# 2018 IBC 1103.2.2 Employee Work Areas. Circular or 'T' space.



## Jamie Holmes (Dec 28, 2021)

I posted this the other day but I may have posted in the wrong category. 

When complying with "approach, enter and exit the work area" portion of the code, would every space with a single exit/exit access, no matter the room size (closet exception noted), be required to have a circular or 'T' space (304.3.1 & 304.3.2 ICC A117.1-2009) for persons in wheelchairs to turn around to exit? I suppose they could back out of this small laundry/janitorial room, but is that compliant with the intent of IBC 1103.2.2? The required door approaches/maneuvering clearances are in place in this design, though I'm arguing with myself as to the backwards direction of approach to the door. 

I deal with several state codes and recall reading somewhere that a turning space was required in every room or space required to be accessible. Now of course I can't find those words anywhere. Even if I could find them, the requirement for an employee work area is only to approach, enter and exit. Nothing else in the room or space is required to be accessible. Does anyone with solid ADA/accessibility knowledge recognize the rabbit hole I'm in, and have any guidance with code support to offer?


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## Rick18071 (Dec 28, 2021)

I don't think a turnaround space is required. It doesn't say "enter, turnaround and exit".


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## ADAguy (Jan 25, 2022)

If you can "enter" it you must be able to "exit" it, show them how you can and you may be ok.


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## steveray (Jan 26, 2022)

You might be able to argue for door maneuvering though....


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## Paul Sweet (Jan 26, 2022)

Backing out MIGHT be allowable if the door doesn't have a closer.  If it's possible to open a door behind you from a wheelchair it wouldn't be very easy.


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## Jamie Holmes (Jan 27, 2022)

ADAguy said:


> If you can "enter" it you must be able to "exit" it, show them how you can and you may be ok.


Thanks for your input. I spoke with the accessibility expert at ICC and the situation I am looking at is considered the difference between what is the minimum code requirement, and what is good design. This one meets the minimum code requirement. There are only a few rooms which require a turning space and this is not one of them. Unfortunately, I can't force them to be better designers.


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## mtlogcabin (Jan 27, 2022)

Jamie Holmes said:


> I can't force them to be better designers.


No but you can point out their ignorance on the subject and the difficulty their design has when put to practical use. Codes are a minimum and the worst design you can legally build


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## Jamie Holmes (Jan 27, 2022)

mtlogcabin said:


> No but you can point out their ignorance on the subject and the difficulty their design has when put to practical use. Codes are a minimum and the worst design you can legally build


Understood. And I do. In this case I am dealing with an architect who designs all of the buildings for a certain state university. A legend in their own mind, if you will.


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## Rick18071 (Jan 27, 2022)

The only place that I know of that turning space is required is in toilet and bathing rooms (ICC/ANSI A117.1 section 603.2.1), ramp landings where ramps change direction (405.7.4) and between 2 doors in a series (404.2.5).
Does anyone know of another place that a turning space is required?


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## mtlogcabin (Jan 27, 2022)

Sounds like that architect needs to walk a mile in someone else shoes. Perhaps he should spend a day in a wheelchair and experience how difficult things are to do from one.


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## ADAguy (Jan 27, 2022)

Spot on MT, they are not immune from DOJ sueing them for noncompliance. 
They are the type of "institutions" they enjoy making an example of.


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## Rick18071 (Jan 28, 2022)

ADAguy said:


> Spot on MT, they are not immune from DOJ sueing them for noncompliance.
> They are the type of "institutions" they enjoy making an example of.


What is the noncompliance?


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## Yikes (Feb 1, 2022)

I have discussed this with several CASPs regarding accessible closets, and their "interpretation" on that issue may help you with your turnaround question for other kinds of spaces.

24" or less depth of space to back wall of closet:  It can be reached without entering through the closet doorway.

24-48" depth to back wall of closet:  Must have min 32" clear opening width, but no turnaround required because at 48" or less deep "dead end", the back of the 30" x 48" wheelchair space is still "touching" the accessible route that led you to the closet, so the chair is technically still "on" an accessible route, and thus backing out ceases to be an issue of concern.

Greater than 48" depth to back wall of closet:  the wheelchair has now "entered" the closet, and it must function like a "room" requiring an accessible path of travel, including sufficient space to be able to exit the closet, which implies a turnaround space (T-turn, circle turn, etc.). 

Therefore, these CASPs tell me not to do closets between 48"-60" deep.  Go bigger, or go smaller.

Your mileage may vary, as this is just some experts trying to extrapolate meaning from the code to apply to other situations.  They may be overly conservative in their interpretation.


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## Rick18071 (Feb 1, 2022)

Rick18071 said:


> The only place that I know of that turning space is required is in toilet and bathing rooms (ICC/ANSI A117.1 section 603.2.1), ramp landings where ramps change direction (405.7.4) and between 2 doors in a series (404.2.5).
> Does anyone know of another place that a turning space is required?


I forgot about toilet rooms need turn around space.

If the closet is in the employee working space it would probably be less then 1,000 sq ft. and be exempt for needing an accessible route.

Why would a closet need a turn around space if the code does not require a turning space in a toilet compartment, in a dead end corridor?


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## Access Specialist (Feb 2, 2022)

ADAguy said:


> If you can "enter" it you must be able to "exit" it, show them how you can and you may be ok.


Correct. The IBC, ICC A117.1, nor the ADA do a good job of expanding on this but the Access Board has a great diagram indicating the intent. https://www.access-board.gov/ada/gu...#access-to-approach-enter-and-exit-work-areas


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## Paul Sweet (Feb 4, 2022)

Access Specialist, thanks for the link.


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