# Single 5" Step in Portion of Existing Building - ramp required? (California)



## Cali_Code_Architect (Dec 9, 2021)

There is a single 5" step for a portion of the existing commercial building. The area is about a third of the floor area but not considered a primary function. Are there any exceptions for providing a ramp for the single step? The work done in this inaccessible portion is limited to structural repair and skylights.

I see there are a few exceptions. Notably the following:

(CBC 1003.5) Elevation Change A stair with a single riser or with two risers and a tread is permitted at locations not required to be accessible by Chapter 11A or 11B
(CEBC 305.6) The altered element or space is not required to be on an accessible route, unless required by Section 305.7.


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## MtnArch (Dec 9, 2021)

You could always ask for a Technical Infeasibility from the CBO.


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## e hilton (Dec 9, 2021)

Would a ramp help with moving equipment and supplies?


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## tbz (Dec 10, 2021)

Cali_Code_Architect said:


> There is a single 5" step for a portion of the existing commercial building. The area is about a third of the floor area but not considered a primary function. Are there any exceptions for providing a ramp for the single step? The work done in this inaccessible portion is limited to structural repair and skylights.


The change in elevation is less than 6-inches thus a ramp surface within the 1:12 is not required to have handrails.

Also, since this is pre-existing, does CA have an exception for the 1:8 for existing environments for a ramp.

The change in elevation is over 4" so it's between the 4:7 riser requirements, and as thus is under 30 inches so no guards required.

Without knowing the sq-footage we are talking about here; I would say find a place to drop in the slanted surface and look into a way to highlight the edge of the drop anyplace someone would walk off to the lower level.


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## e hilton (Dec 10, 2021)

tbz said:


> The change in elevation is less than 6-inches thus a ramp surface within the 1:12 is not required to have handrails.
> 
> Also, since this is pre-existing, does CA have an exception for the 1:8 for existing environments for a ramp.
> 
> ...


I think you missed his question.  You are answering about guardrails ... he is trying to avoid the ramp itself.


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## Cali_Code_Architect (Dec 10, 2021)

e hilton said:


> Would a ramp help with moving equipment and supplies?


There's another shutter doorway into the inaccessible space from the street, so no. I'm trying not to count the doorway as an exit for egress since it is a shutter, thereby requiring egress from the non-accessible space to down the single step.


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## Cali_Code_Architect (Dec 10, 2021)

e hilton said:


> I think you missed his question.  You are answering about guardrails ... he is trying to avoid the ramp itself.


Correct. The ramp would be right in the middle of a circulation path for a 1000sf space, there's not much room for adjustment. The non-accessible space is just over 1000sf. The non-accessible area has an existing shutter that gives it access to the street for any special occasions or deliveries. But it wouldn't be considered an egress exit.


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## bill1952 (Dec 10, 2021)

If you dont make the raised area accessible, are there any features or amenities on the inaccesible level that are not on the accesible?  Would the inaccesible area prevent an employer from hiring a person with a disability who could otherwise do the job?


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## Cali_Code_Architect (Dec 10, 2021)

bill1952 said:


> If you dont make the raised area accessible, are there any features or amenities on the inaccesible level that are not on the accesible?  Would the inaccesible area prevent an employer from hiring a person with a disability who could otherwise do the job?


There is an existing kitchenette, however a slop sink is provided for in the accessible area.

The inaccessible area can be accessed from the street by a separate shutter door when needed however.


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## tbz (Dec 10, 2021)

e hilton said:


> I think you missed his question.  You are answering about guardrails ... he is trying to avoid the ramp itself.


E.H. didn't miss the O.P. just going down the laundry list checking off boxes noting that a low drop without some kind of visible clue might want to be looked at.

to the OP; Bills point is are the same amenities in both areas or does the upper level have better amenities than the accessible level.

And the way I am reading your response please correct me if I am wrong, is the upper level has better amenities, and can be accessed by leaving the building and coming back in another entry, but now how do they get back to the other area, back outside?

1,000 square feet I am envisioning is 20ft by 50ft the ramp is 3x5 or 15sqft to ascend up, with straight approaches you might lose another 6-sqft, 50-sqft if you need open turning radius top and bottom, so 65sqft / 1000 = 6.5% if you only pull the space from upper level.

(Edit) Just one additional note, in the OP, you note the area in question is 1/3 of the floor space, and the floor space in question is 1,000sqft, thus total floor space is 3,000 sqft, I am guessing this by the OP and post #7, thus 65sqft is only 1.5% of the total space, though I know you are trying not to install the ramped surface, it seems odd with the amount of floor space noted, that this small ramp is going to be hardship to place within the structure.

I am all for not having to do something that has not been in place probably for decades, but it's Cali, seems something this small to remove a barrier and be more compliant would be a benefit.  I could be wrong though.


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## bill1952 (Dec 10, 2021)

Too much about building occupancy and use unknown but I too like tbz was having trouble with a 3'x 5' ramp being a big deal.  Restroom?  Being able to enter and use toilet are a basic of accessibility.


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## e hilton (Dec 12, 2021)

Cali_Code_Architect said:


> There is an existing kitchenette, however a slop sink is provided for in the accessible area.


Slop sink doesn’t sound “equal” to a kitchenette.  In fact it sounds derogatory.


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## JPohling (Dec 13, 2021)

There is a CA exiting requirement 1003.5 that restricts exiting across elevation changes like this.  Take a look.  you may need a ramp along the exit path.


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## Rick18071 (Dec 14, 2021)

Don't know about CA but the IEBC would not require the step to be changed for structural repair and skylights unless the structural repair was done on this step.


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## Yikes (Dec 14, 2021)

Rick18071 said:


> Don't know about CA but the IEBC would not require the step to be changed for structural repair and skylights unless the structural repair was done on this step.


The O.P. didn't say it was in California, but let's assume so for sake of discussion.
CBC 11B-202.4 has "Path of travel requirements in alterations, additions, and structural repairs".  
If there are existing skylights being repaired, it wouldn't trigger this, but new skylights would; and the structural repair would.  

The O.P. didn't say the estimated cost of the work that triggers path-of-travel, but let's assume for the moment the adjusted construction cost is less than $172,418.
The likely applicable code would be CBC 11B-202.4 exception #8, with 20% of the cost going towards accessibility upgrades, prioritized as noted:


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## tbz (Dec 14, 2021)

Yikes,

Re-Read the OP,


Cali_Code_Architect said:


> I see there are a few exceptions. Notably the following:
> 
> (CBC 1003.5) Elevation Change A stair with a single riser or with two risers and a tread is permitted at locations not required to be accessible by Chapter 11A or 11B
> (CEBC 305.6) The altered element or space is not required to be on an accessible route, unless required by Section 305.7.


The OP does a direct ref: to the CBC 1003.5 & CEBC 305.6

Oh, and re-read the title of the posting, I think it ends with noting (California)

But your points with assuming are on point.

;>)


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## JPohling (Dec 14, 2021)

The project is in CA,  This is an exiting issue not an accessibility issue. Not enough is known about the occupancy or use in this area, but I assume it will need to be accessible and that will eliminate your exception to CBC 1003.5.  This is primarily a requirement due to the trip hazard of a single riser along the MOE.  Cost of construction would not come into play.


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## Rick18071 (Dec 14, 2021)

Yikes said:


> The O.P. didn't say it was in California, but let's assume so for sake of discussion.
> CBC 11B-202.4 has "Path of travel requirements in alterations, additions, and structural repairs".
> If there are existing skylights being repaired, it wouldn't trigger this, but new skylights would; and the structural repair would.


Interesting that CA is a lot different the the IEBC where it would just fall under "repairs" and would not trigger any accessibility or means of egress requirements.

2015 IEBC:

*REPAIR.* The reconstruction or renewal of any part of an
existing building for the purpose of its maintenance or to correct
damage.

404.1 General. Buildings and structures, and parts thereof,
shall be repaired in compliance with Sections 401.2 and 404.
Work on nondamaged components that is necessary for the
required repair of damaged components shall be considered
part of the repair and shall not be subject to the requirements
for alterations in this chapter. Routine maintenance required
by Section 401.2, ordinary repairs exempt from permit in
accordance with Section 105.2, and abatement of wear due to
normal service conditions shall not be subject to the requirements
for repairs in this section.


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## Cali_Code_Architect (Dec 14, 2021)

Thank you for the responses. It seems like a 1:12 ramp or possibly another accessible entrance into the space would be required. The construction costs are over the threshold and structural upgrades are considered alterations, not repair. Also the new skylights make the space part of the scope of work.



JPohling said:


> The project is in CA,  This is an exiting issue not an accessibility issue. Not enough is known about the occupancy or use in this area, but I assume it will need to be accessible and that will eliminate your exception to CBC 1003.5.  This is primarily a requirement due to the trip hazard of a single riser along the MOE.  Cost of construction would not come into play.


 
This is a helpful distinction, exiting vs accessibility. Although wondering how it resolves with the following:


CEBC 305.6 Alteration: exception 2. Accessible means of egress required by Chapter 10 of the International Building Code are not required to be provided in existing facilities.

So no accessible means of egress required (assuming 1009 Accessible Means of Egress), however MOE 1003.5 Elevation Change would still apply?


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## Yikes (Dec 14, 2021)

Cali_Code_Architect, CEBC Chapter 3 (which includes CEBC 305.6) was never adopted by the Division of the State Architect for Access Compliance.  See the adoption table by clicking here.


This means you must instead follow CBC 11B-202.4 for alterations and structural repairs.
Rick18071, in California a non-structural repair would not trigger 11B-202.4.  Only _structural_ repairs or alterations or additions trigger it.

Also, I like to remind everybody that even when the proposed work doesn't trigger CBC accessible path of travel, you still may be responsible to provide it under ADA, which is enforced by civil courts, not by the local building department.

Note that if it is not feasible to provide a ramp or accessible path to the door, you can spend your 20% accessibility budget on other elements such as level hardware on the door, accessible restrooms serving the area, etc.


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## Cali_Code_Architect (Dec 14, 2021)

Yikes said:


> Cali_Code_Architect, CEBC Chapter 3 (which includes CEBC 305.6) was never adopted by the Division of the State Architect for Access Compliance.  See the adoption table by clicking here.


Ah, thank you! I wasn't even reviewing the adoption tables.  I wrongly assumed up.codes compiled them based on jurisdiction.


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## JPohling (Dec 14, 2021)

The ramp in this situation is not for accessibility.  it is to eliminate tripping on a single step when exiting.  This is an exiting issue.


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## Yikes (Dec 14, 2021)

JPohling said:


> The ramp in this situation is not for accessibility.  it is to eliminate tripping on a single step when exiting.  This is an exiting issue.


Is it possible that the ramp might be needed for accessibility (11B-202.4), and also might be needed for exiting (unless it meets one of the exceptions in 1003.5)?  The two aren't necessarily exclusive.


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## JPohling (Dec 15, 2021)

Yikes said:


> Is it possible that the ramp might be needed for accessibility (11B-202.4), and also might be needed for exiting (unless it meets one of the exceptions in 1003.5)?  The two aren't necessarily exclusive.
> 
> View attachment 8432


We are unsure of the use of the space so determining accessibility is impossible, but you will need to exit from the area and you cannot exit across a single riser.


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## Yikes (Dec 15, 2021)

JPohling said:


> ...you cannot exit across a single riser.


I think 1003.5 exceptions #1 and 2 describe specific instances when exiting is allowed across a single riser.


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## JPohling (Dec 15, 2021)

Yikes said:


> I think 1003.5 exceptions #1 and 2 describe specific instances when exiting is allowed across a single riser.


Absolutely they do.  My assumption is not any of the uses in exeption #1. and not enough info to determine #2


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## ADAguy (Jan 9, 2022)

Long discussion with many points but if I can enter a space I must be able to exit it. Required exits must be accessible. 

If the shutter opening is for deliveries only is considered a pass through window then maybe you might have an out.


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## Jean Tessmer-HI (Jan 19, 2022)

Cali_Code_Architect said:


> There is a single 5" step for a portion of the existing commercial building. The area is about a third of the floor area but not considered a primary function. Are there any exceptions for providing a ramp for the single step? The work done in this inaccessible portion is limited to structural repair and skylights.
> 
> I see there are a few exceptions. Notably the following:
> 
> ...


Cali you need to look at the ADA.  The DOJ will be the ones going out there to find violations.  Or some attorney who knows someone with a disability who could not get into that portion of the building with the step.  If that portion of the building with the step prevents someone in a wheelchair from entering a public accommodation that other folks can, you will be in violation of the *ADA.*  California inspectors are not going to cite you.  I hope their plan reviewers do ask for changes to comply.  Existing buildings are also under the Barrier Removal section of the ADA.


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