHJ and NFPA 101 enforced by a state agency. The most restrictive code has to be met. If this is what you are dealing with then the IBC trumps the NFPA on minimum door widths.
 
2018 IMC
306.2 Appliances in rooms. Rooms containing appliances
shall be provided with a door and an unobstructed passage-
way measuring not less than 36 inches (914 mm) wide and 80
inches (2032 mm) high.

Looks like we need a 40" door to get a 36" wide opening!
 
2018 IMC
306.2 Appliances in rooms. Rooms containing appliances
shall be provided with a door and an unobstructed passage-
way measuring not less than 36 inches (914 mm) wide and 80
inches (2032 mm) high.

Looks like we need a 40" door to get a 36" wide opening!

Rick - Are projectors covered by the IMC? Per IMC 101.2, I'd say no...

101.2 Scope
This code shall regulate the design, installation, maintenance, alteration and inspection of mechanical systems that are permanently installed and utilized to provide control of environmental conditions and related processes within buildings. This code shall also regulate those mechanical systems, system components, equipment and appliances specifically addressed herein. The installation of fuel gas distribution piping and equipment, fuel gas-fired appliances and fuel gas-fired appliance venting systems shall be regulated by the International Fuel Gas Code.
Exception: Detached one- and two-family dwellings and multiple single-family dwellings (townhouses) not more than three stories high with separate means of egress and their accessory structures shall comply with the International Residential Code.
 
I assumed IBC would be most restrictive and final hurdle but I wasn't sure, hence the post. Thank you all for responding.

The projection room, as designed, has no elevator for access The only way to access it is by stairs, making it non accessible. (ch 11. common use circulation path).

I don't think it has to be accessible though if it is a work area. (When is the last time you saw an elevator in the movie theater so the employee in a wheelchair could mop up soda and peel gum off the floor on the back row?) You have to draw the line somewhere.

I will tell the architect to make the door 32"
 
Make sure that the architect verifies whether your code requires a minimum 32" clear distance from the face of the door to the door stop when it is opened 90 degrees.
Yes, it needs to be clear opening width. He's trying to get away with a smaller door to fit it in betweeen two steel columns. He will have to find another solution instead.

Im investigating whether or not State of Georgia, who has adopted IBC and NFPA 101, can clear up what is mandatory
 
Check how they have chosen to address the minimum requirements of the ADA Standards for Accessible Design, your architect should "know" this.
 
You might be able to us a sliding door since the OL less than 10

9. In other than Group H occupancies, manually operated horizontal sliding doors are permitted in a means of egress from spaces with an occupant load of 10 or less.
 
One way to look at it:
If the the type of projectors to not require constant monitoring (like film projectors), and instead only require occasional monitoring by "service personnel" for "maintenance, repair or occasional monitoring", then the space it is located in is exempt per ADA 203.5 "Machinery Spaces".

Another way to look at it:
Theatrical lighting (such as a spotlight operator) up on catwalks is exempt per ADA 203.4 where spaces are "accessed only by ladders, catwalks, crawl spaces or very narrow passageways". A projector is a type of theatrical lighting, is it not

On the other hand, if this projector is in a conventional room with a path of travel via conventional stairs, hallways, and doorways, and this is normally/regularly occupied by a "projectionist" in order to start the movies, then you might not be exempt per the intent of the sections above.
 
Correctomundo MT. Ran in to this yesterday on a pre-ADA electric room (off a public corridor in a school) equipment change out (an alteration?). Its door opening was less than 32" clear. Transformer replacement (less than 800a service panel) so no panic hrdwr/outswinging door req'd but existing door must be widened/ or not?

As to employee work space (on a mezzanine vs 2nd floor - ADA T-1 (reasonable accommodation?) vs code requirement) in a movie theater, If theater is in a retail mall or building you may not qualify for a no elevator/lift exemption.


Or not. You can't make them make the door any bigger, especially if this is just an equipment replacement.
 
And what if the equipment is not like for like, then it is an alteration, no?

ADAguy, when someone asks a code or ADA question, it is helpful for everyone who renders opinion to cite the code in their response.
I request that you cite what code section leads you to assume that a not-like-for-like replacement of equipment triggers an alteration.

For example, in the case of your transformer, I believe that "Electrical work not involving placement of switches, receptacles" is listed as an exception in 11B-202.4.
In the case of a projector, if it is "equipment not considered to be a part of the architecture of the building or area", it is also exempt from alteration requirements for accessibility.

Lastly, the CBC / ADA 202 definition of "alteration", makes clear that it applies to the structure, not the "electrical systems" in the structure.
 
Applying Accessibility ( to new/existing buildings)

There are three key questions to answer that determine if and how accessibility requirements are applied to a particular area:”it depends”

  1. Which standard applies to the situation? If the project is in the United States, then the accessibility requirements could be the 2010 ADASAD, the IBC, or a local code that is more stringent than any of these for a particular parameter or in a particular type of facility. Local codes generally override state and federal requirements, unless the local codes are less stringent.
  2. Is the area an employee area or not? Many employee areas, including conference rooms, lounges, and cafeterias, are also accessible to visitors and must therefore follow accessibility guidelines. In employee-only work areas, ADA requirements do not apply except if the entry is off of an accessible circulation path. Then, access and egress requirements apply, meaning that wheelchair access must be provided to get into and out of the room (but maneuvering about the room and consoles do not need to meet ADA requirements).
  3. Is the area a circulation path? In a building with public access to presentation rooms and corridors, it is easy to determine what is a circulation path into, out of, and between accessible spaces in the building. In these areas, the ADA would apply. Once you get inside an employee work space, such as a closed office that is clearly not for circulation, then the regulations would not apply.
Some grey areas would include conference rooms, where areas around the conference table may be considered a circulation path in and out of the room. This would only apply, however, if the conference room was used by outside visitors and not just internal employees.

Control rooms and data centers often raise questions about accessibility. For most organizations, an AV control room and a data center would be considered employee-only spaces.

This means that within the space racks, consoles, counters, and clearances would not have to adhere to the ADA. However, if the entrance to such space is not employee-only, then the entrance and egress to the space would require accessibility.

This means that most AV projection and control rooms that are at the back of an auditorium would require accessibility into and out of the room (see local code for minimum clear door width allowed), element controls within the room may/may not require accessibility/ subject to reasonable accommodation requests. A ramp might be required up to the doorway if it's raised above the surrounding floor, and clearances would need to be provided just inside and outside the door for wheelchair accessAn alternative to a ramp into an employee-only control room would be to provide an employee-only corridor or storage space between the control-room door and the public area.

In this case, the entrance into the buffer space would need to be accessible, but a ramp would not be required inside the buffer space for the control entrance. This may take less space than a ramp when the control room is, say, 36 inches above the surrounding floor area.

lastly, consider use of alternate methods and means (robotics?)
 
COMMON USE. Interior or exterior circulation paths, rooms, spaces or elements that are not for public use and are made available for the shared use of two or more people.

Depending on the size of the theater one protectionist maybe all that is needed with today's equipment and they rarely have to enter the projection booth

Projectionist Job Description
The Motion Picture Association of America (*MPAA) r*eports that 95 percent of the world’s cinemas used digital projection in 2016. Prior to the introduction of digital movies, a projectionist’s duties included loading film onto the projector, paying attention to the film’s progress and changing film reels as needed. It was also up to the projectionist to splice together pieces of film with ads and movie trailers that would be shown along with the film.

Today, jobs in motion picture projection mean using a computer and s*pecial software* to set up a playlist that is typically used for a week. Films are delivered to theaters in digital form on hard drives by distributors, so there is no longer a need to inspect film for scratches or splice broken film together, which was part of a projectionist’s job duties in the pre-digital days. The playlist created for digital film projection can be programmed to turn theater lights off and on and cue sound as well as play ads, previews and films. Once a theater’s playlist has been created, a manager or some other employer can start it each day with the touch of a button. A projectionist is not required to be present during movie showings in many modern theaters.
 
May qualify as an alternate methods and means, you should have said so at the beginning of this discussion.
Another case of "needing to know" what to know, in order to determine "what" to do (smiling).
 
Applying Accessibility ( to new/existing buildings)

There are three key questions to answer that determine if and how accessibility requirements are applied to a particular area:”it depends”

  1. Which standard applies to the situation? If the project is in the United States, then the accessibility requirements could be the 2010 ADASAD, the IBC, or a local code that is more stringent than any of these for a particular parameter or in a particular type of facility. Local codes generally override state and federal requirements, unless the local codes are less stringent.
In your first key question, the immediately necessary follow-up question, before proceeding with the other questions, is: What does the applicable code/standard actually require for the proposed situation?

For example:
If the projection is all digital and the programming is done away from the projection room, so that no one is required to be physically present at the projector is required in order for it to operate, then ADASAD 202.4 applies, and no accessibility is required to the projector. The projector functions as a glorified light fixture.

In that case, you don't need to cite "alternate means and methods", because it is not an alternative to the accessibility code: the projection room is already in full compliance with accessibility code.

Finding and stating the applicable code reference is essential to eventually arriving at a code-compliant correct course of action. Otherwise, it's all just speculation.
 
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