# Employee-Only Storage Room Require ADA access?



## fj80

Does a 125 sf storage room need to have an ADA compliant door width and maneuvering clearances, if the room is only used by employees? If not, which code determines the minimum door opening width?

IBC 2012, ADA 2010, ANSI A117.1-2003


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## steveray




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## fj80

steveray said:


> View attachment 2458


That section refers to "common use circulation paths" which I'm not sure apply to an opening from one room into another. It's not really a circulation path used by multiple people. There will just be one person, the concierge, going between the front desk and the storage room.

We are planning to demolish a portion of an existing thick wall in order to get our opening between the rooms. However that opening can only be 33" wide, and the wall is approximately 2'-6" deep. Therefore it does not meet the ADA requirements of 404.2.3 "openings more than 24 inches deep shall provide a clear opening of 36 inches minimum."  Since I can't make this opening comply, do I need to add a second opening through another wall in order to comply with ADA? Or is the opening acceptable because it's an employee-only work area and the ADA opening requirement doesn't apply?

I'll try to post a sketch if I can figure out how...


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## fj80

Do you have to be a Sawhorse member to post attachments?

In any case, one additional comment:

ADA 203.9 Employee Work Areas states those areas "shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area." But it doesn't give any specifics on which requirements satisfy this clause. Is this a gray area, or are there specifics for this situation?


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## ADAguy

Specifics as in technical requirements would be found in Chapter 4 - 404, 404.2.3 clear width. Inset your door midway in the width and you should comply.


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## Rick18071

As a building Code Inspector I don't enforce the ADA (a civil rights law) but I do enforce the 2015 IBC for accessibity in my state. I would not consider a storage room an area containing a primary function. This would be under the Existing Buildings Chapter 34:

*3411.6 Alterations*.
A building, facility or element that is altered shall comply with the applicable provisions in Chapter 11 of this code and ICC A117.1, unless technically infeasible . Where compliance with this section is technically infeasible , the alteration shall provide access to the maximum extent technically feasible.
Exceptions:
1. The altered element or space is not required to be on an accessible route, unless required by Section 3411.7.
2. Accessible means of egress required by Chapter 10 are not required to be provided in existing buildings and facilities.
3. The alteration to Type A individually owned dwelling units within a Group R-2 occupancy shall meet the provision for a Type B dwelling unit and shall comply with the applicable provisions in Chapter 11 and ICC A117.1.
*3411.7 Alterations affecting an area containing a primary function.*


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## ADAguy

No you don't but your code should be no less than ADA minimums.


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## Paul Sweet

Doesn't the ADA have an exception for structural impractability?


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## mtlogcabin

A supply storage room is not a "primary function area" under the ADA alterations portion

*(b) Alterations*.

(1) Each facility or part of a facility altered by, on behalf of, or for the use of a public entity in a manner that affects or could affect the usability of the facility or part of the facility shall, to the maximum extent feasible, be altered in such manner that the altered portion of the facility is readily accessible to and usable by individuals with disabilities, if the alteration was commenced after January 26, 1992.
(2) The path of travel requirements of § 35.151(b)(4) shall apply only to alterations undertaken solely for purposes other than to meet the program accessibility requirements of § 35.150.
(3)
(i) Alterations to historic properties shall comply, to the maximum extent feasible, with the provisions applicable to historic properties in the design standards specified in § 35.151(c).
(ii) If it is not feasible to provide physical access to an historic property in a manner that will not threaten or destroy the historic significance of the building or facility, alternative methods of access shall be provided pursuant to the requirements of § 35.150.

*(4) Path of travel.* An alteration that affects or could affect the usability of or access to an area of a facility that contains a primary function shall be made so as to ensure that, to the maximum extent feasible, the path of travel to the altered area and the restrooms, telephones, and drinking fountains serving the altered area are readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs, unless the cost and scope of such alterations is disproportionate to the cost of the overall alteration.
*(i) 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 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 entity using the facility are carried out.
(A) Mechanical rooms, boiler rooms, *supply storage rooms*, employee lounges or locker rooms, janitorial closets, entrances, and corridors are not areas containing a primary function.


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## steveray

3411.6 sends you back to Ch. 11....if it is not exempted under Ch. 11, it is required...I don't believe that primary function has much to do with this specific situation or question...


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## ADAguy

Yes Paul but where do you see the impracticality to install the door in the center of the wall, or to add an assist device (smiling).


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## steveray

ADAguy said:


> Yes Paul but where do you see the impracticality to install the door in the center of the wall, or to add an assist device (smiling).



If you recess it into the wall do you still meet your push and pull side clearances?


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## ADAguy

yes, unless you omit closer and latch or provide an assist device.


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## Paul Sweet

ADAguy said:


> Yes Paul but where do you see the impracticality to install the door in the center of the wall, or to add an assist device (smiling).



ADASAD 404.2.4.3 Recessed Doors and Gates requires maneuvering space if the door is recessed more than 8".  If the door is installed in the middle of a 2'-6" wall it will be recessed more than 8" on both sides.


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## ADAguy

not if you delete latch and closer or provide an assist device.


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## Filthy McNasty

Only if there is an employee that has a disability.


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## Filthy McNasty

Or if they hire one, they may need to make it accessible.


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## mark handler

Filthy McNasty said:


> Or if they hire one, they may need to make it accessible.


Not for new construction


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## Filthy McNasty

So like I said- 
if they hire a disabled employee, they may need to make it accessible.  Glad we agree.


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## steveray

Is it the only way into the storage room? Is it a new room?


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## ADAguy

Read back, it is an alteration as opposed to an accommodation. It may also be viewed as a voluntary barrier removal.


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## fj80

steveray said:


> Is it the only way into the storage room? Is it a new room?


It is a new room that will be created as part of the renovation of the existing space. And yes, the owner would prefer that it be the only way into the storage room. But I have recommended they install a second way into the room that is an ADA-compliant door with required clearances.


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## ADAguy

I understand his wish for security, so consider use of an electronic assist device.


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