# Accessibility of two-story townhouses



## Warthog (Mar 8, 2021)

I'm working on a site where we are proposing 14 townhouses, 6 are 3-unit two-story buildings and 8 are 4-unit two story buildings. In each unit there is one bedroom on the ground floor, with 2 or 3 more bedrooms on the second floor.

Where I'm getting tripped up is the IRC says "IRC Section 320.1, where there are four or more dwelling units or sleeping units in a single structure, the provisions of Chapter 11 of the IBC for group R-3 shall apply." Group R-3 requirements appear to say that all of my 4 unit townhouses would need to be Type B units. 

There is an exemption for Multi-story units without an elevator (we will not have elevators). I'm curious if the ground floor bedrooms disqualify us from this exemption. Also what are the requirements for the 3-unit townhouses? There are no lot lines separating the units. 

Thanks in advance for your guys' help. This is my first time diving into the IBC and I'm a little turned around.


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## cda (Mar 8, 2021)

Welcome

Accessibility not my area

Have never seen a townhome, being accessible

Give a few days for great answers


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## mtlogcabin (Mar 9, 2021)

The project also will fall under the Fair Housing requirements. The most restrictive will apply to the design


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## mp25 (Mar 9, 2021)

If you have access to IRC commentary, they do give a nice explanation of how this specific section applies to a typical townhouse. It sounds like you are on the right track.

Also, to my knowledge, certain versions of the IBC are considered a safe harbor for FHA.


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## Joe.B (Mar 10, 2021)

Separate lots for each building/unit? Or one big lot?


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## Warthog (Mar 17, 2021)

One big lot.


Joe.B said:


> Separate lots for each building/unit? Or one big lot?


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## Joe.B (Mar 17, 2021)

Warthog said:


> One big lot.


It is my understanding that a project like this you would be required to use IBC, not the IRC, for accessibility and other conditions that apply to the whole project. You may be able to use some IRC allowances within individual units though, check with the AHJ.


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## Yikes (Mar 17, 2021)

Welcome, Warthog.  Since codes vary among different regions, it is helpful to know:
1.  What area/city is the project located in? (I can't assume it's Washington, even if you are from Washington.)
2.  What code(s) does that jurisdiction say is applicable to the project?
3.  Specific to housing: are there any public funds being used to either construct or operate the project, such that you might be subject to Federal ADA in addition to your local codes?


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## mark handler (Mar 18, 2021)

Warthog said:


> I'm working on a site where we are proposing 14 townhouses, 6 are 3-unit two-story buildings and 8 are 4-unit two story buildings. In each unit there is one bedroom on the ground floor, with 2 or 3 more bedrooms on the second floor.
> 
> Where I'm getting tripped up is the IRC says "IRC Section 320.1, where there are four or more dwelling units or sleeping units in a single structure, the provisions of Chapter 11 of the IBC for group R-3 shall apply." Group R-3 requirements appear to say that all of my 4 unit townhouses would need to be Type B units.
> 
> ...


*See IBC TABLE 1107.6.1.1 and 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.*


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## Chrisjoneill (Apr 26, 2021)

not to hijack this but in the same vein...1107.7.2 ibc 2015 states that in multistory units  with elevator service to one floor  _"shall comply with the requirements for a type b unit and where provided within the unit a living area, a kitchen and a toilet facility" _by toilet facility means it only needs to be a powder room and does not need a bathing facility such as a shower/tub? am i correct?


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## Rick18071 (Apr 26, 2021)

2015 IBC:
1107.6.3 Group R-3. In Group R-3 occupancies where
there are four or more dwelling units or sleeping units
intended to be occupied as a residence in a single structure,
every dwelling unit and sleeping unit intended to be
occupied as a residence shall be a Type B unit. Bedrooms
within congregate living facilities shall be counted as
sleeping units for the purpose of determining the number
of units.
Exception: The number of Type B units is permitted to
be reduced in accordance with Section 1107.7.

Bathing facilities must be accessible. ICC/ANSI A117.1-2006 has two options for accessible toilet and bathing rooms for type B units. Ether all plumbing fixtures are accessible or only one of each type depending where they are.


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## SH225 (Apr 27, 2021)

Chrisjoneill said:


> not to hijack this but in the same vein...1107.7.2 ibc 2015 states that in multistory units  with elevator service to one floor  _"shall comply with the requirements for a type b unit and where provided within the unit a living area, a kitchen and a toilet facility" _by toilet facility means it only needs to be a powder room and does not need a bathing facility such as a shower/tub? am i correct?


You can see in ANSI A117.1-2009 1004.11 the section title refers to toilet and bathing facilities, which implies they are not entirely the same. Exception 1 refers to toilet rooms with only a lavatory and a water closet. The definition of toilet facility in the IPC mentions only a water closet and lavatory. If the code required a bathing facility here it would be very odd to not say that.


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## Chrisjoneill (May 4, 2021)

SH225 said:


> You can see in ANSI A117.1-2009 1004.11 the section title refers to toilet and bathing facilities, which implies they are not entirely the same. Exception 1 refers to toilet rooms with only a lavatory and a water closet. The definition of toilet facility in the IPC mentions only a water closet and lavatory. If the code required a bathing facility here it would be very odd to not say that.


yes, my thoughts exactly...always like to have someone confirm im not losing my mind


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