# Mini Warehouse Storage



## BayPointArchitect (Feb 18, 2010)

Local Code: IBC Chapter 11 is deleted according to local ammendment and replaced with Nebraska Accessibility Guidelines which is patterned from the 1994 version of ANSI A117.

After reviewing my State Regulations for H.C. Accessibility, I find that the minimum number of self-storage units that need to be handicap accessible is one H.C. unit for each type or size of storage unit.  Considering that I have five different sizes available, then I would require only five of the 229 storage units to be accessible.

I see that IBC Chapter 11 would require eleven units... (which does not apply within this jurisdiction) and A117 doesn't mention anything.

Question:

Is there another code out there that gives a ratio of number of storage units that need to be ADA compliant?

The only practical difference being the operation of the door and the elimination of the 1" lip on the door threshold that would normally help to keep out wind-driven rain.

Thanks

---------------------------------

AIA, NCARB, ICC, NCOA, CSI

ICC Plans Examiner


----------



## brudgers (Feb 18, 2010)

Re: Mini Warehouse Storage

How would any part of a commercial storage facility be exempt from Title III of the ADA?


----------



## TJacobs (Feb 18, 2010)

Re: Mini Warehouse Storage

Call me ignorant, but since you know that IBC requires 11 units why wouldn't you provide them?  You can exceed the outdated state code by following an updated consensus-based code.  Sounds like a no brainer to me.


----------



## Coug Dad (Feb 18, 2010)

Re: Mini Warehouse Storage

If you are the code enforcer, you should not be asking for anything more than required by the code, regarless if you feel it is outdated.  If you are the designer of record, the code is your minimum and you can provide whatever you want in excess of the code minimum.


----------



## Coug Dad (Feb 18, 2010)

Re: Mini Warehouse Storage

Bay Point,

What section of the Nebraska Code do you see as only requiring one per unit type?

How can the jurisdiction eliminate Chapter 11.  Chapter 11 contains the scoping requirements.  ANSI, or in the case of Nebraska, the Fire Marshal's guidelines contain the how to provisions.  Without the scoping provisions of Chapter 11, the how to's are meaningless.


----------



## TJacobs (Feb 18, 2010)

Re: Mini Warehouse Storage



			
				Coug Dad said:
			
		

> If you are the code enforcer, you should not be asking for anything more than required by the code, regarless if you feel it is outdated.  If you are the designer of record, the code is your minimum and you can provide whatever you want in excess of the code minimum.


I wasn't.  I wouldn't.  I'd be stuck with not having IBC Chapter 11 with an outdated code like we have here.  Left Chapter 11 in when we adopted 2006.


----------



## Builder Bob (Feb 19, 2010)

Re: Mini Warehouse Storage

At one time DOJ was requiring either a power actuated door (door opener) or a manual side swing door. the issue here is the 15 lbs required for opening force to open the door. I really haven't seen to many overhead doors that are that easy to open.(matter of fact none, but I always try to leave a little wiggle room in case I missed one)


----------



## Builder Bob (Feb 19, 2010)

Re: Mini Warehouse Storage

http://www.justice.gov/crt/foia/cltr147.txt

letter of interpretation from DOJ dated 1994 for ADA.

Read it, digest it, and see what your opinion becomes.

If storage lockers are intended for people to enter, the accessible locker will have to provide an

accessible entrance, accessible interior controls, and accessible interior space, as well as accessible storage spaces.


----------



## BayPointArchitect (Feb 19, 2010)

Re: Mini Warehouse Storage



			
				brudgers said:
			
		

> How would any part of a commercial storage facility be exempt from Title III of the ADA?


While comparing the State regulations (N.A.G.) with Title III of ADA, I see that section 4.25 Storage, is the same.  It explains the criteria for accessible storage but does not tell me how many storage units need to be accessible.

CougDad,

Thanks for the 1994 letter from DOJ.  It is that same section 4.1.3(12) that I was hanging my hat on.  This is why I would normally require at least one HC unit for each size of storage available.  But I found a letter of interpretation from our State Fire Marshal's office which requires 5% of each type (twelve in this case).

I am more confident now that I haven't missed something.  I will note the option of having a side swing door with maximum 15 lbs force.  I hadn't considered that before.

Thanks everyone for your help.

---------------------------------

AIA, NCARB, ICC, NCOA, CSI

ICC Plans Examiner


----------



## Coug Dad (Feb 19, 2010)

Re: Mini Warehouse Storage

You are welcome, but it was actually Builder Bob


----------



## brudgers (Feb 19, 2010)

Re: Mini Warehouse Storage



			
				BayPointArchitect said:
			
		

> brudgers said:
> 
> 
> 
> > How would any part of a commercial storage facility be exempt from Title III of the ADA?


While comparing the State regulations (N.A.G.) with Title III of ADA, I see that section 4.25 Storage, is the same.  It explains the criteria for accessible storage but does not tell me how many storage units need to be accessible.

CougDad,

Thanks for the 1994 letter from DOJ.  It is that same section 4.1.3(12) that I was hanging my hat on.  This is why I would normally require at least one HC unit for each size of storage available.  But I found a letter of interpretation from our State Fire Marshal's office which requires 5% of each type (twelve in this case).

I am more confident now that I haven't missed something.  I will note the option of having a side swing door with maximum 15 lbs force.  I hadn't considered that before.

Thanks everyone for your help.

---------------------------------

AIA, NCARB, ICC, NCOA, CSI

ICC Plans Examiner

Because a storage facility is obviously a place of public accommodation, I don't see how any portion of it can be inaccessible under ADA Title III.


----------



## Plans Approver (Feb 19, 2010)

Re: Mini Warehouse Storage



			
				brudgers said:
			
		

> Because a storage facility is obviously a place of public accommodation, I don't see how any portion of it can be inaccessible under ADA Title III.


The warehouse building w/ its offices need to be accessible, but, not every storage unit is a place of public accommodation.  Our local storage warehouse uses keycards w/ electric door operators (side swinging and overhead) for the accessible units.


----------



## Builder Bob (Feb 19, 2010)

Re: Mini Warehouse Storage

we typically see a concrete pad for parking with either a overhead door controller (i.e. garage door opener) and/or man side swing door at each accessible unit. The rest of the lot tend to be gravel (informal language for pervious paving).


----------



## brudgers (Feb 19, 2010)

Re: Mini Warehouse Storage



			
				Plans Approver said:
			
		

> brudgers said:
> 
> 
> 
> > Because a storage facility is obviously a place of public accommodation, I don't see how any portion of it can be inaccessible under ADA Title III.


The warehouse building w/ its offices need to be accessible, but, not every storage unit is a place of public accommodation.  Our local storage warehouse uses keycards w/ electric door operators (side swinging and overhead) for the accessible units.

Every building within the facility is a place of public accommodation.

What your local facility does may not meet Title III.

As a matter of fact it probably doesn't.

At least I haven't seen anything in ADAAG which would exempt a unit from being on an accessible route, having accessible controls and operating mechanisms, and allowing a disabled person to enter and exit.

Indeed, each unit might easily be considered to be a primary function area.


----------



## brudgers (Feb 19, 2010)

Re: Mini Warehouse Storage



			
				Builder Bob said:
			
		

> we typically see a concrete pad for parking with either a overhead door controller (i.e. garage door opener) and/or man side swing door at each accessible unit. The rest of the lot tend to be gravel (informal language for pervious paving).


Suppose a facility has 5 "handicapped" units and 100 inaccessible units and none of the "handicapped" units are available but five of the inaccessible units are.

In that case, are you saying that when a person with disablity wants to rent a unit, they're just SOL?

Or is your owner obligated to convert one of the inaccessible units?

Here's what the DOJ has to say on the issue:

http://www.justice.gov/crt/foia/tal277.txt


----------



## Gene Boecker (Feb 19, 2010)

Re: Mini Warehouse Storage

It's all been said. . . . .


----------

