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What Stairs Require ADA Compliance?

There is no such thing as an ADA-compliant stair. Accessible routes use lifts or ramps.

An accessible means of egress can include stairs.
You seriously want to split that hair?
If an accessible means of egress can include stairs then the stairs are accessible and meet ADA guidelines for accessibility.
 
Take this for an example...

I agree, a new monument stair should coincide with an accessible route and per IBC 1104.5 "Accessible routes shall coincide with or be located in the same area as a general circulation path." Obviously though, a monument stair cannot provide an accessible route; stairs are not a component of accessible routes and a ramp, lift, or elevator is needed.

However, a monument stair would likely be an interior exit access stairway. In most cases, these stairs are not part of the MoE. They may be used during a building evacuation, but are often not a part of the marked/designed MoE. The monument stairway is often in addition to the required MoE.

Therefore, as the monument stair is not part of the accessible MoE required by 1009.1 (posted above). However, if it were, then it would possibly require an area of refuge per 1009.3.3. A number of exceptions exist, but it is really not necessary in examples such as Jar put in the OP where two exit stairways are provided.
A new stair may not be defined as an MoE, but still Shall be accessible.
 
You seriously want to split that hair?
If an accessible means of egress can include stairs then the stairs are accessible and meet ADA guidelines for accessibility.
I don't believe I am splitting hairs, but am making sure there is a clear distinction between accessible routes and accessible MoE. The two are not the same, nor even related to the same provisions of the code.

An accessible MoE is not an accessible route, and where using stairs, does not comply with A117.1 nor ADA for an accessible route. Accessible routes cannot include stairs.
 
  • The scoping for accessible routes is determined by ADAS 206, and the enumerated components are in ADAS Division 5 "Accessible Routes", section 402.2. Stairs are not listed component for accessible routes in 402.2.
  • The scoping for accessible means of egress is in ADAS 207, which defers to the building code for technical requirements.
  • The scoping for accessible stairs are in ADAS 210, sandwiched after "Passenger drop off" (209) and before "Drinking fountains" (211), "Kitchens" (212), and "Toilet Facilities" (213). The technical requirements are found in ADAS Division 5 "General Site and Building Elements", section 504.
  • 1701896759336.png

Thus, stairs are treated like other components in ADAS requiring accessibility (risers, treads, nosings, handrails, etc.) per 210 and 504, even though they are not themselves considered part of an accessible route in ADAS Division 4.

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