# Accessible element/space with no accessible route???!?



## righter101 (Jan 28, 2011)

Thanks in advance for the feedback and input on this post.  I have limited knowledge of the accessiblity requirents and seek to increase that, in an attempt to fairly enforce these laws and statues.

2006 IBC; Mixed use building. Fire station with large parking garage for truck.  Permitted as S2(parking portion) and B for the remainder of the structure.  2 stories.  Upper floor was permitted with a small office and the balance being storage.

They are revising their design during construction to make the upstairs dorm type rooms for firefighters.

The lower floor has an accessible restroom and enterance.

Per 1103.1, generally all elements and spaces shall be accessible, unless exempted by this section

1104.1 (accessible route) Exception 1 for <3000 sq. ft.  This project would qualify and an accessible route would not be required to the second floor.

Question:

Does the 2nd floor restroom, and possibly 1 or more of the dorm-type rooms need to meet accessibilty requirements, even though an accessible route to them is not required.?????

My reading of the code leads me to believe yes, per 1103.1.  None of the exceptions deal with "areas not requiring an accessible route".

Just want to make sure that this is a correct interpertation.

Thanks again.


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## steveray (Jan 28, 2011)

Not that I claim to be an expert,...but I believe so....with the intent being that if they ever make those areas accessible, the features already will be....commence battery...


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## Gene Boecker (Jan 28, 2011)

Hi Righter,

Yes, the upstairs must be designed to have fully accessible elements.  The reason the code allows the exception for limited square footage spaces is the same as that in the ADAAG.  Steve's right.  Its an attempt to not be an undue burden on smaller facilities.  However, the thinking is that if at some time in the future access is provided to the upper level then it would be a horrendous cost to upgrade the toilet rooms and such on the upper level.  Its better to do it now so that they're in place as needed, when aces is provided (IF access is ever provided).

On a tangent, although this is only a question about the application from the ICC, you might want to ask the architect is the fire station is subject to Title II of the federal ADA.  There are more stringent federal requirements for access to spaces than what is in the IBC.  If the answer is no, they had best seek the legal opinion of the jurisdiction in which the station is to be located.


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## Yikes (Jan 28, 2011)

righter 101,  our state architect has told me that "accessibility" features address all kinds of issues, and are not just for people in wheelchairs.   So even if a building has stairs only (no elevator), if a person can use crutches or a cane and make it up the stairs, they still are entitled to a generous bathroom stall, strike side clearances, etc. on the upper floor, unless specifically otherwise excepted in the code.


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## righter101 (Jan 28, 2011)

Thank you.  This was my understanding, that accessibilty is not just for wheel chairs, but for other issues or conditions as well.  I will also forward the question about Title II of the ADA to the architect.  Thanks for the info guys.


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## mark handler (Jan 28, 2011)

Gene and Yikes, nailed it.


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## righter101 (Jan 28, 2011)

Mark, I have heard you are a very good, knowledgeable resource on accessibilty.  Your input is appreciated.  I skimmed over the Title II of the ADA and there are potential implications for this fire station.  I am only required to enforce the Building Code provisions.  What do you guys do in a situation such as this?  Suggest that the architect review all the Title II stuff?

The reality of this is we are a rural county, remote location, with primairly residential contractors attempting to do commercial work. They are generally not familar at all with fire separation, stairways wider than 36", doors required to swing outward, etc... So this has been an uphill battle.

The fire department applied for a permit with drawings mainly to get permits and bids, with the full intention of modifying it as the project progressed.  Generally that is ok, but in this case, they have been modifying stuff without applying for a revision, and in this case, the proposed (or now, rough framed changes) have implications beyond structural.

thanks again.


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## mtlogcabin (Jan 28, 2011)

That is a "R" type occupancy. Is the building sprinklered?


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## mark handler (Jan 28, 2011)

righter101

If your the client you can do more than "Suggest" that the architect review all the Title II stuff, as a client, you can require they meet it.

Stairways may not require widening  and doors may not require outward swinging. Based on your post, The occupancy is an R upstairs and the occupancy loads, upstairs are probably less than that required to reverse the swings.

You really need an architect that knows what he/she is doing.

Note:

I am basing this on what has been posted to date.


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## righter101 (Jan 28, 2011)

They are changing to the R occupancy and will be sprinkling the building.

 For Mark H. I/we are the AHJ, and I have been pulling teeth with the fire district to get revised drawings.

I was wondering if I should just politely inform the architect/fire chief about the TITLE II.

My door swing analogy was a general reference to residential contractors not being familiar with commerical work.  It doesn't apply in this situation.


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## Yikes (Jan 28, 2011)

righter101 - you've got several problems on yor hands, but chief among them is the blessing of living a rural area, which has the charm and simplicity of small town life, but with an accessibility code and civil penalties that hangs over your fire department like the sword of Damocles.

The best thing you can do for residential contractors attempting commercial construction is visit the site during construction and mark out for them on the concrete and framing where everything is supposed to go.

Help them understand where they need to do preliminary drywall, and familiarize them with the concept of fire ratings, membranes, and red fire caulk.


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## righter101 (Jan 28, 2011)

One other note, Mark, as far as "needing an architect that knows what he/she is doing", I actually refused the drawings the brought in, which were the original drawings, stamped by a licensed archtiect, modified with highlighter.  I cited state law requiring architects on non-res over 4000sqft (state of washington).

I would wholeheartedly agree and have told them this, using my best tact and diplomacy.


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## brudgers (Jan 28, 2011)

The way to understand the second floor accessibility requirement is:

1. Every space on every floor is required to be accessible.

2. Vertical accessibility is not required for floors less than 3000 square feet in area [ADA] or an aggregate  of floors [iBC].

In otherwords,  you get a break on the chair lift/elevator but that's it.


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## mark handler (Jan 29, 2011)

Came across this re: occupancy

http://www.llr.state.sc.us/FMARSHAL/forms/FMC/2009/FMC_Fire_Sprinkler_Protection_in_Fire_Stations.pdf

Fire Sprinkler Protection in Fire Stations

Q: Is fire sprinkler protection required in fire stations that accommodate sleeping facilities that are not classified as accessory per 508.3.1?

A: Yes. Per (2006) IBC 903.2.7: “An automatic sprinkler system installed in accordance with Section 903.3 shall be provided throughout all buildings with a Group R fire area.” Per the 2006 IBC Commentary to this section, “This section requires sprinklers in any building that contains a Group R fire area. This includes uses such as hotels, apartment buildings, group homes and dormitories. There are no minimum criteria and no exceptions.”

Q: If yes, does the entire building including the bay areas need similar protection?

A: Per (2006) IBC 903.2.7: “An automatic sprinkler system installed in accordance with Section 903.3 shall be provided throughout all buildings with a Group R fire area.” Note that a true “fire wall” [not “fire barrier” or “fire partition”] can be used to separate a building into two separate buildings per IBC 705.1 but only if constructed per all applicable requirements of IBC 705 including structural integrity, structural independence, continuity and adequate fire resistance for exposure protection.

Q: When did this requirement become effective?

A: This requirement was introduced in its current form in the 2003 edition of the IBC and the OSFM adopted it on July 22, 2005; however, the SC Building Codes Council required counties and municipalities in SC to implement enforcement of it effective January 1st, 2005.

Q: What is a fire station?

A: A fire station is usually classified as a mixed occupancy building. A fire station may have a training area (Assembly - Group A), office areas (Business - Group B), sleeping quarters for the firefighter (Residential - Group R), and vehicle and other miscellaneous storage areas for the fire equipment (Storage - Group S). Some buildings may not contain all of these occupancies. It is the designer’s option to decide exactly how to classify the various areas of the building into incidental use areas per 508.2.1, accessory occupancies per 508.3.1, non-separated occupancies per 508.3.2, and separated occupancies per 508.3.3. 1

Q: What are sleeping quarters in a fire station and how are they specifically classified?

A: Per the IBC Commentary to the definition of dormitory in IBC 310.2, “…sleeping areas of a fire station and similar lodging facilities for occupants not of the same family group are also considered dormitories.” A dormitory is specifically listed in Section 310.1 as an example of R-2 occupancy.

Q: What are the apparatus bays in a fire station and how are they specifically classified?

A: Per the IBC Commentary to IBC 406.3.4, “Facilities used for the parking of trucks or buses must be classified as an enclosed parking garage even if the opening requirements of Section 406.3.3.1 are met.” Per the IBC Commentary to IBC 406.2.1, “Parking garages are considered to be storage occupancies (Group S-2).”

Q: Does the presence of apparatus bays, which do not normally meet the definition of “open parking garage” in IBC 406.3.2, require a fire station to be sprinklered?

A: Yes. Per IBC 903.2.9 Group S-2, “An automatic sprinkler system shall be provided throughout buildings classified as enclosed parking garages in accordance with Section 406.4 or where located beneath other groups.”

Q: Can fire station apparatus bays with closable bay doors qualify as openings per 406.3.3.1 in order to meet the definition of “open parking garage” in IBC 406.3.2?

A: No. Per the IBC Commentary to the scope of open parking garages listed in IBC 406.3.1, it is clear that “Section 406.3 provides requirements that are unique to open parking garages […] because of the permanently open exterior walls of open parking garages which permit the dissipation of heated gases.”

Q: What sprinkler system design standard is required for a fire station?

A: Fire stations normally only fall within the scope of NFPA 13. NFPA 13R is only applicable when a building is classified solely as residential occupancy (not mixed) and is 4 stories or less in height. NFPA 13D is only applicable to one- and two-family dwellings. Additionally, a NFPA 13 system is the only type of sprinkler system that can be used to qualify for certain code modifications such as the area increase of 506.3; the rating reductions in 508.3.3, Table 601, and 708.3; and various other modifications too numerous to list here. If an architect utilizes just one of these modifications in his building design, the result is that a NFPA 13 system is required, even if the building is within the scope of NFP 13R. Per IBC 901.2 “Any fire protection system for which an exception or reduction to the provisions of this code has been granted shall be considered to be a required system.”

Q: Do fires occur at fire stations?

A: Yes. Fires in fire stations may seem counter-intuitive, like a robbery at a police station. However, like structures everywhere, fire stations are also susceptible to the dangers of fire. Fire stations are not always occupied by fire fighters. This is especially true of volunteer fire departments, but occurs at any fire station whose on-duty fire fighters have all left to respond to emergency calls in the community. The occurrence of fires in fire stations is a valid concern and such incidents are well documented. Per the U.S. Fire Administration report entitled Fire Station Fires (Rev. December 2001): “Fire station fires most often originate in fire departments’ vehicles (44%); 37% of fires are structure fires. The leading cause of the approximately 150 fire station fires each year is attributed to “electrical distribution,” although “cooking” is the leading cause of structure fires. Electrical wire is the leading material ignited, most often due to short circuits. Too often, fire stations have no damage insurance or are underinsured.”

Q: Are there potential ramifications of not installing a required sprinkler system?

A: The parties ultimately responsible for designing and permitting the occupancy of such a building may have increased potential liability by omitting sprinklers in the absence of approved alternative methods of compliance or performance based designs.

Q: Should fire stations be sprinklered when not required to by the IBC?

A: Yes. Fire stations, hospitals, police stations, etc. provide essential services to the community which should be protected in order to avoid interruption of emergency response service capabilities. The May 1997 US Fire Administration report entitled Safety and Health Considerations for the Design of Fire and Emergency Medical Services Stations states “the U.S. Fire Administration strongly recommends that [fire and EMS] stations be protected with automatic sprinkler systems.” The US Air Force Fire Station Design Guide – 1997 states “Provide an automatic sprinkler system throughout with smoke detectors in all sleeping areas.” The future cost to repair or rebuild a fire station as well as replace or repair the damaged vehicles and equipment can be difficult, especially for small volunteer departments and fire departments which are either uninsured or underinsured. Automatic sprinkler protection should be considered a means for protecting the community's investment in a new fire station. Fire stations are often also used for other purposes such for emergency shelters, community functions, safe havens, etc. And remember, we always teach best by example.


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## Gene Boecker (Jan 29, 2011)

The comments that Mark posted are right on. If the drawings are not properly submitted, then tell them to come back when they are serious. Regarding the Title II suggestion; that's all you can do - or need to do. Your responsibility is to the IBC. The comment about Title II is only one to make as you offer advice (since you're such a nice guy). The "Owner" needs to pay attention to it so as not to get sued in the future. But that's their concern, not yours.

By adding the sprinklers (and I can't imagine why they would even think about not installing them), the stair width can be reduced like Mark said.

Best of luck.


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