Good evening all. This is my first question posted, so let me start by thanking you for this great forum, and for sharing your considerable collective expertise so generously.
The applicable codes/guidelines are the ADAAG and the 2010 CA building code (CBC), which is generally based on the 2009 IBC, but not in the case of Chapter 11, including the IBC exemption for walk-in coolers used only by employees (1103.2.15) which does not apply in CA. Apart from some things not relevant to this issue, the CBC exempts from the accessibility requirements only the following:
1. Floors or portions of floors not customarily occupied, including, but not limited to, nonoccupiable or employee spaces accessed only by ladders, catwalks, crawl spaces, very narrow passageways or freight (nonpassenger) elevators, and frequented only by service personnel for repair or maintenance purposes, including, but not limited to, elevator pits and elevator penthouses, piping and equipment catwalks, and machinery rooms (CBC 1103B.1(1), similar to IBC 1103.2.9).
The ADAAG also does not address walk-in coolers directly, but says:
Areas that are used only as work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas. These guidelines do not require that any areas used only as work areas be constructed to permit maneuvering within the work area or be constructed or equipped (i.e., with racks or shelves) to be accessible (4.1.1 (3).
The project is a new grocery store, with several walk-in coolers and freezers, none of which would be accessible to anyone other than employees. I asked an official in the AHJ how they would deal with cooler accessibility, and was told that, if treated as equipment, then the cooler would not need to be made accessible, but that it might or might not be equipment. I can't find a definition of equipment either in CBC chapter 11B, or in the general CBC definitions. I was also told that, even if coolers were not equipment, i.e. therefore required to be accessible, then it would basically be a matter of providing clearances at the door, so the coolers would be only partially accessible. I cannot find any clause in CBC Chap 11B that says this. As additional background, the CA State Architect has published a code interpretation that walk-in coolers are equipment, and do not need to be made accessible (DSA IR_A-14_rev 08-03-11), but this applies only where the DSA has jurisdiction, and not to an ordinary commercial building.
This all seems very muddy. The 2009 IBC and the code interpretation from the CA State Architect are clear, but are not applicable. The ADAAG and CBC are applicable, but are not clear as to whether accessibility to walk-in coolers is required, and if so, which issues must be addressed for there to be compliance (clearances only? or door handles? door weight? level path of travel into freezers with insulated floors, etc?) The AHJ approach to this, so far (no plan check yet), is along the lines of if, but, maybe.
Does anyone have a view as to what the legal requirement is, and is there a code ref establishing clearly what this is?
The applicable codes/guidelines are the ADAAG and the 2010 CA building code (CBC), which is generally based on the 2009 IBC, but not in the case of Chapter 11, including the IBC exemption for walk-in coolers used only by employees (1103.2.15) which does not apply in CA. Apart from some things not relevant to this issue, the CBC exempts from the accessibility requirements only the following:
1. Floors or portions of floors not customarily occupied, including, but not limited to, nonoccupiable or employee spaces accessed only by ladders, catwalks, crawl spaces, very narrow passageways or freight (nonpassenger) elevators, and frequented only by service personnel for repair or maintenance purposes, including, but not limited to, elevator pits and elevator penthouses, piping and equipment catwalks, and machinery rooms (CBC 1103B.1(1), similar to IBC 1103.2.9).
The ADAAG also does not address walk-in coolers directly, but says:
Areas that are used only as work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas. These guidelines do not require that any areas used only as work areas be constructed to permit maneuvering within the work area or be constructed or equipped (i.e., with racks or shelves) to be accessible (4.1.1 (3).
The project is a new grocery store, with several walk-in coolers and freezers, none of which would be accessible to anyone other than employees. I asked an official in the AHJ how they would deal with cooler accessibility, and was told that, if treated as equipment, then the cooler would not need to be made accessible, but that it might or might not be equipment. I can't find a definition of equipment either in CBC chapter 11B, or in the general CBC definitions. I was also told that, even if coolers were not equipment, i.e. therefore required to be accessible, then it would basically be a matter of providing clearances at the door, so the coolers would be only partially accessible. I cannot find any clause in CBC Chap 11B that says this. As additional background, the CA State Architect has published a code interpretation that walk-in coolers are equipment, and do not need to be made accessible (DSA IR_A-14_rev 08-03-11), but this applies only where the DSA has jurisdiction, and not to an ordinary commercial building.
This all seems very muddy. The 2009 IBC and the code interpretation from the CA State Architect are clear, but are not applicable. The ADAAG and CBC are applicable, but are not clear as to whether accessibility to walk-in coolers is required, and if so, which issues must be addressed for there to be compliance (clearances only? or door handles? door weight? level path of travel into freezers with insulated floors, etc?) The AHJ approach to this, so far (no plan check yet), is along the lines of if, but, maybe.
Does anyone have a view as to what the legal requirement is, and is there a code ref establishing clearly what this is?
