# Clean Room Accessibility



## nitramnaed (Sep 26, 2020)

I have a question if you are familiar with ADA exceptions on clean rooms.

According to the City, clean room would need to be reconstructed to meet ADA standards (e.g. to fit a wheelchair). We have used the California Unreasonable Hardship Exemption found in Accessibility for Existing Buildings 2016 CBC, Section 1134 B.2.1, Exception 1, 2017 Valuation Threshold; and it was rejected.

“Clean rooms” are where staff disinfects, gowns up from head to toe and enters the room to collect the finalized raw material that was crystalized during the lyophilzation process. The product is removed from the trays and placed in small bottles using a safety bench. The product is then removed and additional weighing and paperwork is performed.

The rooms are usually small and have very specific engineering controls. The purpose of gowning and the engineering controls is to ensure that API powders/solids released are minimized and/or eliminated. Further the gowning is meant to protect the worker from receiving small doses of these releases.


Are our arguments against ADA compliance are as follows:

Can’t ensure that the wheelchair is sanitized prior to entering the clean rooms.
Can’t ensure that the wheelchair would not be exposed to APIs, which means that the material could be brought into a person’s car or household.
Can’t gown up a wheel chair.
Expanding the room would change the engineering controls, which would be costly.
Expanding the room would increase the chance that the product would be spilled due to increasing travel distance.

Are there any applicable ADA exemptions that we may use?


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## e hilton (Sep 26, 2020)

I support your position.  However ... 
A special wheelchair could be provided by the company, kept in a dedicated gown-up room, and it could be sanitized between uses.  
A poncho-type gown could be used to cover the wheelchair and occupant.


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## RLGA (Sep 27, 2020)

What is it that makes the space not accessible? The space that you described would be considered an _employee work area _per the 2010 ADA Standards. Assuming the space did not have all these restrictions, could someone in a wheelchair approach, enter the space, and then exit? If so, then you met the criteria. 

Further, logic would dictate that because of the restrictions of use for that space, those with mobility impairments would not be well-suited for working in that environment. For comparison, a building that is on fire could be considered the firefighter's work area. Firefighters require special protective gear and equipment to work in that environment. Although a disabled firefighter could suit-up, approach, enter, and then exit a building that is on fire, no reasonable fire chief would allow that to happen, let alone, actually fight a fire. However, they could reassign the disabled firefighter to other duties, such as dispatch, inspection, etc. The same could be said for a disabled employee in your situation.


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## mark handler (Sep 28, 2020)

2010 Standards, section 203.9, require employee work areas in new construction and alterations to be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas.
IMHO, Changing rooms, like locker rooms, mentioned in the ADA,  would not be an "employee work area".

I have required them to be accessible.


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## ADAguy (Sep 28, 2020)

tough issue, ask DOJ for an opinion letter.


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## mark handler (Sep 28, 2020)

ADAguy said:


> tough issue, ask DOJ for an opinion letter.


THAT MAY STILL NOT COMPLY WITH STATE REQUIREMENTS


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## nitramnaed (Sep 28, 2020)

I think were we are at is the room is to small for accessibility and the work function would not be practical for someone in a wheel chair to perform.  So the AHJ is asking that all the rooms be expanded to accommodate a wheelchair even though a person in a wheelchair would not be able to perform this work.  My only thought is that the room is more like a piece of equipment then a work area.  I do a lot of restaurant work and I don't have to make the walk-in cooler accessible even though it might be quite large in square footage.


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## ADAguy (Sep 29, 2020)

Walkins are not limited to WC users, 32" clear door & hardware, minimum aisle space, alarm, etc.


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## nitramnaed (Sep 29, 2020)

ADAguy said:


> Walkins are not limited to WC users, 32" clear door & hardware, minimum aisle space, alarm, etc.


But no turnaround, latch or ramp.


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## ADAguy (Sep 30, 2020)

accessible hrdwr & threshold req-d


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## nitramnaed (Sep 30, 2020)

ADAguy said:


> accessible hrdwr & threshold req-d


Done hundreds of restaurants in all 50 states and Canada.  Never had to make a walk-in cooler or freezer accessible.


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