IBC COORDINATION WITH ADAAG ADA/ABA VS IBC MATRIX

550 Pages·2011·4.69 MB·English

by  Kim Paarlberg

ICC CODE TECHNOLOGY COMMITTEE
AREA OF STUDY – IBC COORDINATION WITH ADAAG
ADA/ABA VS IBC MATRIX
( Work-in-progress as of JULY 12, 2011)

Base documents:
 2004 ADA/ABA Guideline.
 2012 IBC
 2009 ICC A 117.1

Comments column is for information and is not an official interpretation. Comments are intended to identify differences, explain
why or why not revisions may be appropriate, and provide additional background. The comments column also includes when DOJ
regulations will affect the scoping for a physical building.

Xxx – identified differences, no change

Xxx – identified differences, suggested change

‗*‘ – an advisory is provided in the printed information from Access Board

Red require input from the CTC

CTC ISSUES TO CONSIDER:
1) Do we want to try and match just Title III or also Title II? How to provide a definition to match ADA/ABA definition for ‗public
building‘ and leasing issues would need to be addressed. The IBC does not define public and private buildings in the same
way as 2010 Standard. For example, a school system often owns their buildings – that would not be a privately owned
building, but would be a public building. A mall may have several owners, but this is considered a private building by the
2010 ADA. (See approach in E106.4.2 and E106.4.3).

2) The ADA/ABA specifically reference section in the technical criteria for compliance. The IBC provides a general reference to
ICC A117.1 unless there is a specific limitation – i.e., IBC 1109.1 references Chapter 10 for Accessible, Type A and Type B
units. Do we want to change this?
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3) Scoping for residential units – applicable only for permanent housing owned or run by public entities. See DOJ 35.151 e, f, h,
j and k and 36.406 c, d, e and g and Sections *233 and 809. Definition is
Residential Dwelling Unit. A unit intended to be used as a residence, that is primarily long-term in nature.
Residential dwelling units do not include transient lodging, inpatient medical care, licensed long-term care, and
detention or correctional facilities.
This is not intended to address apartment buildings constructed with private funds. The comparison of requirements
in the matrix will be with the Type A dwelling unit requirements in case we want to work towards some form of consistency.
Note that when this is applicable, it can be tied to a project‘s funding stream, rather than a specific building or jurisdiction.
4) Stairways - 1994 ADAAG scoped stairways only when an accessible route was not provided between levels. 2004 ADA/ABA
scopes all means of egress stairways (ADA 210, ABA F210). The 2004 ADA/ABA does not recognize curved stairways or
spiral stairway configurations. It is not clear if a non-required/accessory stairway would be covered under 2004 ADA/ABA
stairway provisions. If some of the areas typically accessed by spiral stairways (i.e, IBC 1103.2.8 Limited access spaces)
specifically said no accessible route to those spaces too, that would address part of the question. Curved stairways, by
providing a walk line similar to straight stairways could be considered alternative means. While all stairways are considered
means of egress stairways, if DOJ would interpret their provisions to apply only to required means of egress stairways, that
would also free up supplemental stairways for open risers. IBC 1009.7.5.3 has exceptions for open risers. See the
comments in ADA/ABA 504 for technical discussion points. The IBC does not reference ICC A117.1 for stairways – however,
should there be a proposal to delete or to coordinate?
5) Or be on an accessible route - In areas where a spiral stairway (i.e., means of egress but not meeting ADA) would be the
route to a space, such as equipment area or catwalk, it seems better to add this language. However, if you look at 1104.3
which says accessible route only connect accessible elements, then an accessible route is not required to a space that is
exempted. CTC should decide on which approach they want and be consistent throughout the exceptions. Right now there
is a mix. Maybe once at the top of the list of exceptions like in ICC A117.1 1101.2.1.
6) Should the recreational scoping provisions be in a specific section rather than dispersed throughout? Currently,
most of the scoping is in Section 1109.15. Some provisions are spread throughout (i.e., 1109.8, Items 7-9). See Code
Change E152-09/10 as a possible starting place. This would be consistent with separating out other unique situations, like
dwellings and assembly.

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TABLE OF CONTENTS

ADA CHAPTER MATRIX PAGE
Chapter 1: Application and administration 4
Chapter 2: Scoping 41
Chapter 3: Building blocks 294
Chapter 4: Accessible routes 308
Chapter 5: General site and building elements 359
Chapter 6: Plumbing elements and facilities 380
Chapter 7: Communication elements and features 428
Chapter 8: Special rooms, spaces and elements 460
Chapter 9: built-in elements 502
Chapter 10: Recreation facilities 508

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ADA ABA 2012 IBC 2009 ICC A117.1 Comments
ADA CHAPTER 1: ABA CHAPTER 1: IBC CHAPTER 1 A117.1 Chapter 1.
APPLICATION AND APPLICATION AND SCOPE AND Application and
ADMINISTRATION ADMINISTRATION ADMINISTRATION Administration
101 Purpose F101 Purpose IBC SECTION 101 A117.1 101 Purpose
GENERAL
*101.1 General. This This document contains IBC [A] 101.3 Intent. The The technical criteria in
document contains scoping scoping and technical purpose of this code is to Chapters 3 through 9, Sections
and technical requirements requirements for accessibility establish the minimum 1002, 1003 and 1006, and
for accessibility to sites, to sites, facilities, buildings, requirements to safeguard Chapter 11 of this standard
facilities, buildings, and and elements by individuals the public health, safety and make sites, facilities, buildings
elements by individuals with with disabilities. The general welfare through and elements accessible to and
disabilities. The requirements requirements are to be structural strength, means of usable by people with such
are to be applied during the applied during the design, egress facilities, stability, physical disabilities as the
design, construction, construction, addition to, sanitation, adequate light and inability to walk, difficulty
additions to, and alteration of alteration, and lease of sites, ventilation, energy walking, reliance on walking
sites, facilities, buildings, and facilities, buildings, and conservation, and safety to aids, blindness and visual
elements to the extent elements to the extent life and property impairment, deafness and
required by regulations required by regulations from fire and other hazards hearing impairment,
issued by Federal agencies issued by Federal agencies attributed to the built incoordination, reaching and
under the Americans with under the Architectural environment and to provide manipulation disabilities, lack
Disabilities Act of 1990 Barriers Act of 1968 (ABA). safety to fire fighters and of stamina, difficulty
(ADA). emergency responders during interpreting and reacting to
emergency operations. sensory information, and
extremes of physical size.
The intent of these sections is
to allow a person with a
physical disability to
independently get to, enter,
and use a site, facility, building,
or element.

Section 1004 of this standard
provides criteria for Type B
units. These criteria are
intended to be consistent with
the intent of the criteria of the
U.S. Department of Housing
and Urban Development
(HUD) Fair Housing
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ADA ABA 2012 IBC 2009 ICC A117.1 Comments
Accessibility Guidelines. The
Type B units are intended to
supplement, not replace,
Accessible units or Type A
units as specified in this
standard.

Section 1005 of this standard
provides criteria for minimal
accessibility features for one
and two family dwelling units
and townhouses which are
not covered by the U.S.
Department of Housing and
Urban Development (HUD)
Fair Housing Accessibility
Guidelines.

This standard is intended for
adoption by government
agencies and by organizations
setting model codes to achieve
uniformity in the technical
design criteria in building
codes and other regulations.

A117.1 101.1 Applicability.
Sites, facilities, buildings, and
elements required to be
accessible shall comply with the
applicable provisions of
Chapters 3 through 9 and
Chapter 11. Dwelling units
and sleeping units shall
comply with the applicable
provisions of Chapter 10.
1.
101.2 Effect on Removal of IBC 3401.1 Scope. The
Barriers in Existing provisions of this chapter
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ADA ABA 2012 IBC 2009 ICC A117.1 Comments
Facilities. This document shall control the alteration,
does not address existing repair, addition and change of
facilities unless altered at the occupancy of existing
discretion of a covered entity. buildings and structures.
The Department of Justice Exception: Existing
has authority over existing bleachers, grandstands and
facilities that are subject to folding
the requirement for removal and telescopic seating shall
of barriers under title III of the comply with ICC 300.
ADA. Any determination that
this document applies to IBC 3401.2 Maintenance.
existing facilities subject to Buildings and structures, and
the barrier removal parts thereof, shall be
requirement is solely within maintained in a safe and
the discretion of the sanitary condition. Devices or
Department of Justice and is safeguards which are
effective only to the extent required by this code shall be
required by regulations maintained in conformance
issued by the Department of with the code edition under
Justice. which installed. The owner or
the owner‘s designated agent
shall be responsible for the
maintenance of buildings and
structures. To determine
compliance with this
subsection, the building
official shall have the
authority to require a building
or structure to be reinspected.
The requirements of this
chapter
shall not provide the basis for
removal or abrogation of
fire protection and safety
systems and devices in
existing structures

IBC 3401.3 Compliance.
Alterations, repairs, additions
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ADA ABA 2012 IBC 2009 ICC A117.1 Comments
and changes of occupancy to,
or relocation of, existing
buildings and structures shall
comply with the provisions for
alterations, repairs, additions
and changes of occupancy or
relocation, respectively, in the
International Energy
Conservation Code,
International Fire Code,
International Fuel Gas Code,
International Mechanical
Code, International Plumbing
Code, International Property
Maintenance Code,
International Private Sewage
Disposal Code, International
Residential Code and NFPA
70. Where provisions of the
other codes conflict with
provisions of this Chapter, the
provisions of this Chapter
shall take precedence.
102 Dimensions for Adults F102 Dimensions for Adults A117.1 102 Anthropometric
and Children and Children Provisions

The technical requirements The technical requirements The technical criteria in this Consistent
are based on adult are based on adult standard are based on adult
dimensions and dimensions and dimensions and
anthropometrics. In addition, anthropometrics. In addition, anthropometrics. This stan-
this document includes this document includes dard also contains technical
technical requirements based technical requirements based criteria based on children‘s
on children‘s dimensions and on children‘s dimensions and dimensions and
anthropometrics for drinking anthropometrics for drinking anthropometrics for drinking
fountains, water closets, toilet fountains, water closets, toilet fountains, water closets, toilet
compartments, lavatories and compartments, lavatories and compartments, lavatories and
sinks, dining surfaces, and sinks, dining surfaces, and sinks, dining surfaces, work
work surfaces. work surfaces. surfaces and benches.
*103 Equivalent Facilitation *F103 Modifications and A117.1 103 Compliance
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ADA ABA 2012 IBC 2009 ICC A117.1 Comments
Waivers Alternatives
Nothing in these The Architectural Barriers Act IBC [A] 104.10 Nothing in this standard is IBC and ICC consistent with
requirements prevents the authorizes the Administrator Modifications. Wherever intended to prevent the use of ADA. Don‘t know how to
use of designs, products, or of the General Services there are practical difficulties designs, products, or match ABA allowances.
technologies as alternatives Administration, the Secretary involved in carrying out the technologies as alternatives to
to those prescribed, provided of the Department of Housing provisions of this code, the those prescribed by this
they result in substantially and Urban Development, the building official shall have the standard, provided they
equivalent or greater Secretary of the Department authority to grant result in equivalent or
accessibility and usability. of Defense, and the United modifications for individual greater accessibility and
States Postal Service to cases, upon application of the such equivalency is approved
modify or waive the owner or owner‘s by the administrative authority
accessibility standards for representative, provided the adopting this standard.
buildings and facilities building official shall first find
covered by the Architectural that special individual reason
Barriers Act on a case-by- makes the strict letter of this
case basis, upon application code impractical and the
made by the head of the modification is in compliance
department, agency, or with the intent and purpose of
instrumentality of the United this code and that such
States concerned. The modification does not lessen
General Services health, accessibility, life and
Administration, the fire safety, or structural
Department of Housing and requirements. The details of
Urban Development, the action granting modifications
Department of Defense, and shall be recorded and entered
the United States Postal in the files of the department
Service may grant a of building safety.
modification or waiver only
upon a determination that it is IBC [A] 104.11 Alternative
clearly necessary. Section materials, design and
502(b)(1) of the Rehabilitation methods of construction
Act of 1973 authorizes the and equipment. The
Access Board to ensure that provisions of this code are not
modifications and waivers are intended to prevent the
based on findings of fact and installation of any material or
are not inconsistent with the to prohibit any design or
Architectural Barriers Act. method of construction not
specifically prescribed by this
code, provided that any such
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ADA ABA 2012 IBC 2009 ICC A117.1 Comments
alternative has been
approved. An alternative
material, design or method of
construction shall be
approved where the building
official finds that the proposed
design is satisfactory and
complies with the intent of the
provisions of this code, and
that the material, method or
work offered is, for the
purpose intended, at least the
equivalent of that prescribed
in this code in quality,
strength, effectiveness, fire
resistance, durability and
safety.
104 Conventions F104 Conventions A117.1 104 Conventions
IBC [A] 102.1 General. A117.1 104.1 General. Where
Where there is a conflict specific criteria of this standard
between a general differ from the general criteria
requirement and a specific of this standard, the specific
requirement, the specific criteria shall apply.
requirement shall be
applicable. Where, in any
specific case, different
sections of this code specify
different materials, methods
of construction or other
requirements, the most
restrictive shall govern.

IBC [A] 102.2 Other laws.
The provisions of this code
shall not be deemed to nullify
any provisions of local, state
or federal law.

IBC [A] 102.4 Referenced
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ADA ABA 2012 IBC 2009 ICC A117.1 Comments
codes and standards. The
codes and standards
referenced in this code shall
be considered part of the
requirements of this code to
the prescribed extent of each
such reference and as further
regulated in Sections 102.4.1
through 102.4.3.

IBC [A] 102.4.1 Conflicts.
Where conflicts occur
between provisions of this
code and referenced codes
and standards, the provisions
of this code shall apply.

IBC [A] 102.4.2 Provisions
in referenced codes and
standards. Where the extent
of the reference to a
referenced code or standard
includes subject matter that is
within the scope of this code
or the International Codes
listed in Section 101.4, the
provisions of this code or the
International Codes listed in
Section 101.4, as applicable,
shall take precedence over
the provisions in the
referenced code or standard.
104.1 Dimensions. F104.1 Dimensions. A117.1 104.2 Dimensions.
Dimensions that are not Dimensions that are not Dimensions that are not stated
stated as ―maximum‖ or stated as ―maximum‖ or as ―maximum‖ or ―minimum‖
―minimum‖ are absolute. ―minimum‖ are absolute. are absolute. All dimensions
are subject to conventional
industry tolerances.

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