# 1109.13



## RJJ (Nov 18, 2009)

Would the alarm control panel for security need to meet the 48" reach range requirement under IBC 2006 1109.13?


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## D a v e W (Nov 18, 2009)

Re: 1109.13

I would say yes.  :mrgreen:

 :mrgreen: 1109.13 Controls, operating mechanisms and hardware. Controls, operating mechanisms and hardware intended for operation by the occupant, including switches that control lighting and ventilation and electrical convenience outlets, in accessible spaces, along accessible routes or as parts of accessible elements shall be accessible.

Exceptions:

1. Operable parts that are intended for use only by service or maintenance personnel shall not be required to be accessible.

2. Electrical or communication receptacles serving a dedicated use shall not be required to be accessible.

3. Where two or more outlets are provided in a kitchen above a length of counter top that is uninterrupted by a sink or appliance, one outlet shall not be required to be accessible.

4. Floor electrical receptacles shall not be required to be accessible.

5. HVACdiffusers shall not be required to be accessible.

6. Except for light switches, where redundant controls are provided for a single element, one control in each space shall not be required to be accessible.

7. Access doors or gates in barrier walls and fences protecting pools, spas and hot tubs shall be permitted to have operable parts of the release of latch on self-latching devices at 54 inches (1370 mm) maximumand 48 inches minimum above the finished floor or ground, provided the self-latching devices are not also self-locking devices, operated by means of a key, electronic opener, or integral combination lock.


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## Gene Boecker (Nov 18, 2009)

Re: 1109.13

The Fire Alarm Control Panel does not need to meet the reach ranges in the ANSI or ADAAG.  The FACP is not intended for use by the employees or users of the building.  Although it is generally located in a public space, it fits into the category of an equipment space per 1103.2.9.  Therefore, reach ranges are not required.  Mounting heights per NFPA 72 are the only requirements.

Likewise, if the alarm control panel for security is only access by employees, it fits into the category of an employee work space and is exempted per 1103.2.3.  If it is not for use by the general public or in a common space for use "in case of emergency" then it doe snot need to meet the reach range requirements.

But, if the panel is intended to be available for anyone to reach and activate in case on emergency, then all the items associated with operable parts must apply.   :ugeek:


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## RJJ (Nov 18, 2009)

Re: 1109.13

So it looks like it has to be in the reach range. But! But! But! Are most alarms / security systems installed for all to use?

How would one objectively review this issue. Or have grounds to insist on a strict compliance which to me is not clear.

A light switch ok, A pull station ok, alarm panel I ? not referencing the fire alarm panel!


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## Gene Boecker (Nov 18, 2009)

Re: 1109.13

I'd venture to say that most alarm/security panels are *NOT *for use by all - only trained personnel.


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## brudgers (Nov 18, 2009)

Re: 1109.13

In many businesses the last person out the door arms the alarm, and the first one in in the morning disarms it.

Needs to be accessible.

BTW, there's no accessiblity exception for employee only areas.

There is a limited exception for mechanical equipment spaces, but even that is a grey area when it comes to things like IT equipment.


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## Gene Boecker (Nov 18, 2009)

Re: 1109.13

brudgers, I wish you'd limit your conversation to things you know.

ADAAG exempts employee areas under 4.1.1(3).

IBC exempts employee areas under Section 1103.2.3       :x


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## brudgers (Nov 18, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> brudgers, I wish you'd limit your conversation to things you know.ADAAG exempts employee areas under 4.1.1(3).
> 
> IBC exempts employee areas under Section 1103.2.3       :x


You may wish to read the advisory material in the appendix to ADAAG regarding section 4.1.1(3) before you leap to the wrong conclusion.

It clarifies the nature of the exemption by elaborating on "i.e., with racks or shelves."   It indicates that the intent is similar to other movable or easily modifiable conditions such as office furniture.

There is nothing in 4.1.1(3) exempting controls from 4.27 and only controls exempted by 4.1 need not comply.

As for 1103.2.3, I love the part about "essential to the function of the space" as an exemption.  It replaces ADAAG's structural in feasibility with client preference.

_*Is it permissible to deviate from the requirements for elements such as lavatories, operating controls and faucets, urinals, bathtubs, and shower stalls in order to follow State or local building code standards for these fixtures?*__ Sometimes. Such deviations are permissible only if they provide access equal to or greater than that required by the ADA._

http://www.ada.gov/taman3up.html


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## brudgers (Nov 18, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> I'd venture to say that most alarm/security panels are *NOT *for use by all - only trained personnel.


The famous "trained personel" exemption to ADA.

Just out curiosity to you avoid training the disabled by mounting the controls too high, or do you just not hire them in the first place?


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## Gene Boecker (Nov 18, 2009)

Re: 1109.13

Actually, if you go back and read the ADA itself you'll find that the employee work areas are covered by Title I.  The ADAAG covers the common use areas where employees may be present such as break rooms and restrooms (even the copy room is exempted since it is work specific).  Since the ADAAG is Title III it does not address the individual work area.

Further, if you read the draft 2004 ADAAG it is intended to clarify the text to be almost exactly what the IBC says now.  It has nothing to do with structural anything.  That's an entirely different issue.

Title I will tell you that when a person with a disability is hired, the work area must be modified as necessary to accommodate the needs of that disability - and only that disability.  If the person has a hearing disability, then mobility modifications (including reach rages) are not necessary.

The bottom line is whether of not the alarm/security panel is intended as a common use item or not.  If it is intended to be accessed by the public or by the employees then it needs to meet reach range requirements (i.e. setting the alarm on your way out the door at night).  If the panel is only to be accessed by trained personnel (e.g. Brinks, the fire department, etc.) then it is not required to be within reach range.  The Access Board and DoJ have affirmed the fact the electrical panelboards in commercial establishments fit this category.  If the alarm/security panel is similarly used, it should be similarly treated.  The trick is in finding out how it is to be used.


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## Gene Boecker (Nov 18, 2009)

Re: 1109.13

brudgers, I'm sorry I missed your interim acidic remark about hiring.

For the sake of human sanity, I'll just ignore it as you are obviously upset and just spouting off.


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## rktect 1 (Nov 18, 2009)

Re: 1109.13



			
				brudgers said:
			
		

> Gene Boecker said:
> 
> 
> 
> > I'd venture to say that most alarm/security panels are *NOT *for use by all - only trained personnel.


The famous "trained personel" exemption to ADA.

Just out curiosity to you avoid training the disabled by mounting the controls too high, or do you just not hire them in the first place?

Who are we more worried about, the mobility impaired person who can not reach the panel or the children who could?


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## brudgers (Nov 18, 2009)

Re: 1109.13

The 2004 guidelines are not the law regarding title III (or any other part of the ADA).

One reason they are not in place is because they are not equivalent to what is required by Title III.

They are only relevant to the ABA.

Notice that you will not find them at ADA.gov but rather at Access-board.gov.

This page clarifies their applicability:

http://www.access-board.gov/ada-aba/guide.htm


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## Gene Boecker (Nov 18, 2009)

Re: 1109.13

Just for general knowledge:

The 2004 ADAAG (also called the ADA/ABA) is only adopted by certain parts of the federal government - the ABA being notably the part that makes the federal government responsible to itself finally.  The department of the Interior has adopted it as has the Department of Transportation.  The DoJ has not and it is the only branch of the government given authority to enforce the Title III provisions.  But, since the last Bush administration did not have it high on their priority list, they didn't start the adopting process until it was late in the second administration period (not a political slam - just a statement of timing).  The adoption process was underway in 2007/2008 but was halted since all "twilight rule-making" is suspended by all incoming presidents.

The reason why you only see it on the Access Board's web site is for that reason.  It is once again in the process at teh DoJ for adoption.  The time frame is not set and will likely happen toward the end of next year based upon our contacts with the DoJ.  My reason for noting the new document has to do with the fact that the text "clarifies" much of what was placed in the original 1992 document.  Since the last time the feds updated the thing was in 1994, its still has a lot of "dark zones" where the DoJ enforces rules that they have made based on internal decision making and case law.  These were taken into consideration when the 2004 ADAAG was drafted.  Hence the yet-unadopted document can be used for guidance but cannot be enforced.  THAT was my point.


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## brudgers (Nov 18, 2009)

Re: 1109.13

My understanding is that there is some concern that the 2004 draft fails to comply with the legislative intent, particularly in areas where accessibility requirements are reduced from current law.

Nothing in the 2004 draft should be deemed to elaborate on the current version, it is not only unadopted but wholly separate.

It's lower standards play no small part in its popularity.


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## Gene Boecker (Nov 19, 2009)

Re: 1109.13

True, the DoJ is re-reviewing the draft and massaging a few things here and there.  However, from what I've heard, most of the proposed changes are not in the ADAAG (technical) portion of the rule-making.  The changes are mostly in the enabling/ threshold provisions.  In the end, we shall see when it finally comes out - hopefully next year.

However, although the DoJ will give the "party line" (remember, they're a bunch of attorneys) that the new document isn't adopted and can't be used yet (except for those specialized projects where the government has adopted it), the Access Board is consistently re-affirming the fact that where there are void in the preset ADAAG or areas that are not clear, the new document can be used as a guideline to determine intent.

And now, I think we've exhausted this topic - sorry for the hi-jack.


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## brudgers (Nov 19, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> True, the DoJ is re-reviewing the draft and massaging a few things here and there.  However, from what I've heard, most of the proposed changes are not in the ADAAG (technical) portion of the rule-making.  The changes are mostly in the enabling/ threshold provisions.  In the end, we shall see when it finally comes out - hopefully next year.  However, although the DoJ will give the "party line" (remember, they're a bunch of attorneys) that the new document isn't adopted and can't be used yet (except for those specialized projects where the government has adopted it), the Access Board is consistently re-affirming the fact that where there are void in the preset ADAAG or areas that are not clear, the new document can be used as a guideline to determine intent.
> 
> And now, I think we've exhausted this topic - sorry for the hi-jack.


Of course, the nature of the employee area exemption in current law is pretty clear.

But to the extent that the 2004 draft serves the purpose of clarifying ADAAG it doesn't support your position:



> http://www.access-board.gov/ada-aba/final.cfm*Employee Work Area.*  All or any portion of a space used only by employees and used only for work.  Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.
> 
> *Work Area Equipment.*  Any machine, instrument, engine, motor, pump, conveyor, or other apparatus used to perform work.  As used in this document, this term shall apply only to equipment that is permanently installed or built-in in employee work areas.  Work area equipment does not include passenger elevators and other accessible means of vertical transportation.


And of course:



> http://www.access-board.gov/ada-aba/final.cfm*Advisory F205.1 General.*  Controls covered by F205.1 include, but are not limited to, light switches, circuit breakers, duplexes and other convenience receptacles, environmental and appliance controls, plumbing fixture controls, and security and intercom systems.


Your argument was much stronger before you made it.


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## Gene Boecker (Nov 19, 2009)

Re: 1109.13

blah-blah-blah

_Volo vomito_


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## brudgers (Nov 19, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> blah-blah-blah_Volo vomito_


Remember the important thing isn't that I'm right.


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## Gene Boecker (Nov 19, 2009)

Re: 1109.13



			
				brudgers said:
			
		

> Gene Boecker said:
> 
> 
> 
> > blah-blah-blah_Volo vomito_


Remember the important thing isn't that I'm right.

Remember the important thing is that I'm right.     :lol:


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## brudgers (Nov 19, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> The Fire Alarm Control Panel does not need to meet the reach ranges in the ANSI or ADAAG.  The FACP is not intended for use by the employees or users of the building.  Although it is generally located in a public space, it fits into the category of an equipment space per 1103.2.9.  Therefore, reach ranges are not required.  Mounting heights per NFPA 72 are the only requirements.


I guess it must have been in another thread.


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## brudgers (Nov 19, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> I'd venture to say that most alarm/security panels are *NOT *for use by all - only trained personnel.


Because it certainly wasn't in this one.


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## brudgers (Nov 19, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> Further, if you read the draft 2004 ADAAG it is intended to clarify the text to be almost exactly what the IBC says now.  It has nothing to do with structural anything.  That's an entirely different issue.


That much is obvious.


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## brudgers (Nov 19, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> The Access Board and DoJ have affirmed the fact the electrical panelboards in commercial establishments fit this category.  If the alarm/security panel is similarly used, it should be similarly treated.


Maybe it will happen someday.


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## brudgers (Nov 19, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> Remember the important thing is that I'm right.     :lol:


But today's not looking like a strong candidate.


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## RJJ (Nov 24, 2009)

Re: 1109.13

Pretty good debate! I am still alittle in the dark on this issue. "security alarm" I suppose to error on the side of caution would be to just require it to be in the reach range!


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## Gene Boecker (Nov 24, 2009)

Re: 1109.13

Like I said, waaaaaaaay back at the beginning, it depends on how the panel will be used.  If the employees will be using it to lock up at the end of the night (and unlock in the morning) it has to be within reach range.  If only the security team will access the panel because it is in the security office, then it's not required.  And, if you have no idea how it will be used, then yes, err on the side of caution and make it within reach range.


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## brudgers (Nov 24, 2009)

Re: 1109.13



			
				Gene Boecker said:
			
		

> If only the security team will access the panel because it is in the security office, then it's not required


when at least one other built-in accessible security panel is installed.


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