# Is "Accessible Stair" an oxymoron?



## nealderidder (Dec 23, 2013)

I don't want to get too specific because this is a general question. But... this is NYC and I'm looking at a 9 story (high rise) R-2 building. NYC BC requires that we provide an accessible means of egress (1007). We are providing an elevator that meets the requirements for an accessible means of egress. I'm just pondering the stairs (in a vertical exit enclosure). No areas of rescue are required.

Specifically - am I required to meet ANSI A117 404 for the stairwell doors? NYC BC 1007.2 defines stairs as a part of an accessible means of egress by meeting 1007.3 and 1019.1. Neither of those sections reference ANSI A117. If you believe code requires my "accessible" stairway doors must meet ANSI A117 404, why?

A more philosophical question. If my stairwell doors must meet ANSI A117, what's the point? There won't be anyone in a wheelchair using these doors (after making their way down a 36" wide stairwell). We can provide the clearances it just seems pointless to be worrying about 18" on the pull side and 12" on the push side and the 48-60" clear floor space inside a stairwell 36" wide.

Thank you,

Neal


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## steveray (Dec 23, 2013)

I don't have any sections for you right now Neal...but my gut says yes you do have to meet the manuvering clearances....I believe the thought process is that the person using the chair can get themselves into the protected exit and then someone will assist them from there....

And the overall section would be......

1101.2 Design.

Buildings and facilities shall be designed and constructed to be accessible in accordance with this code and ICC A117.1.


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## fatboy (Dec 23, 2013)

Accessible does not always mean wheelchairs......walkers, canes, visual...........just sayin.......


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## nealderidder (Dec 23, 2013)

....I believe the thought process is that the person using the chair can get themselves into the protected exit and then someone will assist them from there....

Seems reasonable but then you've got someone in a wheelchair blocking the stair exit for everyone else. Not all people exiting would be able to assist someone in a wheelchair and open up the path of egress. The poor soul would likely get trampled.


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## nealderidder (Dec 23, 2013)

Agreed but I think those door clearances are for someone in wheelchair. Someone with a cane or visually impaired doesn't need all that space to approach the latch of a door do they?


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## steveray (Dec 23, 2013)

"about 18" on the pull side and 12" on the push side and the 48-60" clear floor space inside a stairwell 36" wide."

Should be just about enough room to get around a wheelchair......


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## JPohling (Dec 23, 2013)

walker needs the clearance and the visually impaired typically use the space to read the braille signage out of the way of the door swing.  the clearances are required.


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## nealderidder (Dec 23, 2013)

JPohling said:
			
		

> walker needs the clearance and the visually impaired typically use the space to read the braille signage out of the way of the door swing.  the clearances are required.


Yes, I'm being a smart ***** but I couldn't resist - So is the person with a walker expected to fall down the stairs and then get up and need maneuvering clearance to open the door at the bottom?


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## Builder Bob (Dec 24, 2013)

Try opening a door while on crutches, I believe you would enjoy the additional clearances that is being talked about.


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## ADAguy (Dec 24, 2013)

Members!

Ever heard of a board or stair strecther? Stairwells are required to be at a minimum 48" clear between handrails (how do you do 9 stories with only a 36" stair width?

Firemen are usually strong for a reason but may need more than 2 to lift and manuver a 400 pounder down the stairs.


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## steveray (Dec 26, 2013)

1007.3 Enclosed exit stairways.

An enclosed exit stairway, to be considered part of an accessible means of egress, shall have a clear width of 48 inches (1219 mm) minimum between handrails and shall either incorporate an area of refuge within an enlarged floor-level landing or shall be accessed from either an area of refuge complying with Section 1007.6 or a horizontal exit.

Exceptions:

1. Open exit stairways as permitted by Section 1019.1 are permitted to be considered part of an accessible means of egress.

2. The area of refuge is not required at open stairways that are permitted by Section 1019.1 in buildings or facilities that are equipped throughout with an automatic sprinkler system installed in accordance with Section 903.3.1.1.

3. The clear width of *******48 inches (1219 mm) between handrails and the area of refuge is not required at exit stairways in buildings or facilities equipped throughout with an automatic sprinkler system installed in accordance with Section 903.3.1.1 or 903.3.1.2.

4. The clear width of *******48 inches (1219 mm) between handrails is not required for enclosed exit stairways accessed from a horizontal exit.


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## BayPointArchitect (Dec 26, 2013)

While talking about a nine (9) story building, we are most certainly talking about all exceptions provided by an automatic sprinkler system.

According to Steve's list of exceptions for buildings that are srinkled, no area of refuge is required and the 48 inches between handrails is not required.

If I am that guy in a wheelchair, I would use the elevator first, find myself in the stairway landing as a second option, and say "sorry" to everyone who must step around my 30" x 42" wheel chair.  Within the next two hours (less than the fire-rated shaft enclosure), I will either arm crawl my way down 9 stories of stairs or a big strong fireman will drag me down the stairs.

San Diego -

If the blind can find themselves anywhere near the stairway door then I am certain that their fingers can find the bumpy braille sign regardless of the 12 inches clearance on the push side.

Builder Bob -

As for the guy in a walker or using crutches who is about to make his way down nine stories, I would have to agree that the 12 inches will allow him to get inside the stairway.  Good luck with the rest of his journey.

I have been pondering the same question about the 12" inch push and 18" inch pull for stairways ever since one of our local hospitals added a new addition.  The stairway doors are tight (4 inches +/-) to the adjacent walls.  No push or pull clearances.  One would think that a hospital has more walkers and wheelchairs than any other type of building.

The question remains unanswered in my opinion.


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## steveray (Dec 26, 2013)

In CT we are 24" on the pull side....FYI.....Commonly missed by out of staters.....

Bay Point.....New stairs?   Accessible MOE not required in existing building......


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## jar546 (Dec 26, 2013)

EMS crews use a "stair chair" that has wheels and sometimes a "reeves" carrier.  You need additional room to get 2 EMS worker and the patient through these doorways.  Much of these requirements have been thought out at a very detailed, involved level.  I find it silly to be so narrow minded in our thought process of "why?"


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## MASSDRIVER (Dec 26, 2013)

If your in a wheelchair and in front of me on a stair with the building on fire, you're in for the ride of a lifetime. I won't leave you, but you're goins to have a great crazy guy story. If i have to go up, I hope you took care of yourself for a piggyback ride. If your a 400 pounder The Lord is probably going to call you home.

Brent


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## DonaldsonR (Dec 27, 2013)

generally maybe wheelchairs, but when I was using crutches, I really enjoyed have the side clearances.


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## fatboy (Dec 27, 2013)

Welcome to the forum DonaldsonR!


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## nealderidder (Dec 30, 2013)

jar546 said:
			
		

> EMS crews use a "stair chair" that has wheels and sometimes a "reeves" carrier.  You need additional room to get 2 EMS worker and the patient through these doorways.  Much of these requirements have been thought out at a very detailed, involved level.  I find it silly to be so narrow minded in our thought process of "why?"


Asking why is being narrow minded? I don't see anything wrong with wanting to understand the reasoning behind the code requirements. I didn't like it when my mother told me "because I say so" and I still don't like it. She was probably right most of the time but I still wanted to know why.


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## jar546 (Dec 30, 2013)

nealderidder said:
			
		

> Asking why is being narrow minded? I don't see anything wrong with wanting to understand the reasoning behind the code requirements. I didn't like it when my mother told me "because I say so" and I still don't like it. She was probably right most of the time but I still wanted to know why.


It was this statement where you had already decided that it was unnecessary:



> A more philosophical question. If my stairwell doors must meet ANSI A117, *what's the point? There won't be anyone in a wheelchair using these doors* (after making their way down a 36" wide stairwell). We can provide the clearances *it just seems pointless* to be worrying about 18" on the pull side and 12" on the push side and the 48-60" clear floor space inside a stairwell 36" wide.


It is one thing to ask a question but another to say why right after you ask.  Like I always say.  "The more I learn, the more I realize just how much I don't know"


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## mark handler (Dec 30, 2013)

More than one kind of disabled....


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## nealderidder (Dec 30, 2013)

I was stating my position on the subject in the hopes that someone would tell me why that position was wrong. I was hoping to learn what I don't know. Sorry, I just don't get the point your trying to make with your scolding.


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## nealderidder (Dec 30, 2013)

nealderidder said:
			
		

> I was stating my position on the subject in the hopes that someone would tell me why that position was wrong. I was hoping to learn what I don't know. Sorry, I just don't get the point your trying to make with your scolding.


That was directed at Jar546. I guess I should "reply with quote"...


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## jar546 (Dec 30, 2013)

nealderidder said:
			
		

> That was directed at Jar546. I guess I should "reply with quote"...


No scolding, simply stating my position and opinion.

Just like you


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## nealderidder (Dec 30, 2013)

I've had a long holiday weekend (Happy Holidays to all!) to ponder this question and came up with a fresh perspective:

Door maneuvering clearances are not required for stairs that are a part of an Accessible Means of Egress (AMOE).

How did I make that leap? Well... A117.1 requires door maneuvering (404) clearances only for those doors that are a part of an Accessible Route. My position is that AMOE stairs are not a part of an Accessible Route.

Stick with me here. I'm saying that:

An *Accessible Route*

and

An *Accessible Means of Egress*

are not the same thing.

An Accessible route can be a part of an AMOE but an AMOE does not have to meet the requirements of an Accessible Route.

This particular example is per the NYC Building Code (NYC-BC), my 9 story R-2 that is allowed a 36" wide egress stair without areas of rescue assistance.

Here is my logic:

NYC-BC Chapter 10 requires an AMOE (or two) in 1007.1. Section 1007.2 describes the components of an AMOE as follows:

* Interior Accessible Routes

*Stairs in vertical enclosures per 1007.3 and 1019.1

*Elevators per 1007.4

*Lifts...

*Other...

Note that Accessible Route and Stairs are two separate things.

1007.3 Describes stairs that are part of an AMOE, no mention of maneuvering clearances or A117.1.

1008 Describes means of egress doors, no mention of maneuvering clearances or A117.1.

1019 Describes vertical exit enclosures, no mention of maneuvering clearances or A117.1.

NYC-BC 1102.1 Describes an Accessible Route as an unobstructed path complying with that chapter. In the entire chapter there are only two mentions of "stairs" and references to Chapter 5 of A117.1, one is for multi-story type B units and one for sunken floor areas.

A117.1 Chapter 4 Describes the components of an Accessible Route:

*Walking surfaces (1:20 or less)

*Doors & Doorways

*Ramps

*Elevators

*Lifts

Stairs are not listed. I feel like I've made a breakthrough in understanding this. It seems to make sense that Accessible Routes and AMOE are two very distinct things. Accessible Routes provide a path for wheelchair users (or other disabilities, I realize there are others) between accessible elements in a building. An AMOE has a very different purpose and since it can include a stairway it obviously isn't required to be an Accessible Route.

My conclusion is that an AMOE does not have to meet the requirements of an Accessible Route and since door maneuvering clearances are only required on Accessible Routes, AMOEs do not require door maneuvering clearances. Voila!

Who's with me?


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## steveray (Dec 30, 2013)

Not it!.....But I do appreciate the line of reasoning....I think because the below sections talk about "access from" and "enclosure"  the doors are assumed in a stair enclosure and manuvering therefore required...

1007.2 Continuity and components.

Each required accessible means of egress shall be continuous to a public way and shall consist of one or more of the following components:

1. Accessible routes complying with Section 1104.

2. Stairways within exit enclosures complying with Sections 1007.3 and 1019.1.

1007.3 Enclosed exit stairways.

An enclosed exit stairway, to be considered part of an accessible means of egress, shall have a clear width of 48 inches (1219 mm) minimum between handrails and shall either incorporate an area of refuge within an enlarged floor-level landing or shall be accessed from either an area of refuge complying with Section 1007.6 or a horizontal exit.


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## nealderidder (Dec 31, 2013)

steveray said:
			
		

> Not it!.....But I do appreciate the line of reasoning....I think because the below sections talk about "access from" and "enclosure"  the doors are assumed in a stair enclosure and manuvering therefore required...1007.2 Continuity and components.
> 
> Each required accessible means of egress shall be continuous to a public way and shall consist of one or more of the following components:
> 
> ...


Hmmm... I've read this several times and I'm not sure I get what you're saying. I agree that an enclosed stairway will of course have doors. You made a leap from "enclosure will have doors" to "doors must therefore meet maneuvering clearances" that I'm not following.

You would agree, I think, that not all doors must meet A117.1 maneuvering clearances, correct? So what doors must meet A117.1 clearances? I say only those doors on an *Accessible Route* (401.1-402.2 of A117.1). If we can agree on that the next question is, are stairs in an exit enclosure part of an Accessible Route - to that I say no!

My point here is that *AMOE* does not equal *Accessible Route*.


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## steveray (Dec 31, 2013)

I believe 1104.3 covers this best...if something is required to be accessible (MOE) then an AR is required.....

1103.1 Where required.

Buildings and structures, temporary or permanent, *****including their associated sites and facilities*****, shall be accessible to persons with physical disabilities.

1103.2 General exceptions.

Sites, buildings, facilities and elements shall be exempt from this chapter to the *******extent specified in this section.

1103.2.1 Specific requirements.

Accessibility is not required in buildings and facilities, or portions thereof, to the extent permitted by Sections 1104 through 1110.

1103.2.2 Existing buildings.

Existing buildings shall comply with Section 3409.

1103.2.3 Employee work areas.

Spaces and elements within employee work areas shall only be required to comply with Sections 907.9.1.2, 1007 and 1104.3.1 and shall be designed and constructed so that individuals with disabilities can approach, enter and exit the work area. Work areas, or portions of work areas, that are less than 150 square feet (14 m2) in area and elevated 7 inches (178 mm) or more above the ground or finish floor where the elevation is essential to the function of the space shall be exempt from all requirements.

1104.3 Connected spaces.

When a building, or portion of a building, is required to be accessible, an accessible route shall be provided to each portion of the building

1104.2 Within a site.

At least one accessible route shall connect accessible buildings, accessible facilities, accessible elements

1104.4 Multilevel buildings and facilities.

At least one accessible route shall connect each accessible level, including mezzanines, in multilevel buildings and facilities.


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## Codegeek (Dec 31, 2013)

nealderidder said:
			
		

> My point here is that *AMOE* does not equal *Accessible Route*.


On occasion, this is correct.  For example, if an elevator does not have standby power, it can only serve as part of the Accessible Route, not the AMOE.  In this example given, the elevator does provide both.  As far as the stairs, in reading through the 2009 IBC Commentary, an accessible route is to provide for someone to get to all accessible areas of a building.  Once someone gets into the space, they must also be able to evacuate in an emergency.  This may or may not be the same route.  My parents both have difficulty in maneuvering stairs.  One can go up them without problems and the other one can go down them without problems.  But neither can use the stairs in both directions without difficultly.  For one of them, the elevator would have to serve as the AMOE but the stairs could serve as their accessible route.  For the other, the elevator would have to serve as their accessible route and the stairs could serve as their AMOE.  If the stair is their accessible route (or anyone's accessible route), then it may also have to provide the same maneuvering clearances if used as an AMOE.


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## ADAguy (Jan 6, 2014)

Thanks for the images MH


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## Yikes (Jan 6, 2014)

I was once told that the reason for 12" clear strike side on the PUSH side of a door was for people who could stand/walk, but were too frail to both turn the handle and push against the force of a door closer.  The 12" gives them enough room to center their body on the handle, and simply lean into it, rather than using their arm leverage.  Is this is true, then (a) yes it helps make the stair accessible, and (b) I wish they would allow a panic bar alternative to the 12" clearance.


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## Dennis (Jan 6, 2014)

Are these accessible--- couldn't resist


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## mark handler (Jan 7, 2014)

Yikes said:
			
		

> I was once told that the reason for 12" clear strike side on the PUSH side of a door was for people who could stand/walk, but were too frail to both turn the handle and push against the force of a door closer.  The 12" gives them enough room to center their body on the handle, and simply lean into it, rather than using their arm leverage.  Is this is true, then (a) yes it helps make the stair accessible, and (b) I wish they would allow a panic bar alternative to the 12" clearance.


Anyone that may have a weak side.  Meaning someone that may need to use the "opposite" hand to open the door


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## mark handler (Jan 7, 2014)

Dennis said:
			
		

> Are these accessible--- couldn't resist


Does not meet chapter 10, no guards


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## JBI (Jan 7, 2014)

If you want to know 'why', take a look at the Commentary. It is not the Code, but does explain the 'why' in many cases.

We won't always agree with what is required/not permitted, and there is a means to address what we believe is a bad requirement/provision in the Code but until the Code is changed our job is to administer and enforce the Code as written, not as we'd prefer it to read.

That an individual doesn't understand 'why' does not negate the requirement.

I think several members have provided ample explanation as to 'why' the space is required.

Rather than being flip about it, try accepting the combined wisdom and experience of those who took the time to sharte their wealth of knowledge and experience with you?

JMHO


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## JBI (Jan 7, 2014)

_"An AMOE has a very different purpose and since it can include a stairway it obviously isn't required to be an Accessible Route"_

A leap of faith? Or simply flawed logic? An _'accessible means of egress'_ must necessarily be _'accessible'_ therefore the accessibility requirements must necessarily be met.


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## mtlogcabin (Jan 7, 2014)

nealderidder

I can follow your logic and could even reach the same conclusion but I would be wrong because of the intent and  the order in which the codes which various code sections have been adopted.

AMOE did not come into the codes till way after the door clearance requirements.

When the door clearance requirements came into the codes there where no exceptions to providing wheelchair spaces in a stairwell in a sprinkled building and it was a trade off for getting sprinklers in more buildings

 Look at the ADA which you are required to design to

*206.5 Doors, Doorways, and Gates.* Doors, doorways, and gates providing user passage shall be provided in accordance with 206.5.

*206.5.1 Entrances.*

 Each entrance to a building or facility required to comply with 206.4 shall have at least one door, doorway, or gate complying with 404.



*206.5.2 Rooms and Spaces. *

Within a building or facility, at least one door, doorway, or gate serving each room or space complying with these requirements shall comply with 404.



*404.2.4 Maneuvering Clearances.*

 Minimum maneuvering clearances at doors and gates shall comply with 404.2.4. Maneuvering clearances shall extend the full width of the doorway and the required latch side or hinge side clearance.


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## nealderidder (Jan 13, 2014)

JBI said:
			
		

> If you want to know 'why', take a look at the Commentary. It is not the Code, but does explain the 'why' in many cases. We won't always agree with what is required/not permitted, and there is a means to address what we believe is a bad requirement/provision in the Code but until the Code is changed our job is to administer and enforce the Code as written, not as we'd prefer it to read.
> 
> That an individual doesn't understand 'why' does not negate the requirement.
> 
> ...


Wasn't trying to be "flip", sorry if it came across that way. I'm humbly seeking the wise council of the most generous members of this board, that is all.


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## nealderidder (Jan 13, 2014)

JBI said:
			
		

> _"An AMOE has a very different purpose and since it can include a stairway it obviously isn't required to be an Accessible Route"_A leap of faith? Or simply flawed logic? An _'accessible means of egress'_ must necessarily be _'accessible'_ therefore the accessibility requirements must necessarily be met.


Don't see the flaw in the logic. I'm saying an AMOE is not the same as an Accessible *Route*. Pretty sure that is correct.


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