Scope of access for nursing home alterations, CBC 11B

[Yikes]

I am confused by the scope of alterations required by CBC 11B as it applies to nursing homes and other licensed long-term care facilities.
CBC 11B-202 has the usual scoping requirements for existing facilities, including exceptions for technical infeasibility, exceptions for work being undertaken solely for accessibility improvements, the 20% valuation rule for path-of-travel, etc.

Later on, CBC 11B-223.1.1 seems to have yet more requirements for "Alterations", including a requirements if we alter a patient room, we have to upgrade its restroom, etc. until we reach the same number as if for new construction, which per 11B-233.3 is 50% of the patient rooms!

So which applies as to scope of accessibility upgrades: 202 or 223/233?

Background:
I've been asked to help an owner/operator of a licensed "rest home" for the elderly. It was built in the 1960s with a D-3 "nursing homes for ambulatory patients" and B-2 certificate of occupancy, and all the bathrooms are too small for accessibility (5'x7'), door strike clearances are too small, etc. The client wants to do selective accessibility upgrades: widen the entry doors, replace some bathtubs with zero-threshold showers, etc., but we will never have enough room to meet current floor clearances.

• If 202 governs, we can make selective accessibility upgrades without triggering 223, and reasonableness prevails.
• If 223 governs, we have no choice but to completely remodel 50% of patient bedrooms and bathrooms per 233.3 - - or not do any remodel at all.

 

[ADAguy]

Interesting quandry, if you swing the doors out will that make the bathrooms work better?
Is the facility slab on grade or a crawl?
Does 5 x 7 indicate wall to wall or clear floor space available?

 

[Yikes]

5x7 is the approximate wall-to wall space. It is taken up by a 30"x60" tub, about 30 x60" clear floor space (incl. door swing), and about 24"x60" for toilet and wall hung lav.
If I swing the door out, there won't be code compliant clearance on the outswing side. And the walls aren't long enough to make a 36" pocket door.
We could, upon request of tenant, take off the bathroom door altogether and install a curtain instead.

 

[steveray]

Not a CA guy, but.....The intent of the gimme on accessible improvements (work being undertaken solely for accessibility improvements) is that you are not penalized for trying to make it any better. So if that truly is the intent, the 20% or 50% or whatever should not apply...IMO