It is a vehicle and not under your jurisdiction as a building department.
It is not a building or structure that would be regulated under the building codes. You can not require a permit to place it at an active fire scene. Heck that would probably take a year or more to get through the process in California.
In other words it is not your problem if it is not accessible
I don't work at a building department and my client asked me to look into this, so it's unfortunately my problem.
Building permit? No. You're correct, we don't need one for that trailer as far as I'm aware.
Building code requirements? Possibly, at least while it's in the warehouse. That's what I'm trying to figure out.
I believe the shower trailer is an HCD-regulated commercial/special-purpose commercial modular unit subject to
CBC Chapter 11B under
25 CCR §4353. Under
IBC / CBC 105.2, permit exemptions do not authorize work that violates the CBC. Separately,
Gov. Code §4450–§4461 and
ADA Title II (28 CFR §35.151; 2010 ADA Standards) require accessibility for new/altered local-government
facilities.
But this is a "Building Code" forum... Let's start with CBC Chapter 1:
Scope of DSA-AC (Accessibility):
CBC 1.9.1.1 Application
See Government Code commencing with Section 4450.
Publicly funded buildings, structures, sidewalks, curbs
and related facilities shall be accessible to and usable by persons with disabilities as follows:
...
CBC 1.9.1.1.2
All buildings, structures and
facilities that are leased,
rented, contracted, sublet or hired
by any municipal, county or state division of government, or by a special district. For public housing see Section 1.9.1.3.
...
CBC 1.9.1.1.4
With respect to buildings, structures, sidewalks, curbs and related
facilities not requiring a building permit,
building standards published in the California Building Standards Code relating to access for persons with disabilities and other regulations adopted pursuant to Government Code Section 4450, and in effect at the time construction is commenced,
shall be applicable.
IBC / CBC 105.2
Exemptions from permit requirements of this code shall not be deemed to grant authorization for any work to be done in any manner in violation of the provisions of this code or any other laws or ordinances of this jurisdiction.
Okay, so anything that's a "building" or "facility" that is used by the government needs to comply with accessibility requirements, regardless of if a permit is required or not. Is this a building or facility?
Definition of "temporary" as defined in our building code with DSA advisory:
Definition of "facility" as adopted in our building code:
"All or any portion of buildings, structures, site improvements,
elements and pedestrian or vehicular routes located on a site.
[DSA-AC] All or any portion of buildings, structures, site improvements, elements, and pedestrian routes or vehicular ways located on a site."
Definition of "Element" as adopted in our state:
Element [DSA-AC]
An architectural or mechanical component of a building, facility, space or site.
This trailer meets the definition of "temporary" "facility" as defined and adopted by DSA-AC as far as I read it.
If it weren't being hauled around, it would need to be accessible imo. But since it's being used both inside and in the field and it's use in the field is restricted to certain personal, I'm trying to determine accessibility only applies in the warehouse or not at all (I'm under the assumption it wouldn't apply when deployed in the field).
