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Relocatable buildings

Sifu

Sifu

SAWHORSE
Joined
Sep 3, 2011
Messages
2,808
Are there any interior accessibility requirements for a relocatable building? I may have erroneously cited accessibility requirements based on IEBC 305, but the scope provided in 305.1 does not include relocatable buildings, and there is no accessibility scoping in ch. 14. There is no alteration to the interior or exterior of the structure. It is a prefab lab container. Using 2018 IEBC/IBC.
 
At first i thought you were talking about a tent. It’s a manufactured unit, like a guard shack, toilet-on-a-trailer, etc. Why wouldn’t it require exterior accessibility?
 
Here in Mass temporary facility that are open to the public have to met the same standards as fixed structures.
Accessible porta potties have to be provided, so why would relocatable structures not have to comply?
 
TheCommish said:
Here in Mass temporary facility that are open to the public have to met the same standards as fixed structures.
Accessible porta potties have to be provided, so why would relocatable structures not have to comply?
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It is not temporary, even thought they are calling that....whole 'nother issue. This is one of those cases where I looked at the code a little closer because this is the 3rd submittal and they continue to ignore the comments, so I wanted to be 110% sure. And to my surprise, I can't find the code path. It was my assumption that compliance was required, but it may not be as clear as I thought. The IEBC scopes alterations, but no alterations are occurring. Reading the commentary for ch. 14 I infer that unless alterations occur, there is no requirement for retroactive compliance to the accessibility provisions. The IEBC has a requirement for "field fabricated" elements to comply with the IBC, but even that is debatable. Is that intended for a set of prefab stairs, manufactured and reused over and over? Or only to a wood stair built on site? It looks like they are proposing prefabricated stairs, but can't seem to find a way to provide compliant details. No ramp, but now I question whether it is required by code. An accessible route is required to be provided to accessible buildings, but if there is no scoping to require the building to be accessible, or to get us to IEBC 305 or IBC ch.11, I'm not sure I can even get there.
 
RELOCATABLE BUILDING. A partially or completely assembled building constructed and designed to be reused multiple times and transported to different building sites.

RELOCATABLE BUILDING. A partially or completely assembled building constructed and designed to be reused multiple times and transported to different building sites.

1401.2 Conformance.
The building shall be safe for human occupancy as determined by the International Fire Code and the International Property Maintenance Code. Any repair, alteration or change of occupancy undertaken within the moved structure shall comply with the requirements of this code applicable to the work being performed. Any field-fabricated elements shall comply with the requirements of the International Building Code or the International Residential Code as applicable.

That would include accessibility to enter the building.
 
It is existing, constructed 13 years ago specifically for this user according to the original documents. Looks to have been manufactured in Canada, no idea where it has been used previously. A new engineering analysis to the current and local conditions has been performed per code. "Any field fabricated elements" doesn't seem to dictate which field fabricated elements to provide, only those that are provided. Further, what exactly does "field fabricated" mean? If the MFR included prefab steps with the building, are they field fabricated?

I'm not trying to argue for or against a position, but I want to be sure I am administering the code correctly, no matter which way it ends up.
 
In Virginia the Industrialized Building Safety Law requires buildings manufactured offsite to be constructed in accordance with the IBC, and requires "any noncomplying unregistered building to be brought into compliance with this chapter". The installation and alterations must comply with the Virginia Uniform Statewide Building Code. See if your state has a similar law.

In any case, ADA still applies and they can be sued if the building is required to be accessible but isn't.
 
Paul Sweet said:
In Virginia the Industrialized Building Safety Law requires buildings manufactured offsite to be constructed in accordance with the IBC, and requires "any noncomplying unregistered building to be brought into compliance with this chapter". The installation and alterations must comply with the Virginia Uniform Statewide Building Code. See if your state has a similar law.

In any case, ADA still applies and they can be sued if the building is required to be accessible but isn't.
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If there are similar state laws here I am not aware of them. We don't have a statewide building code. The ADA element is why I am asking the questions. I realize they are subject to it, but they apparently don't care. As far as I can tell, I don't have the authority to compel compliance with the IBC or the ANSI standard.
 
TheCommish said:
if it is not accessible who is fouled by the the inability to access the building?
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The entire structure is an employee workspace, but the route and toilet would still need access if it were subject to the requirements.
 
TheCommish said:
Then the answer to the question is the building needs to be made accessable, and proably shoud have been when it was built-installed 13 years ago
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Yep it should be, but what is the (adopted) code that mandates it? As mentioned, I can't put my finger on a specific requirement. This is a much bigger issue than this lab trailer as we have lots of "relocatable" buildings like sales trailers, classrooms etc. I would love to find that code that compels compliance, but so far I can't. And it should have complied 13 years ago, but it didn't, and the IEBC is the code we use for this situation, and it is in there that I think the requirements would be.
 
mtlogcabin said:
1401.2 Conformance.
The building shall be safe for human occupancy as determined by the International Fire Code and the International Property Maintenance Code. Any repair, alteration or change of occupancy undertaken within the moved structure shall comply with the requirements of this code applicable to the work being performed. Any field-fabricated elements shall comply with the requirements of the International Building Code or the International Residential Code as applicable.
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I only see field fabricated elements must comply, not the relocatable building it self.
 
bill1952 said:
I only see field fabricated elements must comply, not the relocatable building it self.
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Ok, i can see that. That section says ... if you build something for the relocatable building, like steps, deck, etc … that must comply. That’s kind of a no brainer.
 
IMHO they need to be complaint with ANSI A117. Here we have local ordinance that any structure to be in place for more than 30 days is not considered temporary. Beyond that, it is being move to a new site and there fore should meet all requirements for new construction, period end of story. This is my reasoning why there isn't anything in the IEBC, because the code considers it new when moved to a new location. Any other building would need to be complaint. Might give them a break on restrooms, but would make them as complaint as possible. If you use their logic we would have thousands of school and other portable buildings without compliance.
 
Another way to say it is when they moved it, all work is new, just like remodeling a building the new WORK required to meet the new code. Footing, piers, drainage, grading, sidewalks, entrances, parking etc.
 
The problem is that there are provisions in the IEBC, just not for accessibility. If they were not addressed at all, like previous to the IEBC, then everyone is free to make their own determination. But now, with provisions, it becomes more difficult to provide a code path to require compliance. I think ch. 14 was written to make them more usable in today's world than simply not allowing them. I also think ch. 14 may fall short in many ways, but it is what we have to work with. For this job I left it in the hands of the BO. Partly because I fall short in my determination and am hesitant to proceed without ANY accessibility even though I am becoming convinced I can't require it, but also because this was all done without a permit, it is currently installed and being used, and has been for months.
 
I appreciate your thoughtful post sifu.

Seems difficult to judge without knowing the situation. I recall reading of mobile showers at a wild fire fire fighter encampment being cited as not accesible. Same relocatable building in a homeless encampment would seem different.
 
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