# Multi-story accessibility



## ThatOneGuy (Feb 22, 2019)

Hello all,

Question about where accessible Access is required for multiple stories. I did a lot of searching on the forum and found good information about 4-story buildings, the 3,000 SF rule, and healthcare uses. None of that _quite_ fits what I'm looking at. Using vanilla 2015 IBC (no state amendments).







This is an existing warehouse for a utility provider's maintenance department. Before I go any farther, there is a LOT wrong with the building and it will probably end up getting demolished, so this question is largely academic. In general I'm trying to figure out where elevators would be required in this kind of maintenance-only building. There are a number of code sections in play here, and this is what I've got so far:

Since this is clearly an area not open to the public the first thing I looked at was employee work areas.
_1103.2.2 Spaces and elements within employee work areas shall only be required to comply with Sections 907.5.2.3.1, 1009 and 1104.3.1 _-  So that's visible fire alarms, accessible means of egress, and common use circulation paths. Accessible MOE could be taken care of with stairs as long as we are under 4 stories. Even if you counted the mezzanine as a story (over the 1/3 or 1/2 rule) that's still not an issue. Common circulation is a question for the mezzanine because you cannot "approach, enter and exit the work area" using the stairs. 

Next I looked at multi-story requirements.
_1104.4 Multistory buildings and facilities. At least one accessible route shall connect each accessible story and mezzanine in multilevel buildings and facilities._
_Exception 1: 3,000 SF rule_ -  This building is roughly 5,000 SF per floor so this doesn't work.
_Exception 3:  ATC towers_, n/a.
_Exception 4: 5 occupants or less._ Even at a warehouse loading of 1/500 I'd still be >5 so that's out too. 

Exception 2 is what caught my attention.
_Stories or mezzanines that do not contain accessible elements or other spaces as determined by Section 1107 or 1108 are not required to be served by an accessible route from an accessible level._ -  1107 and 1108 cover dwelling units, assembly seating, self-serve storage, and judicial facilities, so none of that applies. 

So in summary if a multi-story building 3 floors or less intentionally has NO accessible elements on floors 2 and 3 (e.g. all restrooms on 1st floor only), and doesn't fall into one of the four 1107/1108 use categories, then there would be NO requirement for an accessible route to those stories. Does that sound right?

I hope the folks here can check my work and let me know if I've gone astray somewhere. It just seems a little loophole-ish, like you could theoretically have a big 3-story office building where 2 floors have no accessible features at all. Looking forward to seeing  your thoughts on this.


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## ThatOneGuy (Feb 22, 2019)

Image didn't work, here's a separate link.
https://drive.google.com/open?id=1MJ5bzcwgkaABW1VTTXk57IjwWjWQDyBb


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## ADAguy (Feb 22, 2019)

Open risers don't comply
Exemption if not retail also doesn't apply?


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## ThatOneGuy (Feb 22, 2019)

ADAguy said:


> Open risers don't comply


 Yeah, like I said this building has a lot wrong with it. Open risers are the tip of the iceberg. 


ADAguy said:


> Exemption if not retail also doesn't apply?


Retail use is the exception to the exception to the 3,000 ft rule (1104.4.1.1.), so no, it's already over the area limit.


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