# How many stories before elevator required?



## BayPointArchitect

I am thinking that a three story building does not require an elevator but a four story office building would require an elevator.  I've searched IBC and NFPA but can not seem to find anything that would require an elevator.  Once I introduce an elevator, there are several requirements.  But nothing to say that I must have an elevator - regardless of height and building area.

Thanks

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

AIA, NCARB, ICC, NCOA, CSI

ICC Plans Examiner


----------



## SBerg

Re: How many stories before elevator required?

Check Section 1007.2.1.

Accessibility.


----------



## Examiner

Re: How many stories before elevator required?

1007.2.1 is the section but you also need to know the proposed tenants.  ADA will kick in on the type of tenants.  I think the ICC/ANSI A117.1 also addresses type of tenants.

Basically 1007.2.1 will be a 5-story building if the level of Exit discharge is the 1st floor (ground).  The thing to remember its 4 or more stories above or below a level of exit discharge.  The level of exit discharge is a separate story.


----------



## north star

Re: How many stories before elevator required?

*SBerg,*

*Welcome to the Forum / Code Bulletin Board!   *  *     We haven't had too many responses from*

*the great state of Wisconsin.*


----------



## mtlogcabin

Re: How many stories before elevator required?

ACCESSIBLE ROUTE. A continuous, unobstructed path that complies with this chapter.

That can be a ramp or an elevator

1104.4 Multilevel buildings and facilities.

At least one accessible route shall connect each accessible level, including mezzanines, in multilevel buildings and facilities.

Exceptions:

1.	An accessible route is not required to stories and mezzanines above and below accessible levels that have an aggregate area of not more than 3,000 square feet (278.7 m2). This exception shall not apply to:1.1.	Multiple tenant facilities of Group M occupancies containing five or more tenant spaces;

1.2.	Levels containing offices of health care providers (Group B or I); or

1.3.	Passenger transportation facilities and airports (Group A-3 or B).

2.	In Group A, I, R and S occupancies, levels that do not contain accessible elements or other spaces required by Section 1107 or 1108 are not required to be served by an accessible route from an accessible level.

3.	In air traffic control towers, an accessible route is not required to serve the cab and the floor immediately below the cab.

4.	Where a two-story building or facility has one story with an occupant load of five or fewer persons that does not contain public use space, that story shall not be required to be connected by an accessible route to the story above or below.


----------



## jim baird

Re: How many stories before elevator required?

Our state has accessibility regs that trump ICC.  Those regs exempt buildings "under three stories", "unless the building is a shopping center".  Why they couldn't just say three or more stories I don't know.


----------



## brudgers

Re: How many stories before elevator required?



			
				jim baird said:
			
		

> Our state has accessibility regs that trump ICC.  Those regs exempt buildings "under three stories", "unless the building is a shopping center".  Why they couldn't just say three or more stories I don't know.


If it's a healthcare provider, ADAAG 1994 requires an elevator as well.


----------



## BayPointArchitect

Re: How many stories before elevator required?

After taking into consideration IBC 1007.2.1 and realizing that not all floors are required to be accessible, then I look at IBC 1104.4 to see the long list of exceptions.

Theoretically, I can design a 20 story sprinkled building with my elevator going directly from ground floor to fourth floor and providing access to no other floor.

Floor 20: Group "R2" Penthouse apartment (no elevator)

Floor 19: Group "S1" Mechanical & Storage

Floor 18: Group "R2" Residential apartments

Floor 17: Group "R2" Residential apartments

Floor 16: Group "R2" Residential apartments

Floor 15: Group "R2" Residential apartments

Floor 14: Group "R2" Residential apartments

Floor 13: Group "R2" Residential apartments

Floor 12: Group "R2" Residential apartments

Floor 11: Group "R2" Residential apartments

Floor 10: Group "R2" Residential apartments

Floor  9: Group "R2" Residential apartments

Floor  8: Group "R2" Residential apartments

Floor  7: Group "R2" Residential apartments

Floor  6: Group "R2" Residential apartments

Floor  5: Group "R2" Residential apartments (no elevator)

*Floor  4: Group "A2" Restaurant with elevator access*

Floor  3: Group "M"  Retail with five tenants (no elevator)

Floor  2: Group "M"  Retail with five tenants (no elevator)

Floor  1: Group "I2" Health care provider

My tenant living on the 20th floor would need to be very strong and healthy!

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

AIA, NCARB, ICC, NCOA, CSI

ICC Plans Examiner


----------



## SBerg

Re: How many stories before elevator required?

Well, the ICC/ANSI A117.1 and Section 1107.6.2.1.1 requires 2% (If more that 20 units total per structure) of the residential units to meet Type A accessibility. That means unless you can get all of the necessary units on the ground floor on an accessible route you will need an elevator.

This creates another issue. Emergency power is required for elevators used for emergency egress.

Section 3003.

Typically structures greater that 3 stories shall have elevators with emergency power.


----------



## Plans Approver

Re: How many stories before elevator required?

At least one elevator w/ standby power is required for buildings with a floor 75 feet above lowest fire equipment access (high rise 403.9). Granted, it is for fire department use, but, the tenants could pay extra rent to use it.  :evil:


----------



## khsmith55

Going to revive this thread and try to explain my building and interpretations. 2015 IBC; Four story apartment building, Non-elevator(?), 10 Units per floor (40 Units total), 1, 2, 3 and 4 bedroom units. The first floor will have 1-Type A Unit and 9-Type B Units dispersed among 1, 2, 3 and 4 bedroom units. My interpretation is that NO elevator is required under 1104.4, Ex. 2 and 1107.7.1, since  floors 2 thru 4 do not contain any accessible elements. *Scenario #2*; Increase the building to *FIVE* stories (an additional 10 Units, 50 Units total), still with *no elevator*. One might contend an elevator is needed at FIVE stories under 1009.2.1 "where a required _accessible _floor is four or more _stories _above or below a _level of exit discharge"_, my contention is 1009.2.1 IS NOT applicable because floors 2 thru 5 are NOT required accessible floors under 1104.4, Ex. 2 and 1107.7.1, am I correct?

Any and all input is appreciated.

Thanks in advance,
Ken


----------



## ADAguy

So, you deny "visitablity" to the friends and relatives of tenants and deny rental to seniors with mobility limitations too?


----------



## Yikes

ADAguy, I think khsmith55's original question was code-related, and it appears that no one is being denied the opportunity to rent accessible first floor units.  I know he welcomed "any and all input", it would be extra-helpful if you could provide a code or ADAS references that form the basis your concerns.


----------



## mtlogcabin

"visitability" is not a code issue or requirement


----------



## ADAguy

Though shalt Not:

§302. PROHIBITION OF DISCRIMINATION BY PUBLIC ACCOMMODATIONS.

§302(a) General Rule. No individual shall be discriminated against on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place of public accommodation by any person who owns, leases (or leases to), or operates a place of public accommodation.

§302(b) Construction.

§302(b)(1) General prohibition.

§302(b)(1)(A) Activities.

§302(b)(1)(A)(i) Denial of participation. It shall be discriminatory to subject an individual or class of individuals on the basis of a disability or disabilities of such individual or class, directly, or through contractual, licensing, or other arrangements, to a denial of the opportunity of the individual or class to participate in or benefit from the goods, services, facilities, privileges, advantages, or accommodations of an entity.

§302(b)(1)(A)(ii) Participation in unequal benefit. It shall be discriminatory to afford an individual or class of individuals, on the basis of a disability or disabilities of such individual or class, directly, or through contractual, licensing, or other arrangements with the opportunity to participate in or benefit from a good, service, facility, privilege, advantage, or accommodation that is not equal to that afforded to other individuals.

§302(b)(1)(A)(iii) Separate benefit. It shall be discriminatory to provide an individual or class of individuals, on the basis of a disability or disabilities of such individual or class, directly, or through contractual, licensing, or other arrangements with a good, service, facility, privilege, advantage, or accommodation that is different or separate from that provided to other individuals, unless such action is necessary to provide the individual or class of individuals with a good, service, facility, privilege, advantage, or accommodation, or other opportunity that is as effective as that provided to others.

§302(b)(1)(A)(iv) Individual or class of individuals. For purposes of clauses §302(b)(1)(A)(i) through §302(b)(1)(A)(iii) of this subparagraph, the term "individual or class of individuals" refers to the clients or customers of the covered public accommodation that enters into the contractual, licensing or other arrangement.

§302(b)(1)(B) Integrated settings. Goods, services, facilities, privileges, advantages, and accommodations shall be afforded to an individual with a disability in the most integrated setting appropriate to the needs of the individual.


----------



## BayPointArchitect

Thou shalt not impose ADA requirements on stuff that does not fit the definition of "PUBLIC ACCOMMODATIONS".

If you come visiting my apartment in a wheelchair and can not make it past the three steps leading up to my front door, how am I discriminating against those with mobility issues?  I might be so bold as to put up a sign next to the curb that reads, "If you are in a wheelchair and have come to visit me, don't bother getting out of your car.  This apartment is not accessible.  And I don't like people - regardless of their physical abilities or disabilities."

The recent post by KHSMITH55 proposes a five story building has included ten accessible units on the ground floor.  So tell me again why we need to make the satellite dish located on the roof wheelchair accessible?  By the way, your kitchen wall cabinets are too high for a wheelchair user to reach.  Better take those down before you are visited by someone in a wheelchair.

2010 ADA 36.401 (d) (2) Elevator exemption.  This section does not require the installation of an elevator in a facility that is less than three stories or has less than 3,000 square feet per story, except with respect to any facility that houses one or more of the following:
... shopping center ... health care provider ... public transportation ... airport

Regardless of whether-or-not there is a public heliport on the rooftop of this five story apartment building, I would say that the requirement of an elevator hinges on the difference between a "PRIVATE RENTALS" or "PUBLIC ACCOMODATIONS" or something that would otherwise fall within ADA / ANSI A117.1 scope.

But I could be wrong.  And it is possible to be too zealous with regards to ADA enforcement.  I watched a contractor take down kitchen wall cabinets after the inspector ordered them to be taken down during the final inspection of a new apartment.  Meanwhile, the soon-to-be tenant and old lady in a wheelchair cried, "Please don't take down the wall cabinets.  Those wall cabinets make my kitchen look like a normal kitchen."  Kitchen walls without upper cabinets look institutional.  But the inspector remained stoic and firm.  Don't be that guy.


----------



## ADAguy

BPA, you miss the point. Ability to enter into and visit with friends is one thing, ability to use upper cabinets is based on the type of units and is not required for all units.
Are those with disabilities to be/remain so isolated that they cannot be offered the opportunity to share in a friend's view?


----------



## BayPointArchitect

ADAguy,
Sorry but when you use legalistic phrases and words that include "discriminatory" and "though shalt not..." you sound like those inspectors that got lost in the difference between a thoughtful recommendation to spend $200,000 on an elevator versus a code-related requirement.  As code officials, our job is to enforce MINIMUM requirements.  During the course of reviewing plans, issuing a building permit, and performing inspections... we have ample opportunity to mention that building a three story apartment building without an elevator is just a dumb idea.

As for the upper wall cabinets that were removed, those were indeed located within a Type A accessible unit.  But to be "friendly" and considerate, my point is that the inspector should have listened to the end-user and allowed the upper wall cabinets to remain.


----------



## Rick18071

SBerg said:


> Well, the ICC/ANSI A117.1 and Section 1107.6.2.1.1 requires 2% (If more that 20 units total per structure) of the residential units to meet Type A accessibility. That means unless you can get all of the necessary units on the ground floor on an accessible route you will need an elevator.



Don't agree. An elevator should never be required for apartments for the above reason. 

1107.7.1 *Structures without elevator service.* Where no
elevator service is provided in a structure, only the dwelling
units and sleeping units that are located on stories indicated
in Sections 1107.7.1.1 and 1107.7.1.2 are required to
be Type A units and Type B units, respectively. The number
of Type A units shall be determined in accordance with
Section 1107.6.2.2.1.

1107.7.1.1 One story with Type B units required. At
least one story containing dwelling units or sleeping
units intended to be occupied as a residence shall be
provided with an accessible entrance from the exterior
of the structure and all units intended to be occupied as
a residence on that story shall be Type B units.

1107.7.1.2 Additional stories with Type B units. On
all other stories that have a building entrance in proximity
to arrival points intended to serve units on that
story, as indicated in Items 1 and 2, all dwelling units
and sleeping units intended to be occupied as a residence
served by that entrance on that story shall be
Type B units.
1. Where the slopes of the undisturbed site measured
between the planned entrance and all vehicular
or pedestrian arrival points within 50 feet (15
240 mm) of the planned entrance are 10 percent
or less, and
2. Where the slopes of the planned finished grade
measured between the entrance and all vehicular
or pedestrian arrival points within 50 feet (15 240
mm) of the planned entrance are 10 percent or
less.
Where no such arrival points are within 50 feet (15
240 mm) of the entrance, the closest arrival point shall
be used unless that arrival point serves the story
required by Section 1107.7.1.1.


----------



## Christian Nielsen

A friend just introduced me to this forum, because this is a question I have been asking for a long time.Other professionals think I am being stupid or obstinate...
I know the many things we have to do once we have an elevator in a residential building, but I have not found anywhere in the IBC where it says you MUST have an elevator at all. Having a 20-story building with no elevator would be VERY DUMB (and mean spirited?), but it doesn't seem to be illegal. After all, the law allows us to be stupid when we turn 14 and don't have to wear a bike helmet anymore...


----------



## mtlogcabin

1104.4 Multilevel buildings and facilities.
At least one accessible route shall connect each accessible level, including mezzanines, in multilevel buildings and facilities.

Basically an elevator is required to provide an accessible route to every story. 
The code provides exceptions for an accessible route. As a designer it is your job to know these exceptions and if they apply to your specific project and if an elevator will be required to meet the accessible route requirements.


----------



## classicT

*1104.4 Multistory Buildings and Facilities*
At least one _accessible route _shall connect each _accessible story _and _mezzanine _in multilevel buildings and _facilities_.
*Exceptions:*
1. An _accessible route _is not required to _stories _and _mezzanines _that have an aggregate area of not more than 3,000 square feet (278.7 m2) and are located above and below _accessible _levels. This exception shall not apply to:
1.1. Multiple tenant facilities of Group M occupancies containing five or more tenant spaces used for the sales or rental of goods and where at least one such tenant space is located on a floor level above or below the _accessible _levels;
1.2. _Stories _or _mezzanines _containing offices of health care providers (Group B or I);
1.3. Passenger transportation facilities and airports (Group A-3 or B); or
1.4. Government buildings.​2. _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.
3. In air traffic control towers, an _accessible route _is not required to serve the cab and the floor immediately below the cab.
4. Where a two-story building or facility has one _story _or _mezzanine _with an _occupant load _of five or fewer persons that does not contain _public use _space, that _story _or _mezzanine _shall not be required to be connected by an _accessible route _to the _story _above or below.​


----------



## e hilton

Obstinate?   Nobody on this forum is like that.


----------



## Yikes

Welcome, Christian!  
The IBC life-safety requirement for an elevators is mainly based on building height.
IBC 403.6.1 requires a fire service access elevator when there's an occupied floor more than 120 feet above the level of fire vehicle access.

As others have mentioned, portions of the accessibility codes will also require a path of travel between floors for use by building occupants, and that implies an elevator - - although it is theoretically possible to make a 20 story building with ramp access between each floor.


----------



## classicT

Yikes said:


> Welcome, Christian!
> The IBC life-safety requirement for an elevators is mainly based on building height.
> IBC 403.6.1 requires a fire service access elevator when there's an occupied floor more than 120 feet above the level of fire vehicle access.
> 
> As others have mentioned, portions of the accessibility codes will also require a path of travel between floors for use by building occupants, and that implies an elevator - - although it is theoretically possible to make a 20 story building with ramp access between each floor.


Ya know, I've suggested ramps a number of times when owners "really rather not have an elevator". Wish someone would try it, they all seem to go with an elevator though.


----------



## ADAguy

It is: logical, fast, allows for deliveries and is down right mean not to provide one but then the code may be the code and then it may not be.
As previously stated, it remains for the owner and its architect to address (and defend) providing or not providing one. Don't blame the inspector, blame the jurisdiction for not mandating one in their code.


----------



## e hilton

Ty J. said:


> Ya know, I've suggested ramps a number of times when owners "really rather not have an elevator". Wish someone would try it, they all seem to go with an elevator though.


Is there a limit to a ramp?   Could it be practical for getting from the ground to the third floor?   Say its a 20 ft vertical change.   At 1:12 thats going to need 240 ft of ramp, plus landings.


----------



## classicT

e hilton said:


> Is there a limit to a ramp?   Could it be practical for getting from the ground to the third floor?   Say its a 20 ft vertical change.   At 1:12 thats going to need 240 ft of ramp, plus landings.


Oh, I agree that it is impractical. I just wanna see someone try it to see how they approach the ramps/landings.


----------



## ADAguy

See Gugginheim in NY, Frank did it. Lots of walking, but little maintenance required.


----------



## Builder Bob

Welcome - Generally Rule of Thumb was a maximum of four stories without an elevator. I believe this is designer's choice. Look at 1009.2 and see if this makes a different spin for your question.

Welcome -


----------



## BayPointArchitect

Christian Nielsen

Let me be the fourth of fifth to welcome you to the forum.

When I first posted this question ten years ago, my thinking was a little different that it is today.

And it is still an interesting question.

My current thinking is based on the exceptions provided within the 2010 ADA.

Below is an answer shamelessly stolen from Edward Zwilling.  He puts my thoughts into words better than I could ever do.

I've been frequently asked about elevators recently.  Not every new construction multi-story building is actually required to have an elevator by the ADA.  There are certain exemptions for elevators.  The regulation explaining where the ADA does NOT require elevators in new construction is located at 28 C.F.R. 36.401(d) (and is commonly referred to as the "elevator exemption").  In short an elevator is NOT required:

In a facility with less than three stories or which has less than 3000 square feet per story.

This exemption is not absolute and certain types of accommodations or services are nonetheless required to provide an elevator--even if they have less than three stories or less than 3000 square feet per story.  There are a few types of facilities that would still be required to have an elevator, as follows:

1.  A shopping center or shopping mall (provided sales and rental establishments are not limited to the ground floor only);

2.  A professional office of a health care provider (provided such offices are not limited to the ground floor only);

3.  A facility that houses a public transportation station, terminal or depot or an airport passenger terminal.

In existing facilities that do not have elevators, but would require them under the new construction guidelines of the ADA had they been constructed more recently, the question becomes whether it is readily achievable to provide an elevator.  (See my blog entry entitled What does "Readily Achievable" mean? if you don't already know).

Where it isn't readily achievable to provide an elevator, then the question becomes what reasonable accommodations can be afforded.  For example, in a bar with a second floor performance stage, perhaps the stage could be relocated to the ground floor.  Or, perhaps closed circuit television screens could be provided on the ground floor so that the show could still be seen (and not only heard) on the ground floor in cases where the ground floor lacked the necessary room for the stage.

In any event, just because a facility may be exempt from the requirement to provide an elevator does not mean that the facility is also exempt from other ADA requirements on upper floors.  To the contrary, the elevator exemption specifically provides, "The elevator exemption set forth in this paragraph (d) does not obviate or limit, in any way the obligation to comply with the other accessibility requirements established in paragraph (a) of this section."  In other words, but for the lack of an elevator, facilities with multiple stories that meet the elevator exemption, must still be designed and constructed to be readily accessible to and usable by individuals with disabilities in all other regards.


----------



## Paul Sweet

IBC 1104.4 is tougher than ADA.  ADA allows multiple upper floors of 3000 SF or less, while IBC 1104.4 limits you to 3000 SF aggregate for all upper floors.


----------



## Christian Nielsen

Thanks, all! Good group to be in.
I admit to being obstinate... But, while I would advocate for ANY building more than one story to have an elevator (my own "rule of thumb"), it seems to me it is NOT required in multi-family (or even hotel?) construction, as long as there are some accessible units on the ground floor. When the IBC (or ADA?) say "At least one accessible route shall connect each accessible level, including mezzanines, in multilevel buildings and facilities", is is the presence of the elevator that makes those levels "accessible" in the first place. If they are not "accessible", the accessible route is not required. So, if you have an elevator, you need an elevator. If you don't, you don't.  Of course this assumes there are no "public accommodations" in those upper floors.  I did find the requirement for a SERVICE elevator (for the fire department) when a floor is more than 120' above fire vehicle access. 
Obstinately yours, Christian.


----------



## Rick18071

The code is just the minimum and cheapest way to build it but not the smartest way to build it. Not to many people would be interested in moving into a 20 story apartment with no elevator.


----------



## ADAguy

BayPointArchitect said:


> Christian Nielsen
> 
> Let me be the fourth of fifth to welcome you to the forum.
> 
> When I first posted this question ten years ago, my thinking was a little different that it is today.
> 
> And it is still an interesting question.
> 
> My current thinking is based on the exceptions provided within the 2010 ADA.
> 
> Below is an answer shamelessly stolen from Edward Zwilling.  He puts my thoughts into words better than I could ever do.
> 
> I've been frequently asked about elevators recently.  Not every new construction multi-story building is actually required to have an elevator by the ADA.  There are certain exemptions for elevators.  The regulation explaining where the ADA does NOT require elevators in new construction is located at 28 C.F.R. 36.401(d) (and is commonly referred to as the "elevator exemption").  In short an elevator is NOT required:
> 
> In a facility with less than three stories or which has less than 3000 square feet per story.
> 
> This exemption is not absolute and certain types of accommodations or services are nonetheless required to provide an elevator--even if they have less than three stories or less than 3000 square feet per story.  There are a few types of facilities that would still be required to have an elevator, as follows:
> 
> 1.  A shopping center or shopping mall (provided sales and rental establishments are not limited to the ground floor only);
> 
> 2.  A professional office of a health care provider (provided such offices are not limited to the ground floor only);
> 
> 3.  A facility that houses a public transportation station, terminal or depot or an airport passenger terminal.
> 
> In existing facilities that do not have elevators, but would require them under the new construction guidelines of the ADA had they been constructed more recently, the question becomes whether it is readily achievable to provide an elevator.  (See my blog entry entitled What does "Readily Achievable" mean? if you don't already know).
> 
> Where it isn't readily achievable to provide an elevator, then the question becomes what reasonable accommodations can be afforded.  For example, in a bar with a second floor performance stage, perhaps the stage could be relocated to the ground floor.  Or, perhaps closed circuit television screens could be provided on the ground floor so that the show could still be seen (and not only heard) on the ground floor in cases where the ground floor lacked the necessary room for the stage.
> 
> In any event, just because a facility may be exempt from the requirement to provide an elevator does not mean that the facility is also exempt from other ADA requirements on upper floors.  To the contrary, the elevator exemption specifically provides, "The elevator exemption set forth in this paragraph (d) does not obviate or limit, in any way the obligation to comply with the other accessibility requirements established in paragraph (a) of this section."  In other words, but for the lack of an elevator, facilities with multiple stories that meet the elevator exemption, must still be designed and constructed to be readily accessible to and usable by individuals with disabilities in all other regards.



Your bar quote is interesting, I found that exact same condition in a recently remodeled bar in Sacramento. You cannot get the same contact experience via a screen that being on the same level provides. It is there fore a discrimination not to have placed the stage on the ground floor.


----------



## Mike Schempdoll

Properly configured stairs are part of an accessible means of egress. There are a lot of 4 story multi family housing projects with elevators that are not on emergency power. The elevator is provided for the convenience of the resident, but is not part of the accessible means of egress. Assuming the building is NFPA 13 sprinklered, the stairs towers do not have areas of refuge, and the elevator "lobby" has the required call box. When the power fails, the person in a wheel chair calls down to the fire department from the elevator lobby and then goes to a stair tower to wait to be rescued.


----------

