# ADAAG elevator exception 4.1.3



## Simonsays (Mar 2, 2010)

My question concerns the current ADAAG elevator exception 4.1.3 (when a level is less than 3,000 square feet) versus common uses required to be on an accessible route.

Which one trumps the other? I am surrounded by people who cannot agree. I understand that even without an elevator, all of the other accessibility requirements still apply. But does that include the accessible route? Is a stairway to a level of less than 3,000 square feet, containing common use spaces (say toilet rooms or a break room) acceptable?

Furthermore, is an office or an open office area on a 2,990 square foot mezzanine of a mercantile facility considered as common use? (The mezzanine is not primarily used for security or observation.)

I have not found a commentary, example, or detailed explanation on this topic. If you know of one, please point it out, whether a book or an article.


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## RJJ (Mar 2, 2010)

Re: ADAAG elevator exception 4.1.3

What Building code are you using?


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## mtlogcabin (Mar 2, 2010)

Re: ADAAG elevator exception 4.1.3



> Is a stairway to a level of less than 3,000 square feet, containing common use spaces (say toilet rooms or a break room) acceptable?


Those facilties would have to be available on an accessible route (main floor) there are ADAAG court rulings on major retail chains where they lost because the employee break rooms and lockers where not on an accessible route.


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## Alias (Mar 2, 2010)

Re: ADAAG elevator exception 4.1.3



			
				mtlogcabin said:
			
		

> > Is a stairway to a level of less than 3,000 square feet, containing common use spaces (say toilet rooms or a break room) acceptable?


Those facilties would have to be available on an accessible route (main floor) there are ADAAG court rulings on major retail chains where they lost because the employee break rooms and lockers where not on an accessible route.

Agree with mtlogcabin on location of WC and break rooms.

Had a complete remodel of a two story, 1950's era former furniture store, to an office for the local title company.  New owner wanted the break room on the second floor and brought in plans with same.  I informed her she had to:

1) repair existing freight elevator, or

2) provide a lift to second floor for disability access per ADA, or

3) move break room, common areas, etc. to main level

She opted for option #3 and is using second floor for records storage.

Sue, lost on the frontier in CA


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## Gene Boecker (Mar 2, 2010)

Re: ADAAG elevator exception 4.1.3

Questions to ask before you can get a good answer:

1. which code(s) are being applied?

2. what occupancies are on each level?

3. which level is less than 3000 SF (i.e. 1st, 2nd, etc.)?

4. how many stories?

5. new or existing?

5. academic question or real life?


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## Alias (Mar 2, 2010)

Re: ADAAG elevator exception 4.1.3



			
				Simonsays said:
			
		

> Furthermore, is an office or an open office area on a 2,990 square foot mezzanine of a mercantile facility considered as common use? (The mezzanine is not primarily used for security or observation.)


2007 CBC, Section 1105B, *Accessibility for Group B Occupancies *-

1105B.3 - Office buildings and personal and public service facilities.  Office buildings and personal and public service facilities shall conform to the provisions of this section.

1105B.3.1 *Facilities covered *-  Facilities covered in this section are those that are used by the public as customers, clients, visitors or which are _potentially places of employment _and shall include, but not limited to, the following requirements:

2. All types of sales establishments............pet shops.

Sue


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## Simonsays (Mar 3, 2010)

Re: ADAAG elevator exception 4.1.3

Using the 2006 IBC.

Mercantile on both levels - it is a grocery store, with offices on the mezzanine level.

The mezzanine is way under 3,000 sq. feet.

The building is an unlimited area one story (with a mezzanine).

New construction

Somewhere between academic and real life.


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## Simonsays (Mar 3, 2010)

Re: ADAAG elevator exception 4.1.3

Also review exception 1 under 2006 IBC Section 1104.4 "An accessible route is NOT required..."

Also, there is a code interp in the 2006 IBC code interp book.


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## Gene Boecker (Mar 3, 2010)

Re: ADAAG elevator exception 4.1.3

The 3000 SF exception does not apply to shopping centers or malls.  However, since the upper level is offices and NOT retail, access to the mezzanine is not required according to both the ADAAG and IBC (as mentioned above).  However, all the office spaces on the mezzanine level need to be provided with details for accessibility, including the toilet rooms, break room and general circulation routes as well as tactile signage, etc.

Additionally, because neither an elevator nor a ramp connect these two levels, the 12 inch horizontal extension at the bottom of the stairs (to the mezzanine) are required according to ADAAG 4.1.3(4) and 4.9.4(2).  Also, the allowed 4-1/2 inch sidewall projection is not permitted - a maximum 4 inch projection is allowed and the gap between the handrail and the wall must be exactly 1-1/2 inches,  Stairways are not required to meet these provisions if the levels are connected by ramp or elevator.  So pay attention to the details of stairway design if the decision is to provide no elevator.

On final thought, a LULA could be provided instead of a full elevator since the use is limited.  The cost is less than a full elevator and is acceptable according to the current IBC and future ADAAG.  But, if this is Ohio, then a variance is necessary to get the ability to use the LULA since it's not in the current ADAAG.

(Choices, choices. . . )


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## Plans Approver (Mar 3, 2010)

Re: ADAAG elevator exception 4.1.3



> But, if this is Ohio, then a variance is necessary to get the ability to use the LULA since it's not in the current ADAAG.


Not anymore, LULA's are considered elevators according to the BBS and were added to ASME 17.1. LULA's have to meet ADAAG requirements for elevators (at least in Ohio).

Gene ... When did you leave the Columbus BOCA office? The notice came out 12/96, I don't think there was any change. http://www.com.ohio.gov/dico/docs/326.pdf


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## Gene Boecker (Mar 3, 2010)

Re: ADAAG elevator exception 4.1.3

Dan, I left Columbus for St Louis in May, 1995.

Funny that you say that; but, when I was in front of the OBBA just last year I was specifically told that if it wasn't an elevator then we'd need to come back for a variance.  It would be approved but the process needed to be followed.  I guess you guys are a bit more progressive.


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