# Accessible Entrances and Restrooms in an Existing Building



## knelson (Apr 9, 2019)

I'm working on an existing building in California. It's three stories with a basement. We are going to be doing tenant improvements on all three floors. There isn't any change in occupancy. Since you are allowed to go up or down one story to an accessible restroom, can we just upgrade the restrooms on the first and third floor but leave the second floor restrooms as is? I understand that we'd have to provide signage to the nearest accessible toilet facility. 

The main entrance faces a parking garage and is fully accessible. There is an accessible pathway from the public sidewalk (and bus stops) to this entrance. There is a secondary entrance/exit that faces the street but is not accessible. The ramp down to the entrance is too steep. As I understand the code, we don't have to make it accessible since 11B-202.4 requires only a primary entrance to the building or facility. There isn't any requirement that the primary entrance to face the street. We just have to provide signage providing direction to the nearest accessible entrance. Is that correct?


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## steveray (Apr 10, 2019)

Sounds good, but the Cali guys will know better.....Don't forget that you need to spend at least the 20% towards accessible upgrades until you are 100% accessible....


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## ADAguy (Apr 10, 2019)

You are attempting to bypass "the spirit" of the ADA by using what is seen as a "minimum". 
Also, is door hardware throughout the building compliant?


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## MtnArch (Apr 10, 2019)

steveray said:


> Sounds good, but the Cali guys will know better.....Don't forget that you need to spend at least the 20% towards accessible upgrades until you are 100% accessible....


The 20% unreasonable hardship threshold as of January 2019 in California is $166,157.


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## JPohling (Apr 10, 2019)

Yes your TI construction costs will be far over the threshold so you are in it for 100% compliance.  Depending upon the jurisdiction you may be able to argue the one floor up or down issue.  How far is the travel distance to the accessible restrooms from the most remote spot.  The secondary non accessible entry should be allowed with no change in use as long as your primary entry is compliant.


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## mtlogcabin (Apr 10, 2019)

knelson said:


> can we just upgrade the restrooms on the first and third floor


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## mtlogcabin (Apr 10, 2019)

ADAguy said:


> You are attempting to bypass "the spirit" of the ADA by using what is seen as a "minimum".


 Designers can look at the "spirit" of a code but plans examiner and inspectors are limited to make sure the "minimum" be met.


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## steveray (Apr 10, 2019)

To ignore any of the bathrooms, you would have to meet one of the exceptions to have it non accessible as new  in 1109ish IBC...


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## mtlogcabin (Apr 10, 2019)

Relocate them to the upper and lower floors and add the fixtures to the remodeled restrooms.
Or if you do not need the second floor fixture count just remove them.


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