who trumps who

[Examiner]

The following is my research on some questions presented to me at work today.

Code Research

Question;

Is there a minimum number of risers where you do not need a handrail?

Can you have one handrail?

Can you have open risers?

ADA 2010 Standards: Titles II and III & ICC/ANSI A117.1-2003

504 Stairways

504.3 Open Risers. Open risers are not permitted.

504.6 Handrails. Stairs shall have handrails complying with 505.

505 Handrails

505.2 Where Required. Handrails shall be provided on both sides of stairs and ramps.

2006 INTERNATIONAL BUILDING CODE®

1009.10 Handrails. Stairways shall have handrails on each side and shall comply with Section 1012.

Exceptions:

3. Decks, patios and walkways that have a single change in elevation where the landing depth on each side of the change of elevation is greater than what is required for a landing do not require handrails.

COMMENT:

Open Risers; The IBC Section 1009.3.3 does allow open risers in Exception #1. However, the opening cannot permit the passage of a 4” sphere. The Accessibility Codes do not allow open risers in any condition for a stair used as an accessible route.

Handrails; The IBC Section 1009.10 has an exception to not require handrails; however, the Accessibility Codes do require handrails. The IBC also allows one handrail for certain occupancies but the Accessibility Codes requires handrails on each side of the stair or ramp and does not mention occupancy use except it does mention Assembly.

So the question is now, if the IBC does not require a handrail, as 1009.10 Exception #3 states, does the Accessibility Codes require the handrail even for one riser? The IBC Exception referenced would allow one riser. Feel free to respond the the other questions in the body of the research.

 

[Coug Dad]

Trick question. You cannot have a single riser. Elevation changes less than 12 inches have to be by ramp. 1003.5 (2006)

 

[High Desert]

Trick question. You cannot have a single riser. Elevation changes less than 12 inches have to be by ramp. 1003.5 (2006)

Yes you can. Section 1003.5 tells you you can't have one "in the means of egress" while 1009.10, Exception 3 allows it at decks, patios and walkways. These would be locations that are not "in the means of egress" as stated in Section 1003.5. IMHO

 

[JBI]

Point - Counterpoint! Jane, you poor misguided, ignorant **** you! (Sorry, I was channelling Dan Ackroyd there for a second... )

The 'trick' part is the 'minimum' number of risers without a handrail... should be 'maximum'.

That said, what regulations do YOU enforce?

In 17 years of direct enforcement I was never authorized to enforce the ADA, nor ADAAG. State Code and, by reference, ANSI A-117.1 were my domain. Besides, if you look at Chapter 11 of the Code, I believe there may be requirements for 'accessible means of egress' that are more stringent than Chapter 10 requirements for means of egress generally.

Without more details about the stairs in question the querries are unanswerable.

 

[Frank]

ADA would only kick in on stairs that are part of the accessible route

Need to look at scoping

 

[Examiner]

Well it was not intended to be a trick question. Maybe just not clear which I seem to do sometimes.

Chapter 11 of the IBC (2006) addresses accessibility and requires compliance in Section 1101.2 with ICC A117.1. The 2006 Code uses ANSI A117.1-2003 edition. The building code does require enforcement of the FEDS accessibility requirements but it does require enforcement of ICC/ANSI A117.1.

If you compare the ICC/ANSI A117.1 to the 2010 ADA (Feds) they are very similar and use the same numbering system. However, there are a few differences in both. My post lists the section numbers and the words in both accessibility codes that are the same.

Chapter 11 of the IBC has sections in it that are similar to sections in Chapter 2 of the 2010 ADA (Feds). ICC/ANSI A117.1’s Chapter 2 is limited in the amount of text as compared to the Fed’s Chapter 2. It appears that ICC put most all of the Fed’s Chapter 2 text in IBC Sections found in Chapters 10 & 11.

Any stair can be used by the physically disable. Physically disable does not necessarily mean you are limited to wheelchairs. Wheelchairs, without assistance to be carried, cannot use the stairs but others can who may use walkers, canes etc could use the steps / stairs.

If an accessible route is required per the IBC it must also function as the means of egress for the physically disable. In most cases that requires ramps, chair lifts or elevators to access different level changes and other methods covered in IBC Section 1007.

Let’s assume that there is another accessible route provided to different levels using ramps in the same room / area. However, there are hypothetical steps / stairs nearby that can also be used by all and these are the bases for the questions.

Will handrails be required at the steps / stairs when there is only one riser?

Are open risers permitted?

Or should directional signage be provided to indicate the accessible route in lieu of providing compliance handrails / closed risers at the nearby steps/ stairs?

Think of liability possibilities.

 

[mtlogcabin]

Will handrails be required at the steps / stairs when there is only one riser?

Your example provided an accessible route down a nearby ramp so the exceptions could be applied to the single or two riser steps.

1003.5 Elevation change.

Exceptions:

1. A single step with a maximum riser height of 7 inches (178 mm) is permitted for buildings with occupancies in Groups F, H, R-2 and R-3 and Groups S and U at exterior doors not required to be accessible by Chapter 11. No handrail required.

2. A stair with a single riser or with two risers and a tread is permitted at locations not required to be accessible by Chapter 11, provided that the risers and treads comply with Section 1009.3, the minimum depth of the tread is 13 inches (330 mm) and at least one handrail complying with Section 1012 is provided within 30 inches (762 mm) of the centerline of the normal path of egress travel on the stair. This would apply to all other occupancies

 

[Papio Bldg Dept]

Chapter 11 of the IBC (2006) addresses accessibility and requires compliance in Section 1101.2 with ICC A117.1. The 2006 Code uses ANSI A117.1-2003 edition. The building code does require enforcement of the FEDS accessibility requirements but it does require enforcement of ICC/ANSI A117.1.

Any stair can be used by the physically disable. Physically disable does not necessarily mean you are limited to wheelchairs. Wheelchairs, without assistance to be carried, cannot use the stairs but others can who may use walkers, canes etc could use the steps / stairs.

If an accessible route is required per the IBC it must also function as the means of egress for the physically disable. In most cases that requires ramps, chair lifts or elevators to access different level changes and other methods covered in IBC Section 1007.

Let’s assume that there is another accessible route provided to different levels using ramps in the same room / area. However, there are hypothetical steps / stairs nearby that can also be used by all and these are the bases for the questions.

Will handrails be required at the steps / stairs when there is only one riser? As you said earlier, 1009.10 exception 3 of the 2006 IBC does not require a handrail.

Are open risers permitted? As long as the stair is not required to be part of an accessible route, which in this case, the minimum of one is already provided by the ramp, and an open riser would be permitted.

Or should directional signage be provided to indicate the accessible route in lieu of providing compliance handrails / closed risers at the nearby steps/ stairs? 1110.2.5, for directional signage, references 1007.7, and requires that the location of the accessible means of egresss be indicated at exits or elevators not providing an approved accessible means of egress. It does not state that, at the location of the stairs or ramps, which are non-accessible, that signage shall be provided. Using your example, I would encourage the signage, but I would not require it.

Think of liability possibilities.

I agree with JBI, when it comes to review and enforcement of accessiblity, I do not use the ADA, but rather the standards and guidelines adopted by my jurisdiction. I use the State Administrative Code (Title 156) & Chapters 10 (1007) & 11 of the 2006 IBC as my scoping mechanisms, while I use the more stringent of the two guidelines/standards (1991 Federal Register & ICC/ANSI A117.1-2003) to enforce accessbility compliance. Section 1104 sets the scoping for accessible routes, and sets additional exceptions to 1103.2 (General exceptions of applicability), and in general, requires at least one accessible route to connected spaces, employee work areas, press boxes, and multi-level buildings. Section 1105 examines the accessible route at entrances, and sets further exceptions and requirements of applicability. Beyond those scopes, I do not see anything in my jurisdictions adopted codes that would require a closed riser, a handrail, or directional signage.