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Ramp requirements

The OP was about a patio restaurant, so we are not dealing with FHA.
I get that, I was responding to ADAguy's comment that ANSI is not code in CA. It is for multifamily covered under the FHA was my comment. CA accessibility code may be more restrictive so it doesn't matter, but FHADM & ANSI are still required in CA. I have an impulse to correct anyone who says the FHA doesn't apply in their jurisdiction. It always applies in the entire US for covered projects. You may not use it; I don't use it on MN projects because the MN Accessibility Code is more restrictive than the 2009 ANSI. I do use FHADM because it has a few additional scoping requirements MN must have missed or didn't address.

I should have asked my question better about the detectable dropoff. I am not aware of the requirement in either ANSI or ADASAD. Wondering if I missed something or if it was CA specific.
 
ADAguy, regarding edge awareness: If a typical 6" high curb along the edge of a public sidewalk is not required to have any special additional detectable devices, why would the edge of a 6" high ramp or sloping walkway require additional cane detection?
 
I get that, I was responding to ADAguy's comment that ANSI is not code in CA. It is for multifamily covered under the FHA was my comment.
Yeah, but that's where I'm still confused, too. (And I realize now we're getting off topic of the original post, but bear with me.)
As I understand it, FHADM is a standalone document. FHADM does not require a user to research ANSI 117.1 to see if the project complies with FHADM. See the copy of the Preface from FHADM below.


1618017155037.png

FHADM covers both technical AND scoping criteria and is thus a standalone safe harbor.
Here we see that ANSI 117.1 is listed in 3 of 6 alternative safe harbors for technical criteria, but it does not cover scoping, so it has to be taken in conjunction with the scoping in FHADM.
So, it's easier for us to just use the FHADM (+HUD +Guidelines) as a standalone, and not bother consulting ANSI 117.1.
More to the point, California's own CBC-11A was based on (and in several ways exceeds) FHADM, so during the building design process, most professionals out here tend to focus primarily on 11A in the effort of compliance with FHADM.

ANSI is not code in CA.
ADAguy is technically correct that FHADM (and ADA, for that matter) is not "code" in CA, in the sense that the state did not adopt FHADM as a code and does not require the authorities having local jurisdiction to plan check utilizing FHADM.
Instead, CA plan checks to CBC-11B code for public facilities, or CBC-11A code for private housing.

Having said that, there is a preamble "Note 1" at the very start of CBC 11A, that helpfully reminds everyone to comply with the most stringent requirements of "more than one jurisdiction" either federal, state, or local laws, and it makes specific reference to a HUD/DOJ statement dated 4/30/13. That letter is all about the scoping applicability of federal FHA to private housing. See image below.
Conclusion: it is semantically correct to say that FHADM is not "code" enforced by the jurisdiction of California building departments, but is is still a "requirement" that is enforced by the federal government via post-construction civil litigation, and woe to the person who forgets this.

1618015967771.png
 
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Yeah, but that's where I'm still confused, too. (And I realize now we're getting off topic of the original post, but bear with me.)
As I understand it, FHADM is a standalone document. FHADM does not require a user to research ANSI 117.1 to see if the project complies with FHADM. See the copy of the Preface from FHADM below.


View attachment 7725

FHADM covers both technical AND scoping criteria and is thus a standalone safe harbor.
Here we see that ANSI 117.1 is listed in 3 of 6 alternative safe harbors for technical criteria, but it does not cover scoping, so it has to be taken in conjunction with the scoping in FHADM.
So, it's easier for us to just use the FHADM (+HUD +Guidelines) as a standalone, and not bother consulting ANSI 117.1.
More to the point, California's own CBC-11A was based on (and in several ways exceeds) FHADM, so during the building design process, most professionals out here tend to focus primarily on 11A in the effort of compliance with FHADM.


ADAguy is technically correct that FHADM (and ADA, for that matter) is not "code" in CA, in the sense that the state did not adopt FHADM as a code and does not require the authorities having local jurisdiction to plan check utilizing FHADM.
Instead, CA plan checks to CBC-11B code for public facilities, or CBC-11A code for private housing.

Having said that, there is a preamble "Note 1" at the very start of CBC 11A, that helpfully reminds everyone to comply with the most stringent requirements of "more than one jurisdiction" either federal, state, or local laws, and it makes specific reference to a HUD/DOJ statement dated 4/30/13. That letter is all about the scoping applicability of federal FHA to private housing. See image below.
Conclusion: it is semantically correct to say that FHADM is not "code" enforced by the jurisdiction of California building departments, but is is still a "requirement" that is enforced by the federal government via post-construction civil litigation, and woe to the person who forgets this.

View attachment 7724
I think both cases are semantics.

The FHADM references ANSI in seemingly every paragraph for technical information. In some cases it specifically requires following a section of the ANSI standard. The two standards are inseperable. FHADM tells you to read ANSI.
For example, p.2.5 “When designing these areas it is essential to refer to the 1986 ANSI A117.1 Standard specifications 4.1 through 4.31, as appropriate (or an equivalent or stricter standard), for detailed dimensional design specifications for each required accessible element or space.”

I suppose I am used to referring to ANSI as the “code” because it is the half of the pair that reads like code instead of a narrative. Perhaps that isn’t technically the definition of “code” but it does have the same practical effect; you must design to its requirements. Is “code” only what the inspector looks for, or is it the legally required provisions for design?
 
In section 11B-405 of the California code, the requirement for handrails at ramps (405.8) has no minimum height, although other comparable accessibility codes (or standards as the case may be) limit this requirement to ramps with a rise greater than 6 inches. The requirement for edge protection (405.9) applies at ramps that require handrails, if the edge isn’t extended 12 inches or flared.
 
I suppose I am used to referring to ANSI as the “code” because it is the half of the pair that reads like code instead of a narrative. Perhaps that isn’t technically the definition of “code” but it does have the same practical effect; you must design to its requirements. Is “code” only what the inspector looks for, or is it the legally required provisions for design?
"Code" is only what the plan checkers and inspectors are legally allowed to look for. "Requirements" is more inclusive, because the word also contains what everyone else looks for, and the requirements come from a myriad of places, such as:
  • Legal requirements
  • Owner's requirements
  • Funder's requirements
  • Licensing agency requirements (especially true with daycare or education)
  • Product manufacturer's requirements
The reason it is important to make the distinction between "code" and "requirements" is so that design professionals don't get a false sense of security that a good plan check + a good inspection is somehow evidence they've met all requirements for a project.
On the title sheet of our own firm's plans, we include two lists:
1. Codes enforced by local Authority Having Jurisdiction. This will include the state model building codes as modified by the local jurisdiction, health department codes (for swimming pools, restaurants, etc.), local zoning ordinances - - basically, anything that stands between me and a building permit.
2. Additional regulatory requirements not enforced by local Authority Having Jurisdiction. This will include (for example, when applicable) ADAS, FHADM, Section 504 / UFAS with deeming notice, etc., daycare licensing requirements, etc.

And it is true that FHADM references ANSI, but in terms of FHA requiring a designer to follow ANSI 117.1, p. 2.5 of the FHADM says:
1618079284065.png
 
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"Code" is only what the plan checkers and inspectors are legally allowed to look for. "Requirements" is more inclusive, because the word also contains what everyone else looks for, and the requirements come from a myriad of places, such as:
  • Legal requirements
  • Owner's requirements
  • Funder's requirements
  • Licensing agency requirements (especially true with daycare or education)
  • Product manufacturer's requirements
The reason it is important to make the distinction between "code" and "requirements" is so that design professionals don't get a false sense of security that a good plan check + a good inspection is somehow evidence they've met all requirements for a project.
On the title sheet of our own firm's plans, we include two lists:
1. Codes enforced by local Authority Having Jurisdiction. This will include the state model building codes as modified by the local jurisdiction, health department codes (for swimming pools, restaurants, etc.), local zoning ordinances - - basically, anything that stands between me and a building permit.
2. Additional regulatory requirements not enforced by local Authority Having Jurisdiction. This will include (for example, when applicable) ADAS, FHADM, Section 504 / UFAS with deeming notice, etc., daycare licensing requirements, etc.

And it is true that FHADM references ANSI, but in terms of FHA requiring a designer to follow ANSI 117.1, p. 2.5 of the FHADM says:
View attachment 7732
 
There you have it, though AHJ's "only" review to code, There a number of "other" regs that may be required to be complied with subject to a projects use/ license.
 
In CA the only Accessibility codes Plan Checkers check for is CA Building Code and And modifications set forth by the State senate and assembly.

Not Hud Fair Housing Guidelines, Not ANSI, Not ADASAD, Not UFAS, Not IBC......
 
In CA the only Accessibility codes Plan Checkers check for is CA Building Code and And modifications set forth by the State senate and assembly.

Not Hud Fair Housing Guidelines, Not ANSI, Not ADASAD, Not UFAS, Not IBC......
Absolutely agree.
The crazy thing is, after the City of Los Angeles settled the lawsuit with HUD/DOJ, they are now in "once bitten, twice shy" mode.
LA Building and Safety is requiring projects that are (or, once upon a time, were) funded by their Housing and Community Investment Department be plan-checked by HCID for compliance with FHA, UFAS, etc. as a condition of obtaining building permit.
Let me repeat that: not as a condition of getting funded by the city, which would be fine, because a funder can ask for whatever they want; but rather, as a condition to obtain a building permit. And this is in addition to the Building Department's own (entirely appropriate) accessibility plan check per CBC 11A and 11B.

I know of projects that were built in the 90's, now seeking a minor alteration permit, that are being held up because the city is asking for proof of FHA compliance of the original construction, for which LADBS had previously plan-checked, permitted, inspected, and issued a C of O.

Any day now, the city attorney will need to weigh in on the legality of the city plan-checking to FHA when it has never been adopted in the Municipal Code.
 
Absolutely agree.
The crazy thing is, after the City of Los Angeles settled the lawsuit with HUD/DOJ, they are now in "once bitten, twice shy" mode.
LA Building and Safety is requiring projects that are (or, once upon a time, were) funded by their Housing and Community Investment Department be plan-checked by HCID for compliance with FHA, UFAS, etc. as a condition of obtaining building permit.
Let me repeat that: not as a condition of getting funded by the city, which would be fine, because a funder can ask for whatever they want; but rather, as a condition to obtain a building permit. And this is in addition to the Building Department's own (entirely appropriate) accessibility plan check per CBC 11A and 11B.

I know of projects that were built in the 90's, now seeking a minor alteration permit, that are being held up because the city is asking for proof of FHA compliance of the original construction, for which LADBS had previously plan-checked, permitted, inspected, and issued a C of O.

Any day now, the city attorney will need to weigh in on the legality of the city plan-checking to FHA when it has never been adopted in the Municipal Code.
Still not our job.
 
I know LAHA well, did a training for 300 of their M n O staff back in 2002. The did not follow through with their barrier removal, the same with LAUSD and city sidewalks case. They are costing taxpayers hundreds of millions to cure this. City as an owner must comply with "both" code and regs. They are not above the law.
 
"Code" is only what the plan checkers and inspectors are legally allowed to look for. "Requirements" is more inclusive, because the word also contains what everyone else looks for, and the requirements come from a myriad of places, such as:
  • Legal requirements
  • Owner's requirements
  • Funder's requirements
  • Licensing agency requirements (especially true with daycare or education)
  • Product manufacturer's requirements
The reason it is important to make the distinction between "code" and "requirements" is so that design professionals don't get a false sense of security that a good plan check + a good inspection is somehow evidence they've met all requirements for a project.
On the title sheet of our own firm's plans, we include two lists:
1. Codes enforced by local Authority Having Jurisdiction. This will include the state model building codes as modified by the local jurisdiction, health department codes (for swimming pools, restaurants, etc.), local zoning ordinances - - basically, anything that stands between me and a building permit.
2. Additional regulatory requirements not enforced by local Authority Having Jurisdiction. This will include (for example, when applicable) ADAS, FHADM, Section 504 / UFAS with deeming notice, etc., daycare licensing requirements, etc.

And it is true that FHADM references ANSI, but in terms of FHA requiring a designer to follow ANSI 117.1, p. 2.5 of the FHADM says:
View attachment 7732
Like I wrote above, semantics. "Code" is not really a legally defined term. You can define it as you want and I'll define it as I want. At no point have I ever relied on a plan review to ensure conformance with the code. Building departments take no responsibility for the completeness of their review.

Why the FHADM tells you you don't have to follow ANSI and then later in the same book tells you that you do is a mystery. I guess you can ignore it's direction to follow ANSI, it's your lawsuit.
 
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