# IBC Accessibiility to a Church Platform



## Lynn

Doing a plans review on a new church sanctuary.

We have adopted the 2006 IBC and as such, Chapter 11 of the IBC and the referenced ANSI A117.1 standards.

Is anyone aware of any exception in the IBC, Chapter 11 or the A117.1 standard, for access to the raised platform area that serves the pulpit and choir?

Also, what accomodations would be necessary to provide accessibility to a baptismal pool behind the pulpit that is raised 4' or so above the pulpit platform?

I don't find any exceptions and have been calling for a ramp or lift for accessibility to these areas.

Looking for any exceptions that I may have missed.

Thanks


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## mtlogcabin

The pulpit area might fall under

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.

But I do not see any exception for the choir area in fact 1108.2.7 would specifically require an accessible route

 1108.2.7 Performance areas.

An accessible route shall directly connect the performance area to the assembly seating area where a circulation path directly connects a performance area to an assembly seating area. An accessible route shall be provided from performance areas to ancillary areas or facilities used by performers.

As for the baptismal the code is silent it is not a bathing or recreational facility


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## mark handler

There are no exceptions.

Time for churches to stop discrimination.

All areas need to be accessible, including the pool.

And as to employees, that is only when the "general public" is not permitted in those areas, If the parishioners are allowed, the disabled must have access


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## fatboy

No exceptions.......


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## mtlogcabin

mark handler said:
			
		

> There are no exceptions. Time for churches to stop discrimination.
> 
> All areas need to be accessible, including the pool.
> 
> And as to employees, that is only when the "general public" is not permitted in those areas, If the parishioners are allowed, the disabled must have access


Churches are not violating an individuals civil rights and therefore are not discriminating against anyone according to Federal law (ADA) Last I read they are exempt


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## mn joe

Maybe exempt from ADA but they are not exempt from code provisions!

Joe


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## Lynn

Thanks for the replies.

The platform in question is a sizeable area. Much larger than needed to accomodate only the pastor and his pulpit.

Not sure how you could consider it a work area when visiting pastors, or the congragation (other than handicap persons), or a gospel singing group, or a church christmas pagent can be invited up on the platform.

Seems to me like it is much more of a performance area that a work area.

Unless somebody can tell me different, looks like a platform lift or ramp is requied.

Thanks again for your thoughts and expertise.


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## mark handler

mtlogcabin said:
			
		

> Churches are not violating an individuals civil rights and therefore are not discriminating against anyone according to Federal law (ADA) Last I read they are exempt


Just because Churches are exempt from ADA does not mean they are not violating an individuals civil rights.


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## jar546

If your state or jurisdiction adopted the IBC, then the BS ADA exemption for churches may apply but the church must now comply with accessibility of the IBC & ANSI A117.1

Sounds like the post is specific to what is required and not whether or not ADA applies.


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## mark handler

http://www.inspectpa.com/forum/showthread.php?4399-House-of-worship-amp-ADA/page2&highlight=Churches+exempt


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## steveray

Agree with requiring access...I have had that fight and won at least twice in the past few years,,,,,the baptismal I would have to look very closely at to try to make that determination......


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## Builder Bob

If you research this subject..... I have asked this question in the past.

Why is an organization that is trying to serve the greater being causing or prohibitng access to people who may very well want to participate........

Times have changed and now I have to add:

The men and women who are wounded warriors deserve the opportunity to particpate and perform in ceremonies, choirs, public speaking, and baptisms......They served to protect our freedom, why wouldn't we support them in the years to come...............


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## Lynn

Thanks for all the responses.

One more question:

Does anyone have a reasonable solution to providing access into the baptistry for disabled persons?

I can see a lift for access to the level of entry into the baptistry, but then would you have to have a swimming pool type of hoist chair to transfer into the pool?

Seems like the baptistry access becomes unreasonable.

Looking for any methods of addressing this issue.


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## mark handler

Lynn said:
			
		

> Thanks for all the responses.One more question:
> 
> Does anyone have a reasonable solution to providing access into the baptistry for disabled persons?
> 
> I can see a lift for access to the level of entry into the baptistry, but then would you have to have a swimming pool type of hoist chair to transfer into the pool?
> 
> Seems like the baptistry access becomes unreasonable.
> 
> Looking for any methods of addressing this issue.


You can probably get a portable pool lift “on the cheap” or donated from a major hotel chain…..


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## Jim B

Just to throw in my 2 cents, if your jurisdiction has adopted Appendix E of the IBC 2009, then a speaker lectern on a raised platform will need to be accessible:

_IBC 2009; E103.1 Raised platforms. In banquet rooms or __spaces where a head table or speaker’s lectern is located __on a raised platform, an accessible route shall be provided to the platform._


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## Lynn

Going back thru the post I noticed there was a response indicating, "As for the baptismal the code is silent it is not a bathing or recreational facility"

Is anyone else taking the position that the baptismal pool is exempt from accessibility provisions?


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## mark handler

Lynn said:
			
		

> Going back thru the post I noticed there was a response indicating, "As for the baptismal the code is silent it is not a bathing or recreational facility"Is anyone else taking the position that the baptismal pool is exempt from accessibility provisions?


Access Required

International Building Code

2012

1101.2 Design.

Buildings and facilities shall be designed and constructed to be accessible

1103.1 Where required.

Sites, buildings, structures, facilities, *elements and spaces, *temporary or permanent, shall be accessible to persons with physical disabilities

1103.2.7 Raised areas.

Raised areas used primarily for purposes of security, life safety or fire safety including, but not limited to, observation galleries, prison guard towers, fire towers or lifeguard stands, are not required to be accessible or to be served by an accessible route.

1103.2.8 Limited access spaces.

Nonoccupiable spaces accessed only by ladders, catwalks, crawl spaces, freight elevators or very narrow passageways are not required to be accessible.


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## brudgers

Lynn said:
			
		

> Doing a plans review on a new church sanctuary.  We have adopted the 2006 IBC and as such, Chapter 11 of the IBC and the referenced ANSI A117.1 standards. Is anyone aware of any exception in the IBC, Chapter 11 or the A117.1 standard, for access to the raised platform area that serves the pulpit and choir? Also, what accomodations would be necessary to provide accessibility to a baptismal pool behind the pulpit that is raised 4' or so above the pulpit platform?  I don't find any exceptions and have been calling for a ramp or lift for accessibility to these areas. Looking for any exceptions that I may have missed. Thanks


  The areas are used for worship.  Not mere performances.


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## brudgers

mark handler said:
			
		

> Time for churches to stop discrimination.


  Yeah, Baptists should hire Wiccans as Youth Ministers and the local mosque should hire a Rabbi as Imam.


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## brudgers

Lynn said:
			
		

> Thanks for all the responses. One more question: Does anyone have a reasonable solution to providing access into the baptistry for disabled persons? I can see a lift for access to the level of entry into the baptistry, but then would you have to have a swimming pool type of hoist chair to transfer into the pool? Seems like the baptistry access becomes unreasonable. Looking for any methods of addressing this issue.


   Again, it's worship, not mere performance.


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## north star

*+ + +*

From Section 1108.2.1, `06 IBC: Services. 

Services and facilities provided in areas not required to be accessible

shall be provided on an accessible level and shall be accessible.



An approved & compliant ramped access seems to be the most viable

solution......Time to redesign the baptistry for its use!

FWIW  &  IMO,  the design would seem to be incomplete for there

to be an Accessible route in to the [ church ] building and not to one

of the most important areas of service.

*+ + +*


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## fatboy

"Again, it's worship, not mere performance."

Oh, I must disagree on that point. A lot of the churches now have A/V setups that would make a rock band jealous. It must be a performance.


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## brudgers

fatboy said:
			
		

> "Again, it's worship, not mere performance."  Oh, I must disagree on that point. A lot of the churches now have A/V setups that would make a rock band jealous. It must be a performance.


  And what basis in law do you have for determining what is and isn't worship?


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## brudgers

north star said:
			
		

> FWIW  &  IMO,  the design would seem to be incomplete for there to be an Accessible route in to the [ church ] building and not to one of the most important areas of service.


  When it comes to my religion, your opinion of what is and isn't an important area isn't relevant.  So to speak.

  IMO, when it comes to places of worship, accessibility interpretations should be made in favor of consistency with ADA.

  Don't get me wrong.

  Accessibility is good design.

  But there's a reason for a limited interpretation.

  It's called "The First Amendment."


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## fatboy

Merely making an observation as to what it appears to be brudgers.

Whether it is worship or not is irrelavant, it is an assembly occupancy and will be required to comply with Chapter 10 and A117.1 as required.


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## mark handler

fatboy said:
			
		

> Merely making an observation as to what it appears to be brudgers. Whether it is worship or not is irrelavant, it is an assembly occupancy and will be required to comply with Chapter 10 and A117.1 as required.


And Chapter 11 Or Per accessibility State Code

Not all states use the A117.1


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## fatboy

OK, those also..........


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## brudgers

fatboy said:
			
		

> Merely making an observation as to what it appears to be brudgers.   Whether it is worship or not is irrelavant, it is an assembly occupancy and will be required to comply with Chapter 10 and A117.1 as required.


  Only platforms used for performance are required to be accessible.


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## mark handler

brudgers said:
			
		

> Only platforms used for performance are required to be accessible.


And where is that exception in the building code?


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## fatboy

*per·form*

_verb_ \pə®-ˈfȯrm\

*Definition of PERFORM*

transitive verb

1

*:* to adhere to the terms of *:* fulfill <_perform_ a contract>

_*2*_

_*: *__*carry out*__*, *__*do*_ 

_*3*_

_*a : to do in a formal manner or according to prescribed ritual *_

_*b : to give a rendition of : *__*present*_


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## mtlogcabin

mark handler said:
			
		

> And where is that exception in the building code?


I think he is thinking of

1108.2.8 Performance areas.

An accessible route shall directly connect the performance area to the assembly seating area where a circulation path directly connects a performance area to an assembly seating area. An accessible route shall be provided from performance areas to ancillary areas or facilities used by performers.

Some larger churches the platform may be used as a performance area, (concerts, plays) other churches the accessible route does not have to be provided from the seating area it could come from another area.

Lifts are also permitted in lieu of a ramp


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## mark handler

mtlogcabin said:
			
		

> I think he is thinking of 1108.2.8 Performance areas.
> 
> An accessible route shall directly connect the performance area to the assembly seating area where a circulation path directly connects a performance area to an assembly seating area. An accessible route shall be provided from performance areas to ancillary areas or facilities used by performers.
> 
> Some larger churches the platform may be used as a performance area, (concerts, plays) other churches the accessible route does not have to be provided from the seating area it could come from another area.
> 
> Lifts are also permitted in lieu of a ramp


But that is not an exception to raised platforms in churches.

There is no exception, in the IBC, for churches

All areas and elements of a church building, with the exception of of some employee areas. shall be accessible.


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## brudgers

mark handler said:
			
		

> But that is not an exception to raised platforms in churches.  There is no exception, in the IBC, for churches All areas and elements of a church building, with the exception of of some employee areas. shall be accessible.


  Again, it's not performance.    It's worship.

  Falls under 1104.4 exception 2.


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## mtlogcabin

mark handler said:
			
		

> But that is not an exception to raised platforms in churches. There is no exception, in the IBC, for churches
> 
> All areas and elements of a church building, with the exception of of some employee areas. shall be accessible.


Agree about the raised platform area

Still not convinced about the baptistry

I can see churches leaving them out and going back to using a river or lake. Heck I have seen a watering trough set up in the parking lot of a small church used

A lose lose situation for all


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## mark handler

brudgers said:
			
		

> Again, it's not performance.    It's worship.
> 
> Falls under 1104.4 exception 2.


A raised platform is not defined as a story or mezzanine and Most churches allow the "public" on the platform

Not only "worship" happend in the rasied platform.

You are saying the church or synagogue does not allow Weddings, conformations, sacraments, baptisms, bar mitzvahs, etcetera, on the raised platform


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## brudgers

mark handler said:
			
		

> A raised platform is not defined as a story or mezzanine and Most churches allow the "public" on the platform


  What most churches do during worship is irrelevant.  As is a reference to 'the "public"'

  What is relevant is that the scope of exception 2 is levels.

  Not just stories and mezzanines.

  If Baptists can keep Gandhi out of heaven, why shouldn't they be allowed to keep Larry Flynt off the pulpit?


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## mark handler

brudgers said:
			
		

> What most churches do during worship is irrelevant.  As is a reference to 'the "public"'
> 
> What is relevant is that the scope of exception 2 is levels.
> 
> Not just stories and mezzanines.
> 
> If Baptists can keep Gandhi out of heaven, why shouldn't they be allowed to keep Larry Flynt off the pulpit?


2012 IBC

1104.2 Within a site.

At least one accessible route shall connect accessible buildings, accessible facilities, accessible elements and accessible spaces that are on the same site.

Exception: An accessible route is not required between accessible buildings, accessible facilities, accessible elements and accessible spaces that have, as the only means of access between them, a vehicular way not providing for pedestrian access.


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## mark handler

The use of "public" in the IBC is intended to differentiate from "employee use".

"Public" would be a non-employee


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## brudgers

mark handler said:
			
		

> The use of "public" in the IBC is intended to differentiate from "employee use".  "Public" would be a non-employee


  Employees, shemployees.  It's exempt because there is no specific requirement for it to be accessible in 1108.2.


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## brudgers

mark handler said:
			
		

> 2012 IBC 1104.2 Within a site.  At least one accessible route shall connect accessible buildings, accessible facilities, accessible elements and accessible spaces that are on the same site.   Exception: An accessible route is not required between accessible buildings, accessible facilities, accessible elements and accessible spaces that have, as the only means of access between them, a vehicular way not providing for pedestrian access.


  Yes, and so what?    A worship level is not an accessible element.


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## mark handler

brudgers said:
			
		

> Yes, and so what?    A worship level is not an accessible element.


Where is  "A worship level" identified on the code?

Where are you getting this "Stuff"


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## Codegeek

FWIW, there was a proposed code change heard in Dallas to address just this very issue.  It was E171.  It was "approved as submitted" by the committee.

1103.2.8 Areas in places of religious worship. Raised or lowered areas, or portions of areas, in places of religious worship that are less than 300 sq.ft. (30 m2) in area and located 7 inches or more (178 mm) or more above or below the finished floor and used primarily for the performance of religious ceremonies are not required to comply with this chapter.


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## mark handler

Codegeek said:
			
		

> FWIW, there was a proposed code change heard in Dallas to address just this very issue.  It was E171.  It was "approved as submitted" by the committee.  1103.2.8 Areas in places of religious worship. Raised or lowered areas, or portions of areas, in places of religious worship that are less than 300 sq.ft. (30 m2) in area and located 7 inches or more (178 mm) or more above or below the finished floor and used primarily for the performance of religious ceremonies are not required to comply with this chapter.


But it is not in the current codes


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## Codegeek

mark handler said:
			
		

> But it is not in the current codes


Correct, just making a point that it has potential to be in the 2015.


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## brudgers

mark handler said:
			
		

> Where is  "A worship level" identified on the code? Where are you getting this "Stuff"


  "Level" is found in chapter 11 of the IBC.  Do you think that if you had read it, perhaps you would already be familiar with it?


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## mark handler

> Correct, just making a point that it has potential to be in the 2015.


I know that, but Ben does not


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## brudgers

mark handler said:
			
		

> But it is not in the current codes


  What is in current code is "performance."  And that does not necessarily apply to houses of worship.


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## brudgers

Codegeek said:
			
		

> Correct, just making a point that it has potential to be in the 2015.


  That's the problem with the IBC.  Rather than clarifying that performance does not mean worship, they add another provision.


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## mark handler

brudgers said:
			
		

> That's the problem with the IBC. Rather than clarifying that performance does not mean worship, they add another provision.


Thats because some worship services are performances


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## brudgers

mark handler said:
			
		

> Thats because some worship services are performances


  I'm glad to see that you've finally recognized that those that aren't part of the "some" ain't performances.


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## mark handler

brudgers said:
			
		

> I'm glad to see that you've finally recognized that those that aren't part of the "some" ain't performances.


I did not "finally recognize" anything, access is not related to a performance. There are additional POT rules when there are performances. Platforms are required to have access with or without performances.


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## brudgers

mark handler said:
			
		

> I did not "finally recognize" anything, access is not related to a performance. There are additional POT rules when there are performances. Platforms are required to have access with or without performances.


  By what code section?


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## mark handler

International Building Code

2012

1101.2 Design.

Buildings and facilities shall be designed and constructed to be accessible

1103.1 Where required.

Sites, buildings, structures, facilities, *elements and spaces,* temporary or permanent, shall be accessible to persons with physical disabilities

1103.2.7 Raised areas.

Raised areas used primarily for purposes of security, life safety or fire safety including, but not limited to, observation galleries, prison guard towers, fire towers or lifeguard stands, are not required to be accessible or to be served by an accessible route.

 1103.2.8 Limited access spaces.

Nonoccupiable spaces accessed only by ladders, catwalks, crawl spaces, freight elevators or very narrow passageways are not required to be accessible.


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## brudgers

At least now you're reading the code.

  Now read a little further down to 1103.2.1

  Then keep reading until you understand 1104.4.2


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## mark handler

brudgers said:
			
		

> At least now you're reading the code.   Now read a little further down to 1103.2.1
> 
> Then keep reading until you understand 1104.4.2


Ben



> Well I will give you the fact that you certainly have a unique approach. Apparently you are content to just keep rambling until you wear everybody out. Whether the thought process is rational or not.What it "they" say - don't confuse me with the facts, I have my mind made up.


 and reread the thread until you understand


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## brudgers

Mark, some levels are required to be served by an accessible route.

  Some aren't.

  A level used for worship is not necessarily  required to be served by one.

  But don't let the code stand in the way of your misinterpretation.

  And don't let the first amendment stand in the way of your paternalism.


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## DwightB

I had a plan reviewer in Iowa attempt to press the issue of access to the baptistry.  We agreed with other here that it would be difficult and expensive to provide.  We also agree that there are sometimes repentant sinners who desire immersion and have mobility issues due to age, weight, or physical impairment. The minister and I were able to convince the reviewer that there are always capable witnesses to the baptism who are more than eager to help someone into or out of the baptistry when necessary.  He agreed to describe it as a religious ceremony and not require the church to spend unnecessary expense.


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## Lynn

Mercy

I took a few days off and came back and found my question had turned into a three page thread.

Thanks for all the thoughts and interpretations.

In end result I think I have to go with Dwight B relative to the baptistry issue and my interpretation of the code requires access to the platform.

Thanks again for the thoughts and perspectives.


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## fatboy

Seems like a reasonable approach...........


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## brudgers

Lynn said:
			
		

> Mercy I took a few days off and came back and found my question had turned into a three page thread. Thanks for all the thoughts and interpretations. In end result I think I have to go with Dwight B relative to the baptistry issue and my interpretation of the code requires access to the platform. Thanks again for the thoughts and perspectives.


  I don't see any way to apply the code consistently and maintain that distinction.  The same argument about helpers can be applied to any raised area within a house of worship.

  Essentially, be accepting the difference you are making an ecclesiastical judgement.

  And potentially favoring one religion over another.

  E.g. your approach allows you to make exceptions for a Baptist church that you might not make for a Synagog.

  Furthermore, your approach would require a Mosque to pass your ecclesiastical smell test in order to obtain an exemption.

  My recommendation would be to get a written opinion from your municipal attorney.

  I'd actually require one, if it were my project.


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## fatboy

Oh please, you can't be serious. Religious denominations have absolutely nothing to do with the the application of codes. Give it up...........it fits or it doesn't.


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## peach

Churches are exempt from ADA, but not the building code (unless you dont require permits for churches).  Needs to be accessible (and I've never had any blowback from churches when I require ramps and lifts).


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## brudgers

peach said:
			
		

> Churches are exempt from ADA, but not the building code (unless you dont require permits for churches).  Needs to be accessible (and I've never had any blowback from churches when I require ramps and lifts).


  I've never claimed that houses of worship were exempt from the building code.  Code officials aren't either.


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## brudgers

fatboy said:
			
		

> Oh please, you can't be serious. Religious denominations have absolutely nothing to do with the the application of codes. Give it up...........it fits or it doesn't.


  I'm First Amendment serious.  The previous poster was exempting one particular form of religious practice while discriminating against others.


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## mark handler

brudgers said:
			
		

> I'm First Amendment serious.  *The previous poster *was exempting one particular form of religious practice while discriminating against others.


Which previous poster ?


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