# Directional signage at truck loading docks



## Rick18071 (Apr 27, 2020)

2015 IBC 
1111.2 Directional signage. Directional signage indicating
the route to the nearest like accessible element shall be provided
at the following locations. These directional signs shall
include the International Symbol of Accessibility and sign
characters shall meet the visual character requirements in
accordance with ICC A117.1.
1. Inaccessible building entrances.

Inspecting a large 1.5 million sq ft warehouse. Only one accessible entrance, two accessible egress doors (one is exit only with accessible egress stairs) and 45 doors/stairs next to truck loading docks. Do every one of these 45 stairways to the doors next to the loading docks need a directional sign at the bottom of the stairway to the accessible entrances?


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## steveray (Apr 27, 2020)

I have allowed less than every when the signs are specific and clear...your call


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## classicT (Apr 27, 2020)

Nope... these doors are presumably not intended to serve as a public entry. They are intended for the use of the truck drivers and on-site persons performing loading/unloading. Call them what they are....service doors, not entrances.

The primary parking lot, the lot used by staff and for the public visiting the warehouse, should have an apparent accessible route to the building.


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## Rick18071 (Apr 28, 2020)

Ty J. said:


> Nope... these doors are presumably not intended to serve as a public entry. They are intended for the use of the truck drivers and on-site persons performing loading/unloading. Call them what they are....service doors, not entrances.



The code section above doesn't say anything about "public" entrances. Where do you get that? In section 1007.10 does it mean the directional signs for exits that are inaccessible only need to be at "public" exits too?

Also #2 in the same section says you need directional signs at  "Inaccessible public toilets and bathing facilities". Since they actually say "public" here I would think they would use it under #1 too if they mean only the inaccessible "public" entrance need to .have directional signs.

Thoughts?


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## steveray (Apr 28, 2020)

Ty...Even your fist "restricted" entrance needs to be accessible...

1105.1.3 Restricted entrances. Where restricted
entrances are provided to a building or facility, at least one
restricted entrance to the building or facility shall be
accessible.


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## classicT (Apr 28, 2020)

Rick18071 said:


> The code section above doesn't say anything about "public" entrances. Where do you get that? In section 1007.10 does it mean the directional signs for exits that are inaccessible only need to be at "public" exits too?
> 
> Also #2 in the same section says you need directional signs at  "Inaccessible public toilets and bathing facilities". Since they actually say "public" here I would think they would use it under #1 too if they mean only the inaccessible "public" entrance need to .have directional signs.
> 
> Thoughts?





steveray said:


> Ty...Even your fist "restricted" entrance needs to be accessible...
> 
> 1105.1.3 Restricted entrances. Where restricted
> entrances are provided to a building or facility, at least one
> ...


Guys...I get it. But use common sense here. These doors will be used by truck drivers and the crews loading them. They are not intended to serve as an entrance to the building, but as a service door.

I agree, what I have posted does not follow the code explicitly, but it applies common sense and a bit of reason. 

Besides that, if you put signs at each of the 45 stairs/doors, do you also need an accessible path to the entryway that provides accessible use? Good luck routing the accessible route through the loading dock area. You would end up with thousands of feet of striped crosswalks within a semi-truck loading area.


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## steveray (Apr 28, 2020)

The accessible route does not need to be striped the whole way....Luckily this will all go away with autonomous vehicles.....LOL


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## Rick18071 (Apr 29, 2020)

There's a lot of things that don't make sense to me in the code. Here in PA the state is very strict on accessibility and you can lose your certs if not inspecting to the letter of the accessibility code.


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## ICE (Apr 29, 2020)

Ty J. said:


> I agree, what I have posted does not follow the code explicitly, but it applies common sense and a bit of reason.



If people had common sense and a bigger if common sense were a part of the Code....Chapter 11 of the California Building Code wouldn't be 219 pages long.  There's a code for the arc of the water coming from a spout of a drinking fountain.

  Common sense you say?  Try the polar opposite.


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## steveray (Apr 29, 2020)

Hey....We all know how big of a deal water is out there.....


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## ICE (Apr 29, 2020)

Considering the current state, drinking fountains might as well be eliminated from the codes.  Coming to you soon: Covid-19 codes.  The occupant load is going to be way different.


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## ADAguy (Apr 29, 2020)

Ty J. said:


> Guys...I get it. But use common sense here. These doors will be used by truck drivers and the crews loading them. They are not intended to serve as an entrance to the building, but as a service door.
> 
> I agree, what I have posted does not follow the code explicitly, but it applies common sense and a bit of reason.
> 
> Besides that, if you put signs at each of the 45 stairs/doors, do you also need an accessible path to the entryway that provides accessible use? Good luck routing the accessible route through the loading dock area. You would end up with thousands of feet of striped crosswalks within a semi-truck loading area.



Careful. striped crosswalks are not required by code.

Brings up another interesting question, would accessible loading docks be required, as in 5% to accommodate disabled drivers (they do exist)


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## classicT (Apr 30, 2020)

ADAguy said:


> Careful. striped crosswalks are not required by code.
> 
> Brings up another interesting question, would accessible loading docks be required, as in 5% to accommodate disabled drivers (they do exist)


In Washington, we have an amendment that actually requires stripped crosswalks.

*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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## Rick18071 (Apr 30, 2020)

What section requires an accessible route from these inaccessible stairs/doors to an accessible entrance? 
I only see that the sign is required. IBC 111.2 only requires the sign to indicate the "*route*" (does't say an "accessible route") to the accessible entrance .

2015 IBC
1111.2 Directional signage. Directional signage indicating
the *route* to the nearest like accessible element shall be provided
at the following locations. These directional signs shall
include the International Symbol of Accessibility and sign
characters shall meet the visual character requirements in
accordance with ICC A117.1.
1. Inaccessible building entrances.

If I try to make any sense of the code it would drive me crazy. I just go by the letter of the code.


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## Enri Code (May 1, 2020)

Ty J. said:


> Guys...I get it. But use common sense here. These doors will be used by truck drivers and the crews loading them. They are not intended to serve as an entrance to the building, but as a service door.
> 
> I agree, what I have posted does not follow the code explicitly, but it applies common sense and a bit of reason.
> 
> Besides that, if you put signs at each of the 45 stairs/doors, do you also need an accessible path to the entryway that provides accessible use? Good luck routing the accessible route through the loading dock area. You would end up with thousands of feet of striped crosswalks within a semi-truck loading area.



I've done quite a bunch of these warehouses with several truck docks and you are correct. People who know or get a chance to observe how these things operate will understand real quickly what the doors are meant for and more importantly that mixing people and truck traffic is not a good idea. 

The 45 man doors next to the dock doors are not for use by the truckers. They are for the warehouse operators to be able to go outside and open the trailer doors - do a visual inspection if need be - before the truck backs all the way up to the docks. Just the way conventional docks work.

No issue with crossing truck routes as each door lines up with the side of the truck and the warehouse operator doesn't go far from the dock door for what he needs to do.

They could have invested in a vertical storing leveler and continuous dock system so the trailer doors could be opened from inside the building as most modern warehouses would do and they would have eliminated the need for those doors but they did what they did.

Depending on how the facility itself is operated, there are parts that would need to be accessible of course. There may be a shipping/receiving office or a trucker's lounge situated in the vicinity that one can safely get to. Other times, the truckers don't even need to get out or just deposit their trailers elsewhere and a yard jockey does the rest.


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## ADAguy (May 1, 2020)

Back in the day (before everything was palatized) we used to hand swamp many loads.


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## Rick18071 (May 11, 2020)

1104.2 Within a site. At least one accessible route shall connect
accessible buildings, accessible facilities, *accessible elements*
and accessible spaces that are on the same site.

What is an accessible element?

Is a sign required by Chapter 11 an *accessible element*?
If this is true then will an accessible route will be needed from the directional signage (indicating a route to the accessible entrance) to the accessible entrance?


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## Enri Code (May 12, 2020)

The doors and stairs beside the dock doors provide a way for dock operators to get to the dock levelers. These dock levelers I would think would fall under IBC 505.3 Equipment Platforms.


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## ADAguy (May 12, 2020)

Yes but once at the dock level signs directing you an exit would be required, no?


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## Rick18071 (May 12, 2020)

Enri Code said:


> The doors and stairs beside the dock doors provide a way for dock operators to get to the dock levelers. These dock levelers I would think would fall under IBC 505.3 Equipment Platforms.



1. Two of the stairway/doors at the docks indicate a "drivers" restroom by the doors. Would these two stairways/doors need to be accessible? Or would the directional signs to an accessible entrance be sufficient?

2. Would these doors be considered service entrances or part of the required 60% accessible entrances?

1105.1 Public entrances. In addition to accessible entrances
required by Sections 1105.1.1 through 1105.1.7, at least 60
percent of all public entrances shall be accessible.
Exceptions:
1. An accessible entrance is not required to areas not
required to be accessible.
2. Loading and service entrances that are not the only
entrance to a tenant space.

SERVICE ENTRANCE. An entrance intended primarily for
delivery of goods or services.


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## ADAguy (May 12, 2020)

RR's are required to be "accessible", including their doors!


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## Enri Code (May 13, 2020)

ADAguy said:


> Yes but once at the dock level signs directing you an exit would be required, no?



I see how they may need to put a directional sign on the interior to point towards where the egress doors are. So that's correct.
They may need to  put a "Not an Exit" sign at the interior side of the man doors by the dock doors.
Thinking about it some more, since it's a very big building to be sure and having dock doors usually spaced out at about 14 feet on center... about 630 feet at least (45' x14') ... that's a long way to go without having an egress door and stair at some interval between dock doors. At the very least, any required egress would need to straight shot away from the dock and connect to another pedestrian path. 
Not knowing how the building is configured, it would be a good idea to look at how they are achieving their code required exit distances.


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## Enri Code (May 13, 2020)

Rick18071 said:


> 1. Two of the stairway/doors at the docks indicate a "drivers" restroom by the doors. Would these two stairways/doors need to be accessible? Or would the directional signs to an accessible entrance be sufficient?
> 
> 2. Would these doors be considered service entrances or part of the required 60% accessible entrances?
> 
> ...



1. Those stairways/ doors would probably need to be accessible based on their function as restroom access. May even trigger area of refuge requirement for the stair landing. Of course, not knowing how the plan is configured, my guess is that those doors mean that a shipping office and restrooms may be located somewhere along the rows of dock doors so it would bolster the case for those particular doors to need to be accessible. May even need a ramp... yikes...

2. I believe those doors would be service entrances as you described.


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## Rick18071 (May 14, 2020)

Building is a rectangle 750' wide. code says S-2 with sprinklers max. travel distance is to be 400". Doors are about 50' apart along the long walls where the docks are. There are 4 accessible exits at the short ends of the building. Two dock doors go into a vestibule which has a single user restroom. There will be a door from the vestibule into the warehouse that will be locked on the vestibule side but not on the egress side. So the drivers can use the restroom but not enter the warehouse. But I think that these entrances are intended primarily for delivery of goods or services because only the drivers that are delivering goods will be using these doors.

i noticed that the code definition says primarily for delivery of goods or services not for shipping out goods and services. Do you think it makes a difference?


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## Rick18071 (May 14, 2020)

ADAguy said:


> RR's are required to be "accessible", including their doors!



The rest rooms are accessible and have an accessible route from the warehouse but not from grade where the trucks park. There is no accessible means of egress from these restrooms. The ware house was just built and this will be a tenant fit-out for it. Does that make the warehouse existing and no accessible egress is required?


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## Rick18071 (May 14, 2020)

What is your opinion?

See attachment. The lot 5 fit-out has three truckers restrooms with no accessible egress from the truck parking at grade because of a stairway. I think that these entrances are intended primarily for delivery of goods or services because only the drivers that are delivering goods will be using these doors. Service doors for loading docks are not required to be an accessible entrance. There will be a vestibule at these two exterior dock doors with a door into the rest room and a 3rd door into the ware house. They plan to have a one-way lock on this warehouse door so you can get to the exit door and these restrooms from the warehouse but the truckers can’t get into the warehouse.

I'm worrying about the accessible means of egress from these restrooms. The rest rooms are accessible and have an accessible route from the warehouse but not back into the warehouse or from grade where the trucks park. There is no accessible means of egress from these restrooms because the exit door has a stairway and the door will be locked into the ware house. The ware house was just built and this will be a tenant fit-out for it. Does that make the warehouse is existing and no accessible egress is required for the tenant fit-out?


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## Enri Code (May 14, 2020)

Rick18071 said:


> What is your opinion?
> 
> See attachment. The lot 5 fit-out has three truckers restrooms with no accessible egress from the truck parking at grade because of a stairway. I think that these entrances are intended primarily for delivery of goods or services because only the drivers that are delivering goods will be using these doors. Service doors for loading docks are not required to be an accessible entrance. There will be a vestibule at these two exterior dock doors with a door into the rest room and a 3rd door into the ware house. They plan to have a one-way lock on this warehouse door so you can get to the exit door and these restrooms from the warehouse but the truckers can’t get into the warehouse.
> 
> ...



Certain situations can make it impossible to provide an accessible means of egress from building exits to a public way. 

It's common to not allow the truckers access to the warehouse space so that's to be expected but it does create an issue.

 Looks like that's the situation you have.

I understand that you're looking into at 1009.1 Exception #1 which says that accessible means of egress are not required to be provided in existing buildings. I'm not certain about that as well given that the warehouse was "just built". Depending on how long it had been built before the modifications would be done, I'm not certain that it applies.

I'll probably look at another part of the code that may allow this situation. The IBC permits an exterior area for assisted rescue, a protected area immediately outside a building exit, where a connecting accessible route to a public way from the level of exit discharge is not practical.

Look at 1009.7 Exterior areas for assisted rescue.

This would call for modification of the stair landing to fit the area of assisted rescue and having the immediate wall around the door to be 1 hour fire resistance rated (1008.7.2).

It won't allow a smooth way for someone in a wheelchair to exit out of the "driver's entry" but it will be to code...


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## ADAguy (May 15, 2020)

Rick18071 said:


> The rest rooms are accessible and have an accessible route from the warehouse but not from grade where the trucks park. There is no accessible means of egress from these restrooms. The ware house was just built and this will be a tenant fit-out for it. Does that make the warehouse existing and no accessible egress is required?



It does not! Existing are bound by the barrier removal requirements of the ADA. T.I's are alterations and must comply with requirements for new construction. There are drivers with mobility limitations who need to pee too!


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## steveray (May 15, 2020)

If a CO was issued for the warehouse...yes, it is existing....But the door/ exit probably should have been accessible anyway....I can see how they could get around it though and why I do not CO a shell anymore....


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## Rick18071 (May 16, 2020)

ADAguy said:


> It does not! Existing are bound by the barrier removal requirements of the ADA. T.I's are alterations and must comply with requirements for new construction. There are drivers with mobility limitations who need to pee too!



I am code plan reviewer and I am reviewing these plans to the 2015 IBC. I'm not legally allowed to looking at more than that.



steveray said:


> If a CO was issued for the warehouse...yes, it is existing....But the door/ exit probably should have been accessible anyway....I can see how they could get around it though and why I do not CO a shell anymore....



Not sure how that can be done here legally. Here a CO must issued within 3 days after the final inspection passes and we must do the final inspection within 3 days when requested. Besides why would I care if they don't have an accessible egress for the tenant fit-out when the code does not require it (for existing buildings)? It's just one thing more that I don't need to deal with for a plan reviews and inspections.


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## ADAguy (May 18, 2020)

May be so but the landlord is still bound to be code (and ADA) compliant,


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## Rick18071 (May 18, 2020)

ADAguy said:


> May be so but the landlord is still bound to be code (and ADA) compliant,



I'm interested and would like to know what ADA says about accessible egress for existing buildings. I thought the IBC was close in what the ADA requires.


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## Enri Code (May 19, 2020)

Rick18071 said:


> I'm interested and would like to know what ADA says about accessible egress for existing buildings. I thought the IBC was close in what the ADA requires.



The IBC is close to ADA because it draws/ references from it but not in full though because ultimately, the ADA is an anti-discrimination law that not only deals with physical barriers but also other forms of discrimination.

I thought the above worth mentioning because I think that distinction is important because it sheds light on how they are similar but also different in the light of application. So a facility can definitely be code compliant but may not really meet the ADA requirements in full... and vice versa.

With regard to stairs being an egress path which would be the case here, they can still be ADA compliant in terms of handrails, guardrails and treads. ADA and IBC are aligned there.

I don't believe they necessarily need to be ramps or paired with ramps as long as an accessible entrance is already provided for elsewhere and signage is provided where applicable letting people know where the accessible entrance is. 

They may most likely still need to have that exterior area for assisted rescue at least. That would be code compliant. 

However, it won't be fully ADA compliant if you frame the situation in a way that in principle, by having the door back to the accessible path locked, you don't have a complete path without a change of elevation requiring a stair. If ADA is to be met fully, a ramp or a lift would be needed.

That's when it gets messy because in general, with regard to existing facilities... the ADA does dictate that architectural barriers be removed in existing facilities...* "when readily achievable".*

That phrase "when readily achievable" is definitely a can of worms best opened with a can opener... held by a lawyer. 

Who makes the determination of what is readily achievable? You? Them? Uncle Sam? Do you even need to worry about ADA if it already is demonstrably code compliant? Shouldn't ADA then be owner's or tenant's to deal with either now or if faced with a civil suit down the road?

Most likely, owner will bear the burden of proof with regard to if something is readily achievable if challenged in the legal sense.

I'm not sure what the scope of your code plan review is but you may just want to inform the owner of possible issues as a commentary that they need to address without actually prescribing a remedy if that's a liability concern for you.


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## ADAguy (May 19, 2020)

Rick18071 said:


> I'm interested and would like to know what ADA says about accessible egress for existing buildings. I thought the IBC was close in what the ADA requires.



cLOSE BUT NO CIGAR (SMILING) eXISTING barriers must be removed and maintained. You must be able to enter and exit to a public way or area of refuge.

Have you read the 2010 ADASAD? ICC uses the chapter numbers but is not always in step with its minimums. Yes, in some instances they excedd but not in all.


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