# Marking non-accessible entrances



## e hilton (Jan 30, 2021)

We are on a program to get all of our facilities 100% compliant with ADA requirements.  Everything.  To the point that, for example, if the toilet is 1/2” too far from the side wall ... we move it.  The architectural firm that was hired to do the inspections went at it with great fervor. I have a line item that shows the customer counter which is supposed to be 28 to 34” is actually 34.125”.  Gonna move that too.  

But i need help with something, looking for a solution. Think of this as a coffee shop with outdoor seating. We’re on a corner, so entrances on 2 sides, all are double 3-0 storefront doors. (And we are replacing many of those doors because the bottom rail is only 8” high and code calls for a smooth surface 10” high). The one pair around the corner is accessible, and the far pair on the front is accessible. Problem is 3 pair between them. The survey report says “60% of all public entrances shall be accessible per 2014 FAC 206.4.1”.

We never intended the middle 3 pair to be part of the egress path, they lead from the inside seating area to outside tables.   I was reading a recent discussion here that said something about putting a sign on doors to label them as “not accessible”.   That solves my problem, i think.  Question is ... where do i find the requirements for that sign?   Like do the letters have to be 2”.  Labelled both sides.  50 to 60” aff.  Etc. 

We don’t need any of these 3 pair for meeting egress requirements.


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## ADAguy (Jan 30, 2021)

Can those with disabilities enter the outside area from the other pairs of doors?
Can you see them from the center pair?
Sigh should also have a DIRECTIONAL ARROW, IT IS CONSIDERED AN INFORMATIONAL SIGN.


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## e hilton (Jan 30, 2021)

The outside seating area has free access to the sidewalk, there are no handrails or steps, so you could walk out either pair of end doors and get to the tables that way.  Other than the bottom rail being 8” instead of 10”, we’re not sure why the architect declared these to be non-accessible.  For all other items they give exact dimension, or exact slopes, etc.  Not here, they just say 60% of public doors need to be accessible.


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## mark handler (Feb 1, 2021)

*If the building is existing I would not require 60% accessible.*


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## ADAguy (Feb 1, 2021)

no but each door provided must comply with min. door requirements. 33" 10" operable hardware manuvering space


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## e hilton (Feb 1, 2021)

The tenant space was a massive remodel, not going to be much opportunity to claim existing conditions.  

But ... I found this. Section 216.6 Entrances. (second sentence) _Directional signs complying with 703.5 that indicate the location of the nearest entrance complying with 404 shall be provided at entrances that do not comply with 404.  _

We have the required number of proper egress doors, so the 3 pair in question are not needed.  All 5 entrances are identical, a pair of 3-0 storefront with closers, correct thresholds, panic bars etc.  The consultants report is normally very detailed with regard to deviations from requirements (see OP about 1/8” too high) ... except for these 3 entrances.  Here, in typical auditor style, they tell us they are not compliant but don’t say why.


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## mark handler (Feb 1, 2021)

ADAguy said:


> no but each door provided must comply with min. door requirements. 33" 10" operable hardware manuvering space


CBC 1010.1 Doors Means of egress doors shall meet the requirements of this section.


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## e hilton (Feb 1, 2021)

The egress plan requires one exit with 33” width and one exit with 66” width, separated by 53’-5” etc.   We have one single door at the rear and 2 pair of double doors at the front that meet all egress requirements, plus these 3 pair of doors.  So there’s no question we meet code.


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## ADAguy (Feb 1, 2021)

This about ADA compliance in addition to code.


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## e hilton (Feb 1, 2021)

ADAguy said:


> This about ADA compliance in addition to code.


You are correct.  Refer to the original post: the auditors noted that 60% of public entrances have to be accessible.   That’s the problem, I’m trying to solve, not a building code item.


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## steveray (Feb 2, 2021)

A "gang" entrance I would likely count as one.....Not each door individually....That would be like saying you could not have a stair and a ramp serving the same door because only 50% would be accessible....I would consider signing the non doors....


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## Sifu (Feb 2, 2021)

Did the massive remodel alter the doors?  If not I think IEBC would probably not require they be accessible in lieu of signage to the accessible doors.

305.8 Scoping for alterations. The provisions of Sections
305.8.1 through 305.8.15 shall apply to alterations to existing
buildings and facilities.
305.8.1 Entrances. Where an alteration includes alterations
to an entrance that is not accessible, and the facility
has an accessible entrance, the altered entrance is not
required to be accessible unless required by Section 305.7.
Signs complying with Section 1111 of the International
Building Code shall be provided.


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## e hilton (Feb 2, 2021)

Massive remodel ... hah!  It was an old single story building, the original idea was to demo all but 2 and a half exterior walls and get grandfathered under the old code.  Sh!t happened, two of those walls collapsed in a storm so essentially the building is new.  Sidewalk on 2 sides and city parking lot/driveway on third side are existing.


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## Sifu (Feb 2, 2021)

I am with steveray.  If the users of the patio have access from a few feet away, with no restrictions I think requiring them all to be accessible would be a bridge too far.  The problem is now a survey has been done, an ambulance chaser can use it against you.  Find out exactly why the doors aren't accessible.  If it is just the bottoms, I might take that chance.  If it is just the bottom, is there a retrofit available?  Maybe the resident door expert knows.   www.idighardware.com.


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## steveray (Feb 2, 2021)

I would glue a piece of wood or lexan to recess above the bottom rail....FIXED!


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## ADAguy (Feb 2, 2021)

easily remiedied


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## e hilton (Feb 2, 2021)

Sifu ... problem is the auditors can’t or won’t give additional details.  We are already planning to replace the doors that we know are part of the accessible path, and maybe thats what we do here.  We had considered adding a piece of anodized aluminum to raise the top of the rail, but decided it would look like a piece of aluminum added on, so just replace the who door.  $11,000 per pair.  

The comment about the ambulance chaser is on oir minds, thats why we are going through the process.  So far, as gar as i know, we have not has a problem, trying to be proactive.  One hope is if we identify 50 items and correct 48 maybe we will get a pass on the 2 difficult to fix items.  As long as they are minor.  Its a gamble.


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## Sifu (Feb 3, 2021)

e hilton said:


> Sifu ... problem is the auditors can’t or won’t give additional details.  We are already planning to replace the doors that we know are part of the accessible path, and maybe thats what we do here.  We had considered adding a piece of anodized aluminum to raise the top of the rail, but decided it would look like a piece of aluminum added on, so just replace the who door.  $11,000 per pair.
> 
> The comment about the ambulance chaser is on oir minds, thats why we are going through the process.  So far, as gar as i know, we have not has a problem, trying to be proactive.  One hope is if we identify 50 items and correct 48 maybe we will get a pass on the 2 difficult to fix items.  As long as they are minor.  Its a gamble.


Not sure what capacity you are involved in this but whoever hired the auditor should demand details.  If I take my car to the mechanic and pay him to assess problems, it is not enough that they say it is broken.  The need to tell you why it's broken, otherwise how can the problem be fixed?  But, if you have looked at all angles and the bottom is the only thing then that is about the best you can do if they can't enlighten you.  If that is the only issue you can find then it is just down to a simple decision: spend 11,000/door, or employ a field modification.  Based on some of the other examples you gave, my guess is somebody is going to write a big check.  Some people get paid to make those decisions.  I am not one of them.


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## ADAguy (Feb 3, 2021)

And to think he isn't even in CA or FL? When did Virginia become the new land of opportunity?


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## e hilton (Feb 3, 2021)

It’s $11k per pair of doors.  And the building in question is in the Miami area.  My role is construction project manager, i fix what they identify.  The survey company generally provided detailed summaries of the deficiencies at all locations ... except this one set of doors.


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## steveray (Feb 4, 2021)

From the commentary...


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## ADAguy (Feb 4, 2021)

Aha! the rest of the story, its in FL, just as bad as CA


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## Bryant (Feb 4, 2021)

ADAguy said:


> And to think he isn't even in CA or FL? When did Virginia become the new land of opportunity?


Hey now, the old dominion remains blue to its rotten core. Some locales take third party reviews, but we like live action here in the middle of the state


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## e hilton (Feb 4, 2021)

Steve ... Where do i find the commentary?


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## Sifu (Feb 4, 2021)

I understand a little better now.  Your OP made me think you were part of an AHJ and the AHJ was undergoing an audit (I have been through that so I guess I knee-jerked my way to that assumption).  Doesn't really change the opinion though.  They have been paid to tell you what needs fixed, if they don't give you enough info how can you fix it?


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## steveray (Feb 4, 2021)

e hilton said:


> Steve ... Where do i find the commentary?


On my K drive.....I don't think you can get it for free, I bought it from ICC


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## e hilton (Feb 4, 2021)

steveray said:


> On my K drive.....I don't think you can get it for free, I bought it from ICC


That was my question ... is it a book i can buy?  I will check the website.


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## e hilton (Feb 4, 2021)

Sifu said:


> I understand a little better now.  Your OP made me think you were part of an AHJ and the AHJ was undergoing an audit (I have been through that so I guess I knee-jerked my way to that assumption).  Doesn't really change the opinion though.  They have been paid to tell you what needs fixed, if they don't give you enough info how can you fix it?


So ... for almost all the items there is a clear solution.  Grab bar too high ... move it down.  Sidewalk slope too steep ... hire an architect, get plans approved by the city, rework the sidewalk.  
But for a couple of items they have no clear solution, and i have to propose something.


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## steveray (Feb 4, 2021)

ICC A117.1-2009 Standard and Commentary: Accessible and Usable Buildings and Facilities
					






					shop.iccsafe.org


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