# Accessible entrances



## jar546 (Jan 21, 2010)

Uncertified A2 being converted to a B, office.  In PA, uncertified means there is no history of any inspections or C of O.  Bottom line, change of use and occupancy classification.

They will be doing major structural renovations including steel beams in the basement and a complete retrofit of the interior & exterior walls except for one office and one bathroom.  I would call it Level 3 easy but they did not declare the IEBC or renovation levels therefore in PA, Chapter 34 applies.

There is 1 ramp which equates to 1 accessible entrance that does not meet ansi 117.1 so it is being retrofitted.  This enters the building into a conference room.  They are taking an existing service entrance and adding a canopy and making a larger entrance into what will be the new lobby.  It was not planned on being accessible due to an elevation issue.

All in all there will be 4 entrance doors.  The main "public" entrance will be the new lobby that is not accessible is 1, 2nd is the accessible entrance that is being retrofitted to become accessible, 3&4 are side doors that will only be not be used except as exits when needed or for service.

It was my opinion that 60% of public entrances needed to be accessible therefore the 2 regular entrances would have to be accessible since if we only used the existing, then only 50% would be accessible and the enlarged main public entrance into the lobby would not be.  I was not counting the 2 other back doors.  The architect agreed and a redesign of the main entrance made it accessible so now we have 2 ramps and 2 accessible entrances, one of which is the enlarged (door moved too) main lobby entrance.

Now the owner is crying foul stating that she does not understand why she needs 2 ramps.  Unfortunately the elevation and design of the original building created this problem.

I am now looking at 3409.4(1) and rethinking my position.  Rethinking as of now.  My thought is that since she is taking an old service entrance, making it larger and making it the main entrance into the lobby then it has to be accessible.  3409.7 seems to agree that it must be accessible.


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## mtlogcabin (Jan 21, 2010)

Re: Accessible entrances

PRIMARY FUNCTION. A primary function is a major activity for which the facility is intended. Areas that contain a primary function include, but are not limited to, the customer service lobby of a bank, the dining area of a cafeteria, the meeting rooms in a conference center, as well as offices and other work areas in which the activities of the public accommodation or other private entity using the facility are carried out. Mechanical rooms, boiler rooms, supply storage rooms, employee lounges or locker rooms, janitorial closets, entrances, corridors and restrooms are not areas containing a primary function

I don't believe the work on the canopy entrance would require it to be accesible because of 3409.4(1).

However  there does need to be an accessible route to the lobby from the accessible entrance.



> They are taking an existing service entrance and adding a canopy and making a larger entrance into what will be the new lobby. It was not planned on being accessible due to an elevation issue.


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## jar546 (Jan 21, 2010)

Re: Accessible entrances

I am thinking Brudgers would agree that 3409.4(1) would apply.  I am not thinking for him, just presuming that he would think this way if he were to think about this at all.  Always want the DPs opinion.


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## Alias (Jan 22, 2010)

Re: Accessible entrances

As someone who deals with mostly retrofits of existing buildings, I would agree with mtlogcabin on the code section quoted.

Unfortunately I only have the CBC to quote.  Chapter 34 has a reference to Chapter 11 and, in Section 1105B, exception 1, it states "In existing buildings, when the enforcing agency determines that compliance with any regulation under this section would create an unreasonable hardship, an exception shall be granted when full equivalent facilitation is provided".  My interpretation of this would be that the conference room entrance would suffice the entry requirements as long as the interior was remodeled to meet ADA standards.

Clear as mud?

Sue, lost on the frontier


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## ewenme (Jan 22, 2010)

Re: Accessible entrances

Because we deal with great number of existing buildings, I argued for the adoption of the Int'l. Existing Building Code, and the City adopted it. It is more specific as to what level of alteration requires what level of current code that must be met. Also, there is a full chapter devoted to "Change of Occupancy" which has some guidelines as to level of risk, etc. I highly recommend the IEBC in addition to the IBC for just such occasions. The building owners and contractors also appreciate having some firm ground from which to approach the problems. :mrgreen:


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## TJacobs (Jan 22, 2010)

Re: Accessible entrances

3409.8 Scoping for alterations.

The provisions of Sections 3409.8.1 through 3409.8.12 shall apply to alterations to existing buildings and facilities.

3409.8.1 Entrances.

*Accessible entrances shall be provided in accordance with Section 1105.*

Exception: Where an alteration includes alterations to an entrance, and the building or facility has an accessible entrance, the altered entrance is not required to be accessible, unless required by Section 3409.7. Signs complying with Section 1110 shall be provided.

1105.1 Public entrances.

*In addition to accessible entrances required by Sections 1105.1.1 through 1105.1.6, 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.

3409.7 Alterations affecting an area containing a primary function.

*Where an alteration affects the accessibility to, or contains an area of primary function, the route to the primary function area shall be accessible.* The accessible route to the primary function area shall include toilet facilities or drinking fountains serving the area of primary function.

*Exceptions:*

*1.	The costs of providing the accessible route are not required to exceed 20 percent of the costs of the alterations affecting the area of primary function.*

2.	This provision does not apply to alterations limited solely to windows, hardware, operating controls, electrical outlets and signs.

3.	This provision does not apply to alterations limited solely to mechanical systems, electrical systems, installation or alteration of fire protection systems and abatement of hazardous materials.

4.	This provision does not apply to alterations undertaken for the primary purpose of increasing the accessibility of an existing building, facility or element.

Jeff, you were right the first time.  The code sections in bold are the reason you need 2 accessible entrances.  For sure, the main entrance should be the one to be made accessible.

In my opinion, the only exception you could cite would be the underlined.


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## mtlogcabin (Jan 22, 2010)

Re: Accessible entrances

TJ

 I pondered that section myself and the lobby does have to be on an accessible route because it is a primary function area but the entrance is excluded in the definition of primary function and 3409.7 is for Alterations affecting an area containing a primary function.


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## TJacobs (Jan 22, 2010)

Re: Accessible entrances



			
				mtlogcabin said:
			
		

> TJ I pondered that section myself and the lobby does have to be on an accessible route because it is a primary function area but the entrance is excluded in the definition of primary function and 3409.7 is for Alterations affecting an area containing a primary function.


OK, so the entrance is not a primary function, but you have to get into the building or you can't get to the primary function...


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## mtlogcabin (Jan 22, 2010)

Re: Accessible entrances



> but you have to get into the building or you can't get to the primary function





> There is 1 ramp which equates to 1 accessible entrance that does not meet ansi 117.1 so it is being retrofitted. This enters the building into a conference room


The retrofit on this entrance would be part of the maximum 20% figure


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## TJacobs (Jan 22, 2010)

Re: Accessible entrances



			
				mtlogcabin said:
			
		

> > but you have to get into the building or you can't get to the primary function





> There is 1 ramp which equates to 1 accessible entrance that does not meet ansi 117.1 so it is being retrofitted. This enters the building into a conference room


The retrofit on this entrance would be part of the maximum 20% figure[/quote:mdfj3qe9]

Is the conference room changing use?  When they are in a conference do they want to be interrupted?  Instead of retrofitting the ramp to nowhere make the main entrance a real entrance.


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## jar546 (Jan 22, 2010)

Re: Accessible entrances

All areas of the buildng are accessible once you get inside the building from either ramp.

I truly am torn on this one as I see it can go both ways.  If they would eliminate the existing ramp and turn the doors into windows and only have one "public" entrance then they would only need one ramp as the other two entrances are not public.


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## mtlogcabin (Jan 22, 2010)

Re: Accessible entrances



> When they are in a conference do they want to be interrupted? Instead of retrofitting the ramp to nowhere make the main entrance a real entrance


Agree that would be a better design but we are answering code questions not design issues.

In jar's OP he is also struggling with how many accessible entrances are required I believe only one is required by Chapter 34. Where that is placed in an existing building and how it functions with the day to day activities within the existing building is the designers responsibility.


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