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Question Regarding CBC-11B-206.3 Location

phamster

Member
Joined
Aug 9, 2014
Messages
17
Location
San Francisco
The section states the following:

"Accessible routes shall coincide with or be located in the same area as general circulation paths. Where circulation paths are interior, required accessible routes shall also be interior. An accessible route shall not pass through kitchens, storage rooms, restrooms, closets or other spaces used for similar purposes, except as permitted by Chapter 10."

Does this mean that the door(s) leading to the areas in which the accessible route shall not pass through do not need to be accessible unless required elsewhere in the code?

I have a 110sf storage room in a small cafe that I'd like to have accessed only by a pocket door. The hardware on the door will not be accessible. Is there something in the code which prevents me from doing this?
 
"An accessible route shall not pass through...". The operative word is "through". For example, you can't make someone go from the entry lobby through a restroom into order to get to a cafe dining area.

In your case if, after reviewing 11B-206.2.8, 11B-804.5, and 11B-811, you've determined that the cafe storage needs to be accessible, then the storage needs to have an accessible route to it. But the storage room should not be used as part of the accessible route to go through it to other rooms, unless it is also allowed by the Means of Egress code chapter 10.
When there's a pocket door on that accessible route, it needs to be made accessible.

Here's an example:

1637346355491.png
 
I think the more succinct version of the question is: Do storage rooms have to be accessible?
11B-206.2.8, 11B-804.5, and 11B-811 will help answer that question.

If it is storage is serving a "kitchen, kitchenette or wet bar", then 11B-804.5 says that 50% of its storage shelving needs to be accessible; thus you need a path to the accessible storage.
Typically the phase "kitchen, kitchenette or wet bar" refers to a dwelling unit kitchen, a break room kitchen at a workplace, etc.
However, if the "kitchen, kitchenette or wet bar" is not the break room, but is the employee workstation (for example, a giant mixer at a food manufacturing plant), then the issue is not about kitchen storage shelving; the issue becomes solely about the "common use circulation path" to "employee work areas"per 11B-206.2.8.

Let's say the storage room in question is generic storage for the materials used by the person preparing food or drink for sale at the cafe. 11B-206.2.8 would say that if there is a common use circulation path to the storage (in other words, it's not some pull-down attic access ladder that gets used once a year, or it's not a dock-height storage that can only be reached from a 4' high truck bed), then it needs to have an accessible route to the room per 11B-402, and yes, the door would need to be accessible. A CASp may even argue that some token amount (one square foot) of storage shelving should be accessible.
In that scenario, the answer is "yes, storage rooms need an accessible path to the room".

In my opinion (feel free to disagree):
  • If everything in the room is within 24"-25" reach range of a person outside the room (see fig 11B-308.2.2, fig 11B-308.3.2) - - for example, a shallow closet - - then there is no need for the wheelchair to enter the closet, and the accessibility requirement is no different than any other cabinet.
  • If the room is more than 24" but less than 48" deep, then the wheelchair needs to be able to pass through the door (32" clear width, compliant threshold); the back of the wheelchair remains touching the accessible route, and the wheelchair user can reverse out of the door opening.
  • If the room is 48"+ deep then a wheelchair can go fully "into' the room, and therefore the room needs to provide the 60" turnaround space somewhere in the storage room, to be able to exit.
However, another exception: if the "storage room" was (for example) a floor upon which coffee beans were laid out to dry, then the floor becomes "employee work areas that are an integral component of the work area equipment", because the floor is now equipment (a dryer); thus no access to the floor would be required per 11B-206.2.8 exception #2.

There was another recent thread on whether a money storage vault needed to be accessible - -it may help explain this issue.
 
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