# Coolers & Freezers - California Building Code



## Codegeek (Jan 31, 2012)

According to the IBC, walk-in coolers and freezers intended for employee use only are not required to be accessible.  However, we’ve received a plan review comment back on a project that falls under the California Building Code that the door serving the cooler/freezer must comply with opening force requirements.  Due to the nature of the use of the space, for energy purposes, the doors are often more difficult to open which is why the IBC recognizes that these doors and spaces need not be accessible.

Can someone help me out on this?  So now we have to not only be energy efficient with coolers/freezers now they have to comply with accessibility too?


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## mark handler (Jan 31, 2012)

The back-of-house areas fall under the gray area of the CBC and ADAAG.

It can be defined as a workspace and if so defined, the owner must make Work areas accessible for "approach, entry, and exit," which means location on an accessible route so that people using wheelchairs can enter and back out of the space. Door opening force is required to enter the space.

Not turn around.

This is from CA-DSA

 Commercial kitchens used only by employees are generally considered to be work stations requiring compliance with CBC Section 1123B.2 (32” clear entry opening, aisles, and floors and levels). Pre-manufactured walk-in coolers and freezers used only by employees within a commercial kitchen (work station) are considered to be kitchen equipment not requiring compliance with accessibility provisions.


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## Papio Bldg Dept (Jan 31, 2012)

mark handler said:
			
		

> The back-of-house areas fall under the gray area of the CBC and ADAAG. It can be defined as a workspace and if so defined, the owner must make Work areas accessible for "approach, entry, and exit," which means location on an accessible route so that people using wheelchairs can enter and back out of the space. Door opening force is required to enter the space.


I have seen some coolers set up with tables for salad prep before...I guess I would define that as a work space.  Not sure how you would handle the threshold if it needs to be on an accessible route.


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## Codegeek (Jan 31, 2012)

Mark, that's what I thought that at least an accessible route was needed for employees.  Thank you for your help!


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## Codegeek (Feb 16, 2012)

Mark, I used your argument with a plans examiner on a set of review comments and they're still insisting that walk-in coolers and freezers for employee use only are not exempt from accessibility.

Any ideas on how to present the argument that they are not required to be accessible?


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## mark handler (Feb 16, 2012)

As I posted before the back-of-house areas fall under the gray area of the code and ADAAG.

If it is defined as a workspace, the owner must make Work areas accessible for "approach, entry, and exit," which means location on an accessible route so that people using wheelchairs can enter and back out of the space. Door opening force is required to enter the space.

There are no written exceptions.


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## Codegeek (Feb 16, 2012)

It's more for storage but is accessed only by employees.  Does that make any difference in your opinion?


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## Papio Bldg Dept (Feb 16, 2012)

Codegeek said:
			
		

> It's more for storage but is accessed only by employees.  Does that make any difference in your opinion?


If I were in your shoes, I would contact the access-board by phone concerning this gray area and ask to send a diagram/plan showing the situation and make sure to denote specific intended work areas (i.e., s.s. tables, etc.) versus specific intended storage areas (i.e., storage racks, shelving, etc.), for both inside and outside the cooler/freezer area.  Preferrably, send by email so you can document the conversation and share with the AHJ.


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## Alias (Feb 16, 2012)

Codegeek -

No, no difference.  Agree with Mark H.

Papio has a good approach also.  I do a lot of 'stickler' questions by email so that I have a written trail.


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## mark handler (Feb 16, 2012)

Contact the DOJ Disability Rights Section

For information and technical assistance about the Americans with Disabilities Act (ADA)

contact the ADA Information Line

800-514-0301 (voice)

800-514-0383 (TTY)

ADA Specialists are available to provide ADA information and answers to technical questions on Monday, Tuesday, Wednesday, and Friday from 10:30 a.m. until 4:30 p.m. or on Thursday from 12:30 p.m. until 4:30 p.m. (Eastern Time).


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## runbird (Feb 29, 2012)

Codegeek -  What was the resolution to the situation?  Did you contact the ADA specialists?  Justing wanting to know for future in case I run into that situation.


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## Codegeek (Feb 29, 2012)

I contacted the Access Board, who agreed with me, but that didn't fly with the jurisdiction.  I then contacted the Pacific ADA Center who told me to call the State Architect's Office who told me it was up to the local jurisdiction.  The local jurisdiction agrees they don't really need to be fully accessible but they feel that's what the code says, so they're enforcing the language of the code.


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## Papio Bldg Dept (Feb 29, 2012)

Codegeek said:
			
		

> I contacted the Access Board, who agreed with me, but that didn't fly with the jurisdiction.  I then contacted the Pacific ADA Center who told me to call the State Architect's Office who told me it was up to the local jurisdiction.  The local jurisdiction agrees they don't really need to be fully accessible but they feel that's what the code says, so they're enforcing the language of the code.


Wow.  AHJ unwilling to budge after Access Board and PADAC weighs in.  Has your client had the proverbial sit down with the Mayor/City Administrator yet?


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## Codegeek (Feb 29, 2012)

I've worked on too many projects in the last two weeks to remember specifics, but I think the project architect decided to pass the information along to our client's legal department to see if they wanted to pursue the matter further.


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