Restricted entrance

[Sifu]

The code and commentary indicate a door that is for common use on a controlled basis, but not for public use is a restricted entrance. Commentary goes on to say that the key provision here is that the door must have controlled access to meet the definition, and further that a simple locked entrance door does not.

So I have an office suite, in a very large F1. The office suite is proposing to add an exterior door during a remodel. The existing suite had no door, but for the life of me I can't see where the accessible route to it was, unless it was over 500' long, through the factory floor, across the storage warehouse but that's another story. Now they want to add a non-accessible door. They do not provide "controlled access" as far as I can tell, though I need more information about that. The problem is the notion that all of the office staff can enter via this door (it is noted as having the sidewalk extended from the existing parking lot) but a disabled person can't, and that is ok because there is no key-fob (controlled access). Not sure that makes sense.

 

[classicT]

I am not sure what code series you are on, but answering based on the 2021 IEBC.

In my assessment, the office suite is clearly an area of primary function. Adding a door to this space is clearly an alteration. Given such, it would be clear that IEBC 306.7.1 - Alterations Affecting an Area Containing a Primary Function applies in this case.

As such, the route to this primary function area shall be accessible. While the owner/applicant may attempt to indicate that an alternate accessible route exists, I would point to IBC 1104.5. Given that the route is new, the IEBC points to the IBC for how to construct. Per IBC 1104.5, accessible routes must coincide with the general circulation path. Therefore, given the complex and length expressed in what may or may not be an existing accessible route, I'd indicate that the new door shall be provided with an accessible route.

One other section to consider is IEBC 306.7.5. I would however note that this is not an alteration to an existing entrance, so the entrance is not altered. This is a new entrance. Furthermore, this section also points to 306.7.1.

IEBC 306.7.1 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 and 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 a facility.
5. This provision does not apply to altered areas limited to Type B dwelling and sleeping units.

IEBC 306.7.5 Entrances​

Where an alteration includes alterations to an entrance that is not accessible, and the facility has an accessible entrance, the altered entrance is not required to be accessible unless required by Section 306.7.1. Signs complying with Section 1112 of the International Building Code shall be provided.

IBC 1104.5 Location​

Accessible routes shall coincide with or be located in the same area as a general circulation path. Where the circulation path is interior, the accessible route shall be interior. Where only one accessible route is provided, the accessible route shall not pass through kitchens, storage rooms, restrooms, closets or similar spaces.
Exceptions:

1. Accessible routes from parking garages contained within and serving Type B units are not required to be interior.
2. A single accessible route is permitted to pass through a kitchen or storage room in an Accessible unit, Type A unit or Type B unit.

 

[classicT]

One further aspect to expand upon since I did not address the restricted entrance aspect...

IBC 1105.1.4 Restricted Entrances​

Where restricted entrances are provided to a building or facility, at least one restricted entrance to the building or facility shall be accessible.

[BE] RESTRICTED ENTRANCE. An entrance that is made available for common use on a controlled basis, but not public use, and that is not a service entrance.

 

[Sifu]

Agree with it all. I have commented on the need for an accessible route, and for an accessible entrance. I do anticipate that they will try the restricted entrance path, and I will then explain that I don't believe it is a restricted entrance but even if it is one of them has to be accessible, and since it is the only one, either serving the B, or serving the entire facility, the solution is to make it accessible. (There are 11 other existing restricted entrances, that all serve the F1, so they are legit....though none of them appear to be accessible) This is a new opening so I think it must meet the IBC. The entrance they are proposing does not serve the employees of the F1, it serves the employees of the B. To me it is evident that they are providing the office workers a way in and out that does not cross the factory floor, and is much shorter....unless the office worker is mobility challenged. I have no issues citing the codes that won't permit this.

What I am concerned with is the notion that it is an employee entrance, but not for ALL employees. The employee who can't traverse stairs will need to travel at least 500 additional feet, across the factory floor, yet the code and commentary seem to say that is OK as long as it is an access controlled opening, making it a restricted entrance, and not subject to the public entrance requirement for accessibility. It seems like my understanding of this section must be way off base, or this is poor code.

 

[classicT]

What I am concerned with is the notion that it is an employee entrance, but not for ALL employees. The employee who can't traverse stairs will need to travel at least 500 additional feet, across the factory floor, yet the code and commentary seem to say that is OK as long as it is an access controlled opening, making it a restricted entrance, and not subject to the public entrance requirement for accessibility. It seems like my understanding of this section must be way off base, or this is poor code.

Can you provide the code path that gets you to that? I'm not seeing it...

IMHO, I do not think you are dealing with a restricted entrance. Restricted entrances are more commonly associated with Group I facilities, or secured buildings such as court houses, police stations, etc. If the entrance is not intended for the general public (customers, deliveries, etc.) but is available to any employee, I would still assess that it is a public entrance. Public does not always mean everyone and anyone. Placing electronic locks or other security on the door does not automatically make it a restricted entrance.

 

[Sifu]

Can you provide the code path that gets you to that? I'm not seeing it...

IMHO, I do not think you are dealing with a restricted entrance. Restricted entrances are more commonly associated with Group I facilities, or secured buildings such as court houses, police stations, etc. If the entrance is not intended for the general public (customers, deliveries, etc.) but is available to any employee, I would still assess that it is a public entrance. Public does not always mean everyone and anyone. Placing electronic locks or other security on the door does not automatically make it a restricted entrance.

I agree, I don't think this is a restricted entrance, but the way I read the definitions, if they put access control on the door, they may try that route based on the definition, even if everyone knows it is an employee entrance. The rub in the definition is "public use". They installed a new door, landing and steps, to an office space in the factory. If they tell me it is NOT an employee (public) entrance, and they put access control on it, I think I must consider it a restricted entrance if they go that route. The irony seems to be that if they put access control (key fob, card reader, etc) then it could be a restricted entrance by definition, and this is the very thing that would make it an ideal employee entrance. I am citing the deficiency, we'll see what they say.

 

[steveray]

It's a new entrance, therefore it is "new" code....One restricted would have to be accessible, "service" maybe not....

801.4 Compliance​

New construction elements, components, systems and spaces shall comply with the requirements of the International Building Code.