# Doors required to be accessible, or not?



## ADAguy (Jul 3, 2019)

Question raised: Name any and all doors covered by ADA, CBC 11b or ICC 11 that are not required to be accessible other than those with exceptions.


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## classicT (Jul 3, 2019)

Considering that each of the code/legal provisions named deal explicitly with accessibility, the answer is none.

The premise of your question is asking what doesn't have to comply that is not included in the exceptions. Only the exceptions do not have to comply.

However, if you intend to state that all doors shall provide accessible use, then that is not accurate. Where not required to comply with ADA, CBC 11b or IBC Ch 11 (per the exceptions of each), a door would not be required to be accessible. See IBC Section 1103.2 for exceptions.

Example - Utility Buildings (1103.2.4), prison guard tower or other observation balcony (1103.2.6), highway tollbooths (1103.2.10), correctional facilities (1103.2.13), or walk-in-cooler/freezer (1103.2.14).


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## ADAguy (Jul 3, 2019)

We are on the same page but another poster doesn't appear to be.
Those exceptions are understood, the point made by another poster was that there were "others" not requiring compliance. The majority of doors if/when provided, found in T-II & T-III facilities "must" meet ADASAD minimums.


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## mtlogcabin (Jul 3, 2019)

Any door not on an accessible route does not need to be accessible


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## ADAguy (Jul 4, 2019)

Barrier removal required "all" existing doors to be accessible unless specifically exempted.


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## mtlogcabin (Jul 4, 2019)

The exemption would be the door is not on an accessible route
Example the door to access an unoccupied roof.


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## mark handler (Jul 5, 2019)

All New doors, on an accessible route, or not, Should be accessible.


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## ADAguy (Jul 5, 2019)

Thank you MH


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## mtlogcabin (Jul 5, 2019)

The question is "required" not "should be" accessible doors
As we all know there is more to an accessible door than just the width. There is the latch and locking mechanisms, the approach clearances, if there is a closure or not to mention a few. All those things are not required if it is not on an accessible route. If one of those is not in compliance then you do not have an accessible door.


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## ADAguy (Jul 5, 2019)

Are we on the same page mt? Do you have an issue with "each door" other then those specifically exempted but not on a accessible route meeting the requirements for an accessible door?


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## mtlogcabin (Jul 5, 2019)

ADAguy said:


> Do you have an issue with "each door" other then those specifically exempted but* not on a accessible route* meeting the requirements for an accessible door?


Yes depending on the location and function the door serves
Example: A warehouse with the required signed and code compliant accessible exits also has 3 non-exit exterior (no exit signage ) doors serving the loading dock for an F or S occupancy. Are the 3 non-exit doors now required to have the maneuvering clearances as outlined in ANSI TABLE 404.2.3.2
MANEUVERING CLEARANCES AT MANUAL SWINGING DOORS?

No 
The doors are a convenience for the operation of the facility and the truck drivers that use it. Should it meet the other requirements such as lever hardware? Yes 
The doors are not part of the means of egress system and therefore are not on an accessible route.


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## mark handler (Jul 5, 2019)

mtlogcabin said:


> The question is "required" not "should be" accessible doors
> As we all know there is more to an accessible door than just the width. There is the latch and locking mechanisms, the approach clearances, if there is a closure or not to mention a few. All those things are not required if it is not on an accessible route. If one of those is not in compliance then you do not have an accessible door.


I would look at it on a case by case basis
The code does have a minimum door width And there are exceptions
1010.1.1 Size of doors and Exceptions.

*Remember the width of the doors also affect emergency personnel not just those with physical impairments. When they come to get me from my heart attack I don't want the female paramedic to drag me through the door.... she can give CPR... but I want a stretcher….*


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## mtlogcabin (Jul 5, 2019)

To paraphrase Albert Einstein

An inspector should look for what is required, and not for what he thinks should be.


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## conarb (Jul 5, 2019)

mtlogcabin said:


> To paraphrase Albert Einstein
> 
> An inspector should look for what is required, and not for what he thinks should be.



True, and anyone wo tries to cram his personal political beliefs down the throats of the masses has no business in public employment.


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## ADAguy (Jul 5, 2019)

Legal jargon for deminimus mt, are "you" an AHJ or a AOR? an owner who wants it "cheap" or best practices?


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## Yikes (Jul 5, 2019)

mtlogcabin said:


> To paraphrase Albert Einstein
> 
> An inspector should look for what is required, and not for what he thinks should be.



Corollary:  when asked for a code opinion on a code forum, try to give a response that cites the specific code sections that support your position.


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## mtlogcabin (Jul 5, 2019)

An AHJ who acknowledges the code requirements are a minimum and "best practices" is a designers responsibility and not a code requirement. An AHJ has no legal authority to require "best practices" as part of the plan review or inspection process for a code that is written as the minimum requirements you have to legally follow. 

_A best practice is a method or technique that has been *generally accepted as superior* to any alternatives because it produces results that are superior to those achieved by other means or because it has become a standard way of doing things, e.g., a standard way of complying with legal or ethical requirements_


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## Yikes (Jul 5, 2019)

mark handler said:


> I would look at it on a case by case basis
> The code does have a minimum door width And there are exceptions
> 1010.1.1 Size of doors and Exceptions.


I note that the OP was not asking about Ch 10 "Means of Egress", and was instead asking about accessibility.

Here's a bunch of doors that don't need to be accessible: every door serving a closet or cabinet that is less than 24" deep.
That because it's not on an accessible route (route to go into the closet/cabinet).

CBC 11B / ADA is very straightforward:
1.  Use Division 2 to determine what spaces and components need to be accessible.
2.  Use ADAS/11B-206.2 to determine what routes need to be provided to get to those accessible spaces and components.
3.  Use  ADAS/11B-401.1 to determine that the doors that are in the routes that are required to be accessible by Div. 2 - themselves need to be accessible.  If the doorway is not part of an accessible route, the doorway does not need to be accessible.

Also, do not confuse an accessible doorway with accessible hardware:
An accessible door can be made accessible via its swing clearances and hardware - -  or via its automatic powered operation (which does not require the same clearances and hardware).

Conversely, a non-accessible door may require accessible hardware, such as D-pulls on a cabinet door.  It has nothing to do with the route.


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## ADAguy (Jul 8, 2019)

Does Montana code rely on ICC/ANSI or ADASAD? As you are an AHJ I better understand your comments but in CA doors (whether a closet or not) without accessible hardware are asking for trouble, whether on an accessible path/route, or not.


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## mtlogcabin (Jul 8, 2019)

ICC/ANSI only
Required on every Certificate of Occupancy

*24.301.902*    DISCLAIMER

(1) A building permit or certificate of occupancy issued by the state or a municipality or county must contain a statement that reads: "Compliance with the requirements of the state building code for physical accessibility to persons with disabilities does not necessarily guarantee compliance with the Americans with Disabilities Act of 1990, the Rehabilitation Act of 1973, the Fair Housing Amendments Act of 1988, Title 49, chapter 2, commonly known as the Montana Human Rights Act or other similar federal, state or local laws that mandate accessibility to commercial construction or multifamily housing."


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## ADAguy (Jul 8, 2019)

Yes but, does your code align with the minimum provisions of ADASAD 2010 or only ANSI 117.1?


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## mtlogcabin (Jul 8, 2019)

only ANSI 117.1?


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## conarb (Jul 8, 2019)

ADAguy said:


> Yes but, does your code align with the minimum provisions of ADASAD 2010 or only ANSI 117.1?


He just explained that to you in his last post, in fact the local code doesn't have to align with Federal Law or ANSI, in fact that's one of the things we fight the ICC on is that it's a reflexion of totalitarian Federal law instead of being an independent agency like the ICBO and/or SBC.;


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## Rick18071 (Jul 8, 2019)

Whenever ADA is listed under the designed codes on a plan I am reviewing I cross it off because it is not a code, I am not reviewing per ADA and I don't know or required to know the ADA.


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## conarb (Jul 8, 2019)

Rick18071 said:


> Whenever ADA is listed under the designed codes on a plan I am reviewing I cross it off because it is not a code, I am not reviewing per ADA and I don't know or required to know the ADA.


Good man, finally a man with guts.


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## classicT (Jul 8, 2019)

conarb said:


> Good man, finally a man with guts.


Conarb... his point is that the ADA is not a building code, ICC Standard A117.1 is.

Don't get yourself all wound up and excited. Many of us do the same as Rick; cross out ADA and write in A117.1.


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## ADAguy (Jul 8, 2019)

We all agree that ADA is not a code but it is the law of the land. If your state chooses to "ignore" the law by not addressing it in its code then owners may be subject to federal and/or state law suits in the future. It is up to their designers to address code items that do not comply with minimum ADA Standards which may exceed A117.1 or ICC Ch 11. 
Stop fighting it, it is not rocket science to comply,


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## mtlogcabin (Jul 8, 2019)

If the designers do their job then the owners will not be subject to a federal lawsuit regardless of what the state or local AHJ require.

There are many federal laws that cannot be enforced at the local level. ADA is just one of them.


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## ADAguy (Jul 8, 2019)

Woe to he who adheres to "code minimum" without considering all the "other" rules & regs too.


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## mtlogcabin (Jul 9, 2019)

When ADA first became law our county attorney instructed us that we could not require a builder to comply with it. However whatever the architect specs and drawings specified we are obligated to inspect to those drawings and specifications even if they went over and above the code minimum.
So again it is not my responsibility to require your design to adhere to all the various accessibility laws that are out there for a specific project. It is my job to make sure the project is constructed to your design.

Every new commercial project will have an architect stamped drawing that we will review under ANSI, not under Fair Housing and not under ADA and not under any federal monies restrictions like site visitability requirements.

Montana does not provide a way for attorneys and others to profit from non-compliant accessibility requirements like CA, and FL states do.  



ADAguy said:


> Woe to he who adheres to "code minimum" without considering all the "other" rules & regs too.


I assume you are referring to the designers since the AHJ can only review drawings under the rules they have adopted and not the "other" rules and regs that are out there.


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## e hilton (Jul 9, 2019)

mtlogcabin said:


> Montana does not provide a way for attorneys and others to profit from non-compliant accessibility requirements like CA, and FL states do. .



Really.  Thats interesting. How do they prevent it?


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## ADAguy (Jul 9, 2019)

CA's was an unintended consequence of a law that predated the ADA and our code. They write laws in CA and then they take years to develop the implimenting regulations with which to administer them. Yes, they opened the flood gates and the gold still flows through into the "pockets" of plaintiff's counsel.


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## mtlogcabin (Jul 9, 2019)

Simple it is a federal requirement so you file complaints with the feds under their rules which limit monetary damages for violations.


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## ADAguy (Jul 9, 2019)

And take forever for them to resolve given their limited resources.


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## e hilton (Jul 9, 2019)

mtlogcabin said:


> Simple it is a federal requirement



What about when a state has its own version?


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## mtlogcabin (Jul 9, 2019)

Then you have added another burden of regulations a designer has to follow in addition the the many others out there.


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## ADAguy (Jul 9, 2019)

Not always a bad thing, some times it is necessary to do so.


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## e hilton (Jul 10, 2019)

mtlogcabin said:


> Then you have added another burden of regulations a designer has to follow in addition the the many others out there.


No, what i meant was, can the very ethical lawyer file suit against the state regulations rather than federal, to get around the federal restrictions?   Or if a city has their own requirements.


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## mtlogcabin (Jul 10, 2019)

My understanding is you can file a civil lawsuit against anyone for any reason at any time so I guess the answer is yes. Will you prevail when you have not exercised all other legal options 1st such as filing a complaint with the DOJ. I am not an attorney and do not know the answer


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## mtlogcabin (Jul 10, 2019)

Remember ANSI is a building code standard and as such is under the AHJ to determine if compliance is met where as the ADA is civil rights and nobody can make exceptions to that except how a court rules.

And the state of Montana has this language
(23) The building official may waive minor building code violations that *do not constitute an imminent threat to property or to the health, safety, or welfare of any person.*

So under ANSI I could approve a WC that is 18.5 inches from the wall to the center line of the WC or a tub opening that is only 59.5 inches clear opening instead of the required 60 inch minimum width but under ADA this would not be permitted

So would someone prevail in a MT local/state court where the BO gave a certificate of occupancy when these "minor" violation posed no "imminent threat" to their safety or welfare? Who knows


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## ADAguy (Jul 10, 2019)

The "low hanging" fruit in Montana is not as attractive to the "suits" unless it is a large statewide chain or a government agency that a disabled person cannot access for services, or a courthouse.  Maybe then it would rise to a level where DOJ might choose to focus resources on it.


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## Rick18071 (Jul 10, 2019)

mtlogcabin said:


> Remember ANSI is a building code standard and as such is under the AHJ to determine if compliance is met where as the ADA is civil rights and nobody can make exceptions to that except how a court rules.
> 
> And the state of Montana has this language
> (23) The building official may waive minor building code violations that *do not constitute an imminent threat to property or to the health, safety, or welfare of any person.*
> ...



wel·fare
/ˈwelˌfer/
Learn to pronounce
_noun_

the health, happiness, and fortunes of a person or group.
"they don't give a damn about the welfare of their families"
synonyms: well-being, health, good health, happiness, comfort, security, safety, protection, prosperity, profit, good, success, fortune, good fortune, advantage, interest, prosperousness, successfulness
"local authorities have a duty to promote the welfare of children"
statutory procedure or social effort designed to promote the basic physical and material well-being of people in need.
"the protection of rights to education, housing, and welfare"

It's seems to me that any of the things you say you could approve would affect the welfare of some people especially if they are handicapped.


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## Yikes (Jul 10, 2019)

ADAguy said:


> We all agree that ADA is not a code but it is the law of the land. If your state chooses to "ignore" the law by not addressing it in its code then owners may be subject to federal and/or state law suits in the future. It is up to their designers to address code items that do not comply with minimum ADA Standards which may exceed A117.1 or ICC Ch 11.
> Stop fighting it, it is not rocket science to comply,



 ADAguy, who are you addressing when you say "stop fighting it"?  It is not within a local building official's jurisdiction to fight it, nor to comply with it.


ADAguy said:


> Yes but, does your code align with the minimum provisions of ADASAD 2010 or only ANSI 117.1?


The system is working exactly as it is supposed to when "It is up to their designers to address code items that do not comply with minimum ADA Standards which may exceed A117.1 or ICC Ch 11."

If the local code aligns with it, it is a convenience for the applicant, but not a necessity.
I would also add that if you give the illusion that your local code complies 100% with ADA, or that you are plan-checking 100% for ADA, you may be doing a disservice to your customer by lulling them into a false sense of security.
Better to give them the disclaimer as noted in other posts above.

Now, what were we saying about doors?


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## ADAguy (Jul 10, 2019)

That door hardware (for T-II & T-III, ) should be accessible, as in "no knobs, operable without special knowledge or effort" is that too difficult to do/understand?


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## mtlogcabin (Jul 10, 2019)

Really, do you honestly think 1/2 inch will make a difference if a WC or tub can be used or not? Or that it will hinder the enjoyment of health and the common blessings of life; prosperity; happiness; applied to persons.
I have no trouble explaining my decisions that do not line up exactly with the code requirements. However those same decisions when accused of violating an individuals civil rights will probably never stand up and that is the main reason I am a strong believer in it is not my responsibility or am I authorization under federal law to enforce ADA, FHA or OSHA  regulations. Am I responsible to inform owners contractors and designers of the other rules and regulations that may effect their project. 
Absolutely, 
http://www.montanafairhousing.org/newsletters_press/2003/nov03.pdf

*Webster 1824 dictioanary*
*Welfare*
*WELFARE*, _noun_ [well and fare, a good faring; G.]

*1.* Exemption from misfortune, sickness, calamity or evil; the enjoyment of health and the common blessings of life; prosperity; happiness; applied to persons.

*2.* Exemption from any unusual evil or calamity; the enjoyment of peace and prosperity, or the ordinary blessings of society and civil government; applied to states.


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## e hilton (Jul 10, 2019)

mtlogcabin said:


> Really, do you honestly think 1/2 inch will make a difference if a WC or tub can be used or not?



I work for a large organization.  We are going through all the facilities with a 93 page ada checklist, looking for any and everything.  Several facilities have the wc 18-1/2" off the side wall.  We are adding a layer of 5/8 gwb and reinstalling the grabbars to bring them into compliance.


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## mtlogcabin (Jul 10, 2019)

It is odd you mention you work for a large corporation using an ADA checklist.
We had an hotel that was built a few years ago and corporate sent their own people out and had to redo I think it was 6 ADA rooms because of a 59.5 inch clear opening for the tubs. I am sure they found a couple of other items also.
The tubs where located between a 2 hour shaft and the 1-hour partition wall. I do not remember the details of the fix but it was a nightmare to meet the ADA minimum requirement and maintain the fire ratings all because of a 2010 consent decree with the DOJ


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## Yikes (Jul 10, 2019)

ADAguy said:


> That door hardware (for T-II & T-III, ) should be accessible, as in "no knobs, operable without special knowledge or effort" is that too difficult to do/understand?


Your question of feasibility and comprehension appears to be a different than your original post, where the original question was:

"Name any and all doors covered by ADA, CBC 11b or ICC 11 that are not required to be accessible other than those with exceptions"
And the response and examples in posts #2,6,9,11,18 was basically:  There are many doors that area allowed in CBC/IBC that are not covered by ADA, CBC 11b or ICC 11, and those doors don't need to be accessible.
Listing all the types and conditions of doors not covered by ADA, CBC 11b or ICC 11 would be an endless task, because the list includes any door on a route that is not required to be accessible by ADA, CBC 11b or ICC 11.

As to your second question: I don't think a requirement for "operable without special knowledge or effort" exists in ADA T-II or T-III, CBC 11b or ICC 11.


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## ADAguy (Jul 10, 2019)

1010.1.9 Door Operation ... without special knowledge or effort
1010.1.9.5 Unlatching. one operation ( to release latch/lock)
1010.1.9.1 Hardware. without tight grasping, tight pinching, or twisting the wrist


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## classicT (Jul 10, 2019)

ADAguy said:


> 1010.1.9 Door Operation ... without special knowledge or effort
> 1010.1.9.5 Unlatching. one operation ( to release latch/lock)
> 1010.1.9.1 Hardware. without tight grasping, tight pinching, or twisting the wrist


I think this is where you are confusing folks ADAguy.

Your question relates to accessibility, but again you are referring to Ch. 10 requirement. Ch. 10 is solely means of egress and does not address accessible use.

Set a fire alarm off, add some smoke, and people are not much smarter than cattle in a stampede; hence how people get trampled. The requirements of Ch. 10 are actually more stringent than the accessibility requirements of Ch. 11.


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## mtlogcabin (Jul 10, 2019)

Similar language and intent as Chapter 10
ANSI
404.2.6 Door Hardware.
Handles, pulls, latches, locks, and other operable parts on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, pinching, or twisting of the wrist to operate. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the floor. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.

*ADA
404.2.7 Door and Gate Hardware. *Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.


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## Yikes (Jul 10, 2019)

ADAguy said:


> 1010.1.9 Door Operation ... without special knowledge or effort
> 1010.1.9.5 Unlatching. one operation ( to release latch/lock)
> 1010.1.9.1 Hardware. without tight grasping, tight pinching, or twisting the wrist





Ty J. said:


> I think this is where you are confusing folks ADAguy.
> Your question relates to accessibility, but again you are referring to Ch. 10 requirement. Ch. 10 is solely means of egress and does not address accessible use..



ADA, if your original post is about Chapter 11 and ADA, please don't bring chapter 10 into the conversation.
Why?  Because Ch. 10 concerns Means of Egress (getting out of the building), but Ch. 11 /ADA is about Access.

To put it another way, if the phrase "without special knowledge or effort" was really about getting _into_ a building, then no door could ever have an entry lock, because entry locks require special knowledge ("which key am I supposed to use?") and effort (the extra operations to pull out the key and unlock).

If I'm wrong please let me know, and I can look forward to the day when the nearby bank decides to remove its entry door and vault door locks in the name of ADA accessibility.


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## Paul Sweet (Jul 11, 2019)

I'm puzzled about these constant arguments about ADA vs. IBC.  The IBC incorporates all the ADA and Fair Housing Act construction requirements, and actually exceeds them in a few cases.  IBC includes churches and private clubs which are exempt from ADA because of the way the 1964 Civil Rights Act was written.  ANSI A117.1 requires vertical grab bars at toilets and now requires larger toilet stalls.  The only ADA requirements that aren't covered by IBC are operational issues which a building code can't address.

It might be prudent to say you are only reviewing or inspecting to IBC, but in reality you're also reviewing or inspecting to ADA unless you allow exceptions to ANSI A117.1 requirements or other provisions in the IBC that are covered by ADA.


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## conarb (Jul 11, 2019)

Paul:

I'm also puzzled as to how ANSI is even relevant, as I understand it ANSI writes it's standards that are either incorporated within codes or not, if they are incorporated their wording stands, if they are not they are completely irrelevant. Remember how Uncle Bob used to yell: "We have a stand-alone code?"  So what if ANSI requires larger toilet stalls?


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## Rick18071 (Jul 11, 2019)

I am required to enforce the icodes by the state not ADA. If the state made us enforce the ADA we would be checking all the existing buildings even when no construction is being done. I am not sure if the ADA makes a distinction between new construction and existing buildings. And I don't think the IEBC incorporates all the ADA or Fair Housing Act.


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## ADAguy (Jul 11, 2019)

Rick18071 said:


> I am required to enforce the icodes by the state not ADA. If the state made us enforce the ADA we would be checking all the existing buildings even when no construction is being done. I am not sure if the ADA makes a distinction between new construction and existing buildings. And I don't think the IEBC incorporates all the ADA or Fair Housing Act.



Yes Rick, ADA does address both new and existing and unlike the "code", requires retroactive barrier removal.
The disconnect is that the Feds require compliance but did not follow through on the connection between ADAAG/ADASAD and the code, given that the code is accepted or amended by each state separately.  That and making those with disabilities the policing arm and not building departments.


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## classicT (Jul 11, 2019)

conarb said:


> Paul:
> 
> I'm also puzzled as to how ANSI is even relevant, as I understand it ANSI writes it's standards that are either incorporated within codes or not, if they are incorporated their wording stands, if they are not they are completely irrelevant. Remember how Uncle Bob used to yell: "We have a stand-alone code?"  So what if ANSI requires larger toilet stalls?


The IBC provides the scoping of when and how to apply the A117.1 standard.

BTW, ICC A117.1-2009 is not an ANSI Standard anymore. ICC owns it outright


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## conarb (Jul 11, 2019)

Ty J. said:


> BTW, ICC A117.1-2009 is not an ANSI Standard anymore. ICC owns it outright



Thanks for that Ty, I need to think about it, as corrupt as the ICC is my initial reaction is that they shouldn't be allowed to buy the standards.


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## Paul Sweet (Jul 12, 2019)

I should have been clearer.  I was referring to 2010 ADA Standards for Accessible Design (ADASAD), which is a small part of the overall ADA.  The U.S. Access Board worked closely with ANSI to develop these standards, which is why they are almost identical.

As Ty said, IBC 1102.1 requires buildings and facilities to be designed and constructed to be accessible in accordance with this code and ICC A117.1.  IBC chapter 11 tells what has to be accessible, and A117.1 tells how to make it accessible.

California and some other states modify this to refer to their own access code, which is probably still based on ADASAD and A117.1.

The IBC incorporates many other many NFPA, ANSI, and other standards.  Chapter 16 references ASCE 7 for almost all structural design issues.


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## ADAguy (Jul 15, 2019)

CBC uses the numbering system of ADASAD (with additions) but not ANSI until it meets or exceeds ADASAD, which it doesn't in certain areas.


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## Yikes (Jul 15, 2019)

But to be very clear, Rick18071 and other building officials do not - and should not - check for ADA.  
They only check for the code adopted by their jurisdiction.  If the code they are required to enforce happens to have been edited to match ADASAD, that is of great benefit and convenience for all involved, especially the building owners.  But the local code is not ADA.

The building official becomes involved when an application is submitted for plan check / building permit, not before then.
So if there is an legally existing building that is out of compliance with ADASAD, the building official has no involvement unless and until the owner applies for some change (addition/alteration) to the building.


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## ADAguy (Jul 15, 2019)

Yes, (unfortunately) that is true. It would be best if each counter had a disclaimer so indicating that as a service to customers.
Maybe even requiring it on drawings (which you can do per Chapter 1 Of the code).


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## Sifu (Jul 8, 2022)

I googled "do all doors have to be accessible" and this thread popped up. (I use google search and it often turns up threads in the awesome forum).  My question was basically the same as the OP from long ago...*not* *ADA vs. ANSI*.  I think I am on the right track and in agreement with the over-all theme here, but for clarification I will use an example from one of my current reviews.

I have a tenant finish in an existing core-shell.  It is a typical two story office/warehouse space (a little too big to be a mezzanine).  The upper floor is < 3,000sf² so IBC 1104.4 #1 does not require an accessible route to the story.  Code does not exempt all accessibility on the story, just the route to it.  So does the accessible route start again?  I think it does, since the intent is that *IF* an accessible route to the story is ever provided, the elements on the story would be accessible.  So if the route to an open office area is provided, it must be accessible.  But what if there are two routes?  IBC 1104.3 requires "at least one accessible route" to each portion of the building.  Of the two routes they provide, one of them has a door that does not have maneuvering clearances, and ANSI 117.1 requires that "Doors and doorways that are part of an accessible route" shall comply.  So I don't think both routes are required to be accessible, therefore the door is not required to have the maneuvering clearance, or any other portion of ANSI section 404.  Any flaws in that logic?


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## Rick18071 (Jul 8, 2022)

I only know what the IBC requires. Only one required as long it is a common use circulation path unless more than one means of egress are required.


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## ADAguy (Jul 8, 2022)

Will that stand up in court if your code is not certified and less than ADASAD minimums?


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## Rick18071 (Jul 12, 2022)

What do you mean that our code must be certified? By who? All I need to know is what my state requires. I am not responsible to enforce ADASAD and don't know it.


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## ADAguy (Jul 13, 2022)

mtlogcabin said:


> Remember ANSI is a building code standard and as such is under the AHJ to determine if compliance is met where as the ADA is civil rights and nobody can make exceptions to that except how a court rules.
> 
> And the state of Montana has this language
> (23) The building official may waive minor building code violations that *do not constitute an imminent threat to property or to the health, safety, or welfare of any person.*
> ...


Construction tolerances, si! Discrimination alledged, no! 
its a civil right not to be discriminated against but what constituted discrimination? 
Only courts can decide.


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## ADAguy (Jul 13, 2022)

Rick18071 said:


> What do you mean that our code must be certified? By who? All I need to know is what my state requires. I am not responsible to enforce ADASAD and don't know it.


DOJ was expected, per the ADA, if submitted to them, to certify compliance of each states codes, they lacked the manpower and budget to do do


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