# Is a deadbolt NOT a "latch"?



## Michael.L (May 16, 2018)

I'll admit: it took me a few days of pondering to finally understand why extra clear floor space was needed for doors with both a closer *and* a latch, but not for a door with either a closer *or* a latch. Additionally, I couldn't imagine a scenario where a single-occupancy restroom would have a door without some way of securing it for privacy.

Then it dawned on me that a "latch" must be defined as a spring-loaded device that the user must perform an action upon in order to release the door (turn a lever, press a paddle, etc) *and* that the user must continue to hold that "latch" in the released position (against the pressure of the latch's spring mechanism) while the door is then being pushed or pulled open against the force of the closer. In other words, the user must perform two separate but simultaneous actions: (1) hold open the latch against spring pressure; *and* (2) push or pull open the door against the pressure of the closer.

Remove the closer, and the user can release the latch and then freely swing the door open.

Remove the latch, and the user can simply push through the door (or pull it open).

Add both a closer *and* a latch and it becomes very challenging for a disabled person to perform both actions at the same time. Hence the need for additional maneuvering space.

Am I understanding this correctly so far?

So that leads me to four questions:

1. If a door has a closer and a _deadbolt_ for privacy (with *no* spring-loaded "latch" that automatically secures the door when the door closes), does that negate the requirement for additional clear floor space?

2. Is it permitted to have a door to a single-occupancy restroom with only a deadbolt, but no latch?

3. If the previous two questions are true, is this widely known and accepted by inspectors?

4. Is there any ADA code reference that specifically backs this up?​Just to be clear, my definition of a deadbolt would be a manually-activated device that has an operating lever on the inside and a keyed cylinder on the outside. The deadbolt requires a user to perform an action on the inside lever to lock or unlock the door; the bolt remains in whichever position is selected by the user. For a single-occupancy restroom, the deadbolt would have an indicator that shows that the restroom is "Occupied" when the deadbolt is locked, and "Vacant" when the deadbolt is unlocked.


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## cda (May 16, 2018)

not into handicap bathrooms,

But I think you are applying latch wrongly,

I have seen slide latches and other type, where you open it and it stays open. Then you just open the door


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## Michael.L (May 16, 2018)

cda said:


> I have seen slide latches and other type, where you open it and it stays open. Then you just open the door


I realize those are called latches in common vernacular. But does a slide latch meet the definition of a "latch" for the purposes of ADA clear floor space requirements? I would think that it doesn't. Is the word "latch" defined anywhere in the ADA code? I couldn't find it.


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## cda (May 16, 2018)

Ok I was thinking the actual stall door

And I think you mean the room door

Sorry


Not sure if it has to be spring loaded?


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## cda (May 16, 2018)

Read through this

May help


http://idighardware.com/?s=Restroom&submit=

Plus use different search terms


Plus you can email a question


http://idighardware.com/about-2/


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## mp25 (May 16, 2018)

Michael.L said:


> 1. If a door has a closer and a _deadbolt_ for privacy (with *no* spring-loaded "latch" that automatically secures the door when the door closes), does that negate the requirement for additional clear floor space?​


​
While I am not a building inspector, I have always interpreted it the same way as you have described it.


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## north star (May 16, 2018)

*#  #  #  #*

1.  No
 2.  IMO, Yes !
 3.  Nothing is widely known or accepted by Inspectors, ...anywhere !
 4.  Back what up ?......What are you trying to find out ?

*latch* =  [ One definition ]: _"A device for holding a door, gate, or the_
_like, closed, consisting basically of a bar falling or sliding into a catch,_
_groove, hole, etc."_  [  i.e. - no spring is required  ]

*#  #  # #*


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## Michael.L (May 17, 2018)

north star said:


> 1.  No


May I ask what you're basing this determination on? I'm not seeking opinion, but something either in the ADA code or in widely-accepted practice.


north star said:


> 4.  Back what up ?......What are you trying to find out ?


I thought that was clear from my post. I'm trying to find out if it's possible to have a closer and a "deadbolt" (as opposed to a closer and a "latch") to avoid the extra clear floor space requirement.


north star said:


> latch = [ One definition ]: "A device for holding a door, gate, or the like, closed, consisting basically of a bar falling or sliding into a catch, groove, hole, etc."  [  i.e. - no spring is required  ]


This appears to be a dictionary definition. I'm seeking the legal definition of a "latch" with respect to the ADA code.


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## Builder Bob (May 17, 2018)

The problem with code is that it is subject to interpretation by the AHJ --- A deadbolt in my humble opinion does not meet the requirement for a latch, however in the next city, USA it may...... the best guidance is to look at DOJ lawsuits for improper ADA accessibility and determine what is most probably the norm....  Crappy answer I know, but in most cases if you ask a code related question, the response you will get is "It depends"


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## Michael.L (May 17, 2018)

Builder Bob said:


> The problem with code is that it is subject to interpretation by the AHJ --- A deadbolt in my humble opinion does not meet the requirement for a latch, however in the next city, USA it may...... the best guidance is to look at DOJ lawsuits for improper ADA accessibility and determine what is most probably the norm....  Crappy answer I know, but in most cases if you ask a code related question, the response you will get is "It depends"


Wow. So the ADA code has been in existence since 1990, with a major revision in 2010, and in almost 3 decades, no one has bothered to establish definitions for the binding legal language used in the code? How hard is it to write a glossary of terms? Instead, they're leaving it up to local interpretation (and perhaps even leaving it to the interpretation of various individuals)? To me, this is unacceptable.


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## Michael.L (May 17, 2018)

Btw, this is the type of deadbolt I'm thinking about putting on the single occupancy restroom (with no other latch). So someone inside can unlock the deadbolt and then push through the door as if no latch exists.


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## Michael.L (May 17, 2018)

I just found an interesting tidbit that seems to back up my position that a deadbolt, by itself, is not a latch.


> Because this is a fire door, it must close and latch to deter the spread of smoke and flames. NFPA 80 addresses products which do not latch each time the door closes, but requires that _“in a fire emergency, the door becomes positively latched by means of an automatic fail-safe device that is activated by an automatic fire detector.”_



Note the focus on the requirement for a "latch" to actually latch (secure) the door _automatically _when the door is in the closed position_._ A manually-operated deadbolt will never automatically latch a door. To me, this means that a deadbolt is not considered a "latch" for the purposes of building, fire, and accessibility codes; instead, a deadbolt falls under the category of "a product which does not latch each time the door closes."


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## LGreene (May 17, 2018)

Hi All - 

I just submitted a request for a staff opinion to the ICC, and I will report back.  In my opinion, a deadbolt is not the same thing as a latch, based on industry terminology and the requirements for latching on fire doors.  The building occupant would not be holding a latch retracted and pushing against the force of the closer simultaneously, so I don't think the extra maneuvering clearance is needed.  But I will let you know what the ICC says.

- Lori


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## Michael.L (May 17, 2018)

Thank you, Lori!


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## ADAguy (May 17, 2018)

Michael:
1. ADA "is not" a code, it is merely a model.
2. 201.4 Terms not defined refers you to "other commonly implied in the context of its use", (wordsmithing required and an English major (smiling)).  
You are expending a great amount of time seeking an affirmative definition where one does not presently exist.  The intent of the code is not to have to define "every" term used or it will increase in size tremendously. This is where "it depends" is left to the AHJ and "others" to determine what is acceptable or not.


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## Michael.L (May 17, 2018)

ADAguy said:


> You are expending a great amount of time seeking an affirmative definition where one does not presently exist.  The intent of the code is not to have to define "every" term used or it will increase in size tremendously. This is where "it depends" is left to the AHJ and "others" to determine what is acceptable or not.


Considering that people are able to sue a business into oblivion over "civil rights violations" established by this "model," I'd say it's pretty damn important that the terms be affirmatively defined. Why should it be left to the discretion of the AHJ where it can vary from county to county? Laws and regulations should be standardized, uniform, and clear.

And since when has the government been concerned about the size of paperwork?


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## mtlogcabin (May 17, 2018)

Latch is used 57 times throughout the I-codes and it includes self latching, night latch, hook-and-eye-type latch incorporating a spring-actuated retaining lever such as a safety gate hook, three-point latch and latch bolt.

1. If a door has a closer and a _deadbolt_ for privacy (with *no* spring-loaded "latch" that automatically secures the door when the door closes), does that negate the requirement for additional clear floor space? No you would still have to meet the clearance requirements for a compartment door which is 52 inches from hinge side A117.1 section 604.9.3.1

2. Is it permitted to have a door to a single-occupancy restroom with only a deadbolt, but no latch? Yes if is is an accessible thumbturn. See answer above and  http://idighardware.com/2010/08/accessible-thumbturns/

3. If the previous two questions are true, is this widely known and accepted by inspectors? IMHO No

4. Is there any ADA code reference that specifically backs this up? Not to my knowledge



604.9.3 Doors.
Toilet compartment doors, including door hardware, shall comply with Section 404, except if the approach is to the latch side of the compartment door clearance between the door side of the stall and any obstruction shall be 42 inches (1065 mm) minimum. The door shall be self-closing. A door pull complying with Section 404.2.6 shall be placed on both sides of the door near the latch. Toilet compartment doors shall not swing into the required minimum area of the compartment.

404.2.6 Door Hardware.
Handles, pulls, latches, locks, and other operable parts on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, pinching, or twisting of the wrist to operate. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the floor. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.

EXCEPTION: Locks used only for security purposes and not used for normal operation shall not be required to comply with Section 404.2.6.

404.2.7 Closing Speed.

404.2.7.1 Door Closers.
Door closers shall be adjusted so that from an open position of 90 degrees, the time required to move the door to an open position of 12 degrees shall be 5 seconds minimum.

404.2.7.2 Spring Hinges.
Door spring hinges shall be adjusted so that from an open position of 70 degrees, the door shall move to the closed position in 1.5 seconds minimum.

404.2.8 Door-Opening Force.
Fire doors shall have the minimum opening force allowable by the appropriate administrative authority. The force for pushing or pulling open doors other than fire doors shall be as follows:

1.    Interior hinged door: 5.0 pounds (22.2 N) maximum

2.    Sliding or folding door: 5.0 pounds (22.2 N) maximum

These forces do not apply to the force required to *retract latch bolts or disengage other devices* that hold the door in a closed position.


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## Michael.L (May 17, 2018)

mtlogcabin said:


> 1. If a door has a closer and a _deadbolt_ for privacy (with *no* spring-loaded "latch" that automatically secures the door when the door closes), does that negate the requirement for additional clear floor space? No you would still have to meet the clearance requirements for a compartment door which is 52 inches from hinge side A117.1 section 604.9.3.1


Thank you for this information, but that code section is for toilet compartments (i.e., toilet stalls). I don't believe it applies to entry doors to single-occupancy toilet facilities (single-occupancy restrooms).


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## mtlogcabin (May 17, 2018)

I would consider a single occupancy toilet room as either a compartment or a room and allow whichever section will give you the smallest clearance requirement at the door (alternate means and methods). If it works for a compartment it will work for a toilet room door, A compartment is required to have a pull handle on both sides as you may have to pull on the door to engage the slide latch/bar I would require a pull handle if you installed anything other than a self-latching device, maybe that is the reason for the clearance requirements I do not know.


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## cda (May 17, 2018)

LGreene said:


> Hi All -
> 
> I just submitted a request for a staff opinion to the ICC, and I will report back.  In my opinion, a deadbolt is not the same thing as a latch, based on industry terminology and the requirements for latching on fire doors.  The building occupant would not be holding a latch retracted and pushing against the force of the closer simultaneously, so I don't think the extra maneuvering clearance is needed.  But I will let you know what the ICC says.
> 
> - Lori




Idea what could be used?


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## Michael.L (May 17, 2018)

mtlogcabin said:


> I would consider a single occupancy toilet room as either a compartment or a room and allow whichever section will give you the smallest clearance requirement at the door (alternate means and methods). If it works for a compartment it will work for a toilet room door, A compartment is required to have a pull handle on both sides as you may have to pull on the door to engage the slide latch/bar I would require a pull handle if you installed anything other than a self-latching device, maybe that is the reason for the clearance requirements I do not know.


Since I'll only be building a single-occupancy restroom (no compartments/stalls), I'll limit my discussion to only this type of facility.

I think it would be a good idea to have a pull-handle on a door that has only a deadbolt (no self-latching device), even if the door has a closer.


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## ADAguy (May 17, 2018)

Good "Best Practice", code required? Only for Accessible stalls, required on both sides.


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## LGreene (May 17, 2018)

I talked with an ICC staff member today, and she agreed that a deadbolt is not a latch.  So a door with a closer and a deadbolt would not require the additional maneuvering clearance needed when a door has a closer and a latch.


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## Yikes (May 17, 2018)

I look forward to Lori's research and response.  I believe the reason for the extra 12" push side clearance when equipped with both closer AND latch is that the extra force and dexterity required to SIMULTANEOUSLY operate the latch and closer means that a person with weak limbs might have to physically center their body at the latch handle in order to both  turn it and open the door.

Therefore, if the latch can be opened first and it stays open, then in a second step the door can be pushed open without needing to simultaneously hold onto the latch, there should be no need for the 12" push.  

As I say, I think this is the code intent.  how it is worded and what was intended are sometimes different things.


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## Yikes (May 17, 2018)

LOL, just missed Lori's response before I posted.


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## steveray (May 18, 2018)

Technically....The deadbolt is not allowed...

1008.1.9.3 Locks and latches. Locks and latches shall be
permitted to prevent operation of doors where any of the following
exists:
1. Places of detention or restraint.
2. In buildings in occupancy Group A having an occupant
load of 300 or less, Groups B, F, M and S, and in places
of religious worship, the main exterior door or doors
are permitted to be equipped with key-operated locking
devices from the egress side provided:
2.1. The locking device is readily distinguishable as
locked;
2.2. A readily visible durable sign is posted on the
egress side on or adjacent to the door stating:
THIS DOOR TO REMAIN UNLOCKED
WHEN BUILDING IS OCCUPIED. The sign
shall be in letters 1 inch (25 mm) high on a contrasting
background; and
2.3. The use of the key-operated locking device is
revokable by the building official for due cause.
3. Where egress doors are used in pairs, approved automatic
flush bolts shall be permitted to be used, provided
that the door leaf having the automatic flush bolts
has no doorknob or surface-mounted hardware.
4. Doors from individual dwelling or sleeping units of
Group R occupancies having an occupant load of 10 or
less are permitted to be equipped with a night latch,
dead bolt or security chain, provided such devices are
openable from the inside without the use of a key or
tool.
5. Fire doors after the minimum elevated temperature has
disabled the unlatching mechanism in accordance with
listed fire door test procedures.


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## ADAguy (May 18, 2018)

No mention of restrooms?
Doors equipped with both latching hardware and deadbolts must be openable with a single effort.


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## Michael.L (May 18, 2018)

steveray said:


> Technically....The deadbolt is not allowed...
> 
> 1008.1.9.3 Locks and latches. Locks and latches shall be
> permitted to prevent operation of doors where any of the following
> exists:


I have never seen a single-occupancy restroom that did not have a lock or a locking latch. How else is the entry door secured for privacy? Even water closet stalls have locks or latches on their doors.


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## Michael.L (May 18, 2018)

ADAguy said:


> Doors equipped with both latching hardware and deadbolts must be openable with a single effort.


My intention is to have a deadbolt, but no latching hardware.


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## steveray (May 18, 2018)

Michael.L said:


> I have never seen a single-occupancy restroom that did not have a lock or a locking latch. How else is the entry door secured for privacy? Even water closet stalls have locks or latches on their doors.



A privacy set that unlocks when you hit the lever.....


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## Michael.L (May 18, 2018)

steveray said:


> A privacy set that unlocks when you hit the lever.....


That's still a lock and a latch. It seems that we're getting wrapped up in semantics now.


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## steveray (May 18, 2018)

One motion to egress...

1008.1.9.5 Unlatching. The unlatching of any door or leaf
shall not require more than one operation.

No...We are getting wrapped up in code....


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## Michael.L (May 18, 2018)

steveray said:


> One motion to egress...
> 
> 1008.1.9.5 Unlatching. The unlatching of any door or leaf
> shall not require more than one operation.
> ...


That code does not say one motion to egress. It says one motion to unlatch a door. Opening the door would require an additional motion to push or pull the door open. (And technically, an additional additional motion is required to egress after opening the door.)


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## Sleepy (May 18, 2018)

steveray said:


> Technically....The deadbolt is not allowed...
> 
> 1008.1.9.3 Locks and latches. Locks and latches shall be
> permitted to prevent operation of doors where any of the following
> exists:...



1008.1.9.3 does not prohibit deadbolts.  It prohibits making doors in the means of egress inoperable, such as locking main entry doors so that a key would be needed for egress.  There is nothing wrong with a deadbolt on a toilet room door, provided it is readily released in accordance with 1008.1.9 (IBC-2012) which requires "Except as specifically permitted...readily openable from the egress side without the use of a key or special knowledge or effort."  and that the unlatching of the door "not require more than one operation."  Michael.L is correct in pointing out that the one operation refers to unlatching, not opening.  If it were otherwise every door would have panic hardware.


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## Sleepy (May 18, 2018)

Back to the original question.  It seems to me the crux is the word "latch" maybe has a slightly different meaning in the accessibility codes than in IBC chapter 10. 

I think you would have a hard time arguing that a deadbolt is not a latch in the context of IBC Chapter 10.  For reference refer to IBC-2012 paragraph 716.5.9.1 which requires ..."side hinged fire doors...shall be provided with an active latch bolt that will secure the door when it is closed."  So, it seems there is a distinction, in IBC, between a "latch" and an "active latch bolt".  It would be up to whoever is enforcing the applicable accessibility code (the courts via lawsuit) to decide if in that context "latch" means something other than it does in IBC.


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## mtlogcabin (May 18, 2018)

self latching hardware, deadbolt, slide latch they are all door hardware and have to operate within the requirements of the code

1008.1.9.1 Hardware.
Door handles, pulls, latches, locks and other operating devices on doors required to be accessible by Chapter 11 shall not require tight grasping, tight pinching or twisting of the wrist to operate.

A typical deadbolt will not meet this requirement so be careful and spec a specific brand and model that will

http://idighardware.com/2010/08/accessible-thumbturns/

Category: Accessibility,Locks & Keys — Lori @ 11:53 am Comments (4) 



At least once a month someone asks me whether it’s ok to use a deadbolt with a thumbturn on a door that is required to be accessible.  It took some digging to get a definitive answer, because the accessibility standards don’t specify a certain dimension that would be acceptable for the thumbturn.  The ADA guidelines and ICC A117.1 both state that hardware has to be operable without tight grasping, pinching, or twisting of the wrist, but that still leaves a lot up to interpretation.

_Here’s the section from the 2009 edition of ICC A117.1:_
_404.2.6 Door Hardware. Handles, pulls, latches, locks, and other operable parts on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, pinching, or twisting of the wrist to operate. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the floor. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides._ _EXCEPTION: Locks used only for security purposes and not used for normal operation shall not be required to comply with Section 404.2.6._

In my opinion, there are thumbturns that can be operated by someone with a disability, as long as the hardware is installed correctly (incorrect installation can cause binding and make the thumbturn difficult to turn).  I requested a staff opinion from the ICC, and I was told that if you can operate the thumbturn with the side of your palm, without grasping it with your fingers, it would be considered accessible.  I have also heard of code officials using the tip of a pencil to test the accessible operation of a thumbturn.

Many thumbturns are now designed so that they pivot from the end rather than the center, requiring less leverage to operate. The lock would also need to be mounted within the allowable range for operable hardware – typically 34 inches to 48 inches above the floor, and it would have to be the only lock on the door to meet the requirement that the door unlatch with one operation.  If the door was fire-rated, a deadbolt would not provide the necessary positive latching, so a lockset or fire exit hardware with an active latchbolt would be required for that application.

*Here are some thumbturns that are likely to be accessible if installed correctly:*





*Here are some thumbturns which may not be accessible (test operation with the side of palm):*


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## mark handler (May 18, 2018)

Common Lock Functions
ANSI F and E
http://amdoor.com/public_html/functions.htm

Two types of latches ANSI/BHMA A156.13
A lockset may incorporate a latchbolt, a deadbolt, or may integrate both into a single lockset.
*Latchbolt *
The latchbolt is spring-loaded, allowing the door to be closed without first retracting the bolt. In addition, the bolt may be fitted with a guardbolt, which is arranged to prevent the unwanted retraction of the latchbolt by an intruder; in this case the latchbolt is called a deadlocking latchbolt. There may be a provision on the inside handle to disable (lock) the outside handle from operating the latchbolt; this is referred to in the table below as the "inside locking mechanism". This mechanism may consist of a push button or turn button in the inside handle.
*Deadbolt *
A deadbolt may be projected (thrown) only once the door is in the closed position; it will resist being forcibly retracted once it is in its projected position, hence is known as a deadlock. If it is projected or retracted by a handle (rather than by a key), that handle is referred to in the table below as a "thumbturn".


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## ADAguy (May 18, 2018)

As you may or may not chose to see Michael, your issue is both a performance (for you to prove) and a prescriptive (specific code compliance required). Based on your choice of business location and the opinions of a number of experts on this Forum, maybe you should hire a consultant to present your concerns and justifications for alternate methods and means to the local AHJ.


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## Michael.L (May 18, 2018)

ADAguy said:


> As you may or may not chose to see Michael, your issue is both a performance (for you to prove) and a prescriptive (specific code compliance required). Based on your choice of business location and the opinions of a number of experts on this Forum, maybe you should hire a consultant to present your concerns and justifications for alternate methods and means to the local AHJ.


As I have stated in another thread, I will be hiring an architectural firm to draft the set of plans that will be submitted for approval. I also intend to have a code compliance consultant review the final design. If there is push-back from the AHJ on anything, I'll let the architect and code compliance consultant handle it.


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