# Can an accessible route from to building entrance occur in the middle of a driveway?



## Yikes (Sep 8, 2015)

Could a building  / site comply with code and have its accessible path-of-travel to/from the public right of way go right up the middle of the driveway?  I have a client with a very narrow lot.  It's only wide enough for the parking and the drive aisle, with the building entrance towards the rear of the parking lot.

Assume for the moment that the driveway path would meet all other requirements for accessible slope, cross-slope, etc. down the middle of the driveway.  The only issue is that there is no dedicated, separate walkway for pedestrian entry.  The accessible path from the street is shared by cars, pedestrians, and wheelchair users.  (FWIW, the facility is a self-storage building, and pedestrian use is very rare.)

I understand that ADA CBC 11B-502.7 does not allow accessible parking stalls to have a path-of travel behind other parked cars.  We've created accessible stall(s) right next to the building entrance that fully comply, so that's not the issue.

The only question is whether wheelchair users can go to/from the street and the building entrance while sharing the drive aisle with cars.

Any code problems with this?


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## ICE (Sep 8, 2015)

Might be a ramp.  Up the middle of the driveway you say.  Odd place for handrails.


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## Frank (Sep 8, 2015)

That is typical here


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## jdfruit (Sep 9, 2015)

Yikes, here is the CBC section that could be an over riding requirement for PoT to public way (hope I have properly interpreted your OP)

11B-247.1.2.5 Hazardous vehicular areas. If a walk crosses or adjoins a vehicular way, and the walking surfaces are not separated by curbs, railings or other elements between the pedestrian areas and vehicular areas, the boundary between the areas shall be defined by a continuous detectable warning complying with Sections 11B-705.1.1 and 11B-705.1.2.5.


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## north star (Sep 9, 2015)

*& = &*



> " ...and the walking surfaces are not separated by curbs, railings or other elements"


Could those "other elements" be something as simple aspainted lines, similar to Crosswalks type of pavement marking ?

*& = &*


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## steveray (Sep 9, 2015)

I do not believe it is flat out prohibited....there is no max travel in a vehicular way that I am aware of, crossing street, parking lot, driveway, etc....


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## ADAguy (Sep 9, 2015)

NS, last I checked, paint is not "detectable" to a cane or non-cane user.


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## Yikes (Sep 9, 2015)

So, this would be code compliant:

I come out of the building main entrance/exit,

cross a detectable warning,

go down the middle of the driveway on a path that is painted / striped / indicated for the path in the driveway that complies with all slope, cross-slope, etc. requirements,

cross another detectable warning,

and end on the public sidewalk.

Complies for both going and coming to the building, correct?

ADA guy:  The code does not require me to tactile label the entire pathway from building to ROW.  It only requires me to provide a tactile warning strip when the path is leading into / out of vehicular areas.  I might have to put tactile warning across the entire building front entrance, like they do at our local Target store.  Is that correct?


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## JBI (Sep 10, 2015)

So the wheelchair user that probably crossed multiple intersections to arrive at the site will somehow be endangered wheeling up the driveway? I'm not seeing it.

Put the detectables at the top and bottom.


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## mark handler (Sep 10, 2015)

ADASAD 2010 Advisory 502.3 Access Aisle.*Accessible routes must connect parking spaces to accessible entrances. In parking facilities where the accessible route must cross vehicular traffic lanes, marked crossings enhance pedestrian safety, particularly for people using wheelchairs and other mobility aids. Where possible, it is preferable that the accessible route not pass behind parked vehicles.

CBC 11B-247.1.2.5 and CBC 11B-705.1.2.5

At any walk entering or adjoining vehicular ways without curb, railing, or barrier separation, Shall have a *continuous* detectable warning strip per item 22 with 36-inch (absolute) depth for entire length/width of transition.


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## mark handler (Sep 10, 2015)

*NOT the right thing to do, this designer does not have a clue*


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## JPohling (Sep 10, 2015)

looks like some kind of food offering for a snow plow


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## mark handler (Sep 10, 2015)

JPohling said:
			
		

> looks like some kind of food offering for a snow plow


In San Diego?


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## ADAguy (Sep 10, 2015)

MH, thank you but: no TD's on curb ramp (smiling)?

Would it be "Best Practice" or required to paint "No Parking" in striped area?


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## mark handler (Sep 10, 2015)

ADAguy said:
			
		

> MH, thank you but: no TD's on curb ramp (smiling)?Would it be "Best Practice" or required to paint "No Parking" in striped area?


I am not saying that is the way to do it BUT the first picture does comply with the code section for seperation, yes DW's are req. on the ramp.


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## Yikes (Sep 11, 2015)

Mark, thanks for supplying the photo.  However, I would disagree with their solution in the first photo for at least two reasons:

1.  The warning strip should have been continuous for the TRANSITION.  In this case, continuous only across the bottom of the curb ramp.

2.  They way they've done it would give a vision-impaired person a false sense of safety: "If I stay inside of the detectable bumps, must be out of the flow of traffic."  It appears to me that cars could still drive over the blue striped area on the inside / "safe" side of the detectable warning.

The second photo also gives this false impression.  It implies that once you've crossed the aisle (moving towards the camera), you are now out of traffic.  That does not appear to be the case, unless there are some bollards out of view to the right to block the cars.


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## ADAguy (Sep 11, 2015)

Yikes, onsite stripping for crosswalks is not required/regulated but is good risk-management practice.


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## MASSDRIVER (Sep 11, 2015)

mark handler said:
			
		

>


Does that come with a dental plan?

Brent.


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## Yikes (Sep 23, 2015)

UPDATE:  Here's the proposed code change for 2016:

http://www.documents.dgs.ca.gov/dsa/access/2016-Pt2_Draft-Changes-4th-Public-Hearing_06-23-2015.pdf

"11B-247.1.2.5 Walks at vehicular areas. If Where a walk crosses a

vehicular way or adjoins a vehicular way area, and the walk is not separated

from the vehicular way or vehicular area by curbs, railings or other elements, the boundary between the walk and vehicular way or the

walk and vehicular area shall be defined by a continuous detectable warning complying with

Sections 11B-705.1.1 and 11B-705.1.2.5 placed on the walk. Detectable warnings are not

required on the walk at opposite sides of a driveway apron."

REASON: DSA-AC is proposing an amendment to this section to clarify the terminology in the code as it

relates to the placement of detectable warning surfaces for walks at vehicular areas. As this section is

currently written, the term “hazardous vehicular area” is applied based on what the user determines to be

“hazardous”, and not based on a specific setting as defined in the code. As a result, incorrect placement

of detectable warning surfaces is common in many facilities, where incorrect placement of detectable

warning surfaces provides no benefit to a visually impaired user. This is evident in parking lots where

detectable warning surfaces are placed at the end of accessible parking access aisles, some of which are

adjacent to crosswalks and marked pedestrian ways, and all of which are components of a vehicular area.

Furthermore, detectable warning surfaces in accessible parking access aisles restricts use of the access

aisle for a user with mobility impairments, while providing no benefit to an individual with vision

impairments, who is escorted with assistance from accessible parking areas to the areas of the facility that

can be navigated independently. Amendment to this section will provide specificity for the placement of

detectable warning surfaces for walks at vehicular areas.


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## ADAguy (Sep 23, 2015)

Thank you for the heads up but what of sight impaired individuals who are unescorted or use canes?


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## amsfife (Apr 19, 2021)

I'm in a similar situation

Can you have the path of travel from building entrance to the right of way share space with a driveway, or be along side of the driveway, but not be separated by a curb?


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## ADAguy (Apr 26, 2021)

This a typical condition found and allowed in conversions of existing gas station service bays to minimarts who don't have direct connections to the public way. Same with rear stairs dumping into alleys.


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## Rick18071 (Apr 26, 2021)

Don't know CA codes but 2015 IBC has this:
Exception: Other than in buildings or facilities containing or serving type B units, an accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing for pedestrian access.

If it wasn't for the exception a lot of camps back in the woods would have problems.


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## ADAguy (Apr 28, 2021)

example of ICC not complying w/ ADASAD


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## redeyedfly (Apr 28, 2021)

ADAguy said:


> example of ICC not complying w/ ADASAD


206.2.1 Ex. 2


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## Pcinspector1 (Apr 28, 2021)

I've seen an ADA accessible route from the gas pumps with a blue painted hatched route on the driveway to the front doors of a convivence store. 

Is that okay?


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## ADAguy (Apr 29, 2021)

not required to be marked.


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## classicT (Apr 29, 2021)

ADAguy said:


> not required to be marked.


Typically...

However, some states do amend. For example, in WA...

*2018 IBC 1106.6 Location*
Accessible parking spaces shall be located on the shortest accessible route of travel from adjacent parking to an accessible building entrance. In parking facilities that do not serve a particular building, accessible parking spaces shall be located on the shortest route to an accessible pedestrian entrance to the parking facility. Where buildings have multiple accessible entrances with adjacent parking, accessible parking spaces shall be dispersed and located near the accessible entrances. *Wherever practical, the accessible route shall not cross lanes of vehicular traffic. Where crossing traffic lanes is necessary, the route shall be designated and marked as a crosswalk.*

*Exceptions:*​
In multilevel parking structures, van-accessible parking spaces are permitted on one level.
Accessible parking spaces shall be permitted to be located in different parking facilities if substantially equivalent or greater accessibility is provided in terms of distance from an accessible entrance or entrances, parking fee and user convenience.


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## mark handler (Apr 30, 2021)

Rick18071 said:


> Don't know CA codes but 2015 IBC has this:
> Exception: Other than in buildings or facilities containing or serving type B units, an accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing for pedestrian access.
> 
> If it wasn't for the exception a lot of camps back in the woods would have problems.


*2019 CA Building Code 11B-206.2.1 Site Arrival Points*
At least one accessible route shall be provided within the site from accessible parking spaces and accessible passenger drop-off and loading zones; public streets and sidewalks; and public transportation stops to the accessible building or facility entrance they serve. Where more than one route is provided, all routes must be accessible.
*Exceptions:*

Reserved.
*An accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing pedestrian access.*
General circulation paths shall be permitted when located in close proximity to an accessible route.

*But, If there is a way to provide that path of travel, even though it does not currently exist, I require them to add the POT.*


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## SH225 (Apr 30, 2021)

mark handler said:


> *2019 CA Building Code 11B-206.2.1 Site Arrival Points*
> At least one accessible route shall be provided within the site from accessible parking spaces and accessible passenger drop-off and loading zones; public streets and sidewalks; and public transportation stops to the accessible building or facility entrance they serve. Where more than one route is provided, all routes must be accessible.
> *Exceptions:*
> 
> ...


Can you describe an example of what you’ve required to be added? Has it involved additional paving and grading?


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## Rick18071 (Apr 30, 2021)

mark handler said:


> But, If there is a way to provide that path of travel, even though it does not currently exist, I require them to add the POT.


I can't see how you make them do that when it's clear that the exception says that it's not required. Your making up your own codes.


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## ADAguy (Apr 30, 2021)

Chapter 1 of the CBC and ICC allow AHJ's to exceed code minimums.


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## redeyedfly (Apr 30, 2021)

ADAguy said:


> Chapter 1 of the CBC and ICC allow AHJ's to exceed code minimums.


Where?


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## mark handler (May 1, 2021)

Rick18071 said:


> I can't see how you make them do that when it's clear that the exception says that it's not required. Your making up your own codes.


I'm not making up anything
If they *can make a path *and *choose not to*, it does not meet the intent or letter of the code.

It is no different from not making a building entry or restrooms accessible, because you claim it will effect the structure.

If it is not infeasible, you do it.
They need to show you, Or the AHJ, how it is not infeasible.


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## Rick18071 (May 4, 2021)

I don't agree. In PA the inspectors are not allow to decide if something accessible is not infeasible. We have a state board for that. If the plans only show a vehicular way not providing pedestrian access, then an accessible route shall not be required between site arrival points and the building, just like the exception says. This section does not say an accessible route is required if it is feasible.


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## mark handler (May 4, 2021)

Rick18071 said:


> I can't see how you make them do that when it's clear that the exception says that it's not required. Your making up your own codes.


If it is possible, it is required 

2010 ADASAD 106.5 Technically Infeasible. With respect to an alteration of a building or a facility, something that has little likelihood of being accomplished because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame; or because other existing physical or site constraints prohibit modification or addition of elements, spaces, or features that are in full and strict compliance with the minimum requirements.

 2010 ADASAD  §36.401 Any new construction must be accessible to  persons with disabilities, except when it  can demonstrate it is structurally  impracticable or technically infeasible to fully  comply with the requirements of ADA. 

2010 ADASAD 202.3 On a Retrofit (Repair or Maintenance), the  pedestrian access route shall be made  accessible to the maximum extent feasible  within the scope of the project.


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## mark handler (May 4, 2021)

If it is not required when feasible, everyone will design their projects, without access, and say  I don't need to, therefore, i won't. defeating the intent of ADA and barrier removal.
Where technical infeasibility is encountered, compliance is still required to the maximum extent technically feasible.
You may encounter issues in meeting slope requirements on existing developed sites located on steep terrain where necessary re-grading and other design solutions are not feasible. you may need a car to get to the buildings But it may be feasible to provide access between buildings, or other amenities.


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## mark handler (May 4, 2021)

SH225 said:


> Can you describe an example of what you’ve required to be added? Has it involved additional paving and grading?


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## Rick18071 (May 4, 2021)

This is very interesting. Even though the ADA is the same all through the states and most go by the IBC it's  enforced differently.

We don't enforce ADASAD in PA. We use IBC. The plan reviewer and inspector don't have any wiggle room at all in PA. Compliance to the accessibility codes has to be done to the letter. Any deviations to the code must be appealed through the state accessibility board.The state has auditors that comes out and checks our work. We can loose our cert to inspect if we screw up to much. I only got wrote up twice in 15 years where the plow took out the parking sign before the state auditor did their inspection 2 years after I did the final inspection and when someone moved a microwave to a higher shelf, even though I had a photo of it on the counter.

On the plans above they would only need to comply to an accessible route if they have a walkway to any of these areas otherwise *the only means of access between them is a vehicular way not providing pedestrian access .

One of the  worst accessible inspections I had was a hilly scout camp that had rough paths (walkways) through the woods to different facilities (on the same site), some miles apart. I defined the paths to be a pedestrian access. They had to go to the state appeals board to not require these paths to be accessible.

We have a lot of large developments with private roads with no sidewalks in my area. Most of them have community buildings, pools, etc. a mile or so from a public street. Since they are private streets, some are just gravel or dirt, I don't require an accessible route from the street to the facility even if they had a walkway there. If they did have sidewalks all the way to the public street then they would need to be accessible the whole way. What would you require?*


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## ADAguy (May 5, 2021)

Enforcement of ADASAD is not based on ICC if ICC items are less than ADASAD mins.
ICC is not a warranty of ADA compliance, only code. ADA is a "law", not a code.


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## Yikes (May 5, 2021)

ADAguy said:


> Enforcement of ADASAD is not based on ICC if ICC items are less than ADASAD mins.
> ICC is not a warranty of ADA compliance, only code. ADA is a "law", not a code.


ADAGuy, I believe that when Rick 18071 was saying "we don't enforce ADA", he meant "we, as building officials in PA, are legally allowed to plan check and enforce only the codes adopted by our jurisdiction, and ADA is not a code adopted by our jurisdiction".  
It is up to others besides the building official (e.g. DOJ and the courts) to enforce ADA in PA.


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## ADAguy (May 10, 2021)

Do you respond then to complaints after C of O if a project has not been built to the access requirements of your code?


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## Rick18071 (May 11, 2021)

Never had any except from the state accessibility auditors, mostly when the tenants change something after they get the C. O., like hanging a mirror to high over a lavatory or taking down the braille exit signs after a C. O. Then there is no way to respond. All other complaints are from contractors and owners about us enforcing the code before the C O


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## ADAguy (May 14, 2021)

Hmm, thank you


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