2018-1498 Doug's Mazda Service Center #2 Struc and NS.pdfOV ED_4 0 City of Edmonds
PLAN REVIEW COMMENTS
BUILDING DIVISION
(425) 771-0220
DATE: March 21, 2019
TO: Frank Karreman
Email:- Frankk3rkarchitecture.com
FROM: Leif Bjorback, Building Official
RE: Plan Check: BLD2018-1498 2 nd review
Project: Doug's Mazda Service Center
Project Address: 22214 Highway 99
During review of the plans for the above noted project, it was found that the following information,
clarifications or changes are needed. Please provide written responses to each comment, and submit revised
plans/documents to a permit coordinator in the Development Services Department.
Please respond to the following structural and non-structural review comments from Beck and Associates.
Page 1
Beck & Associates, PLLC
Structural Engineering & Code Consulting
March 8, 2019
Leif Bjorback
Building Official
City of Edmonds
1215 th Avenue North
Edmonds, WA 98020-3145
Subject: Mazda Service Center Addition (Structural Review)
Permit: BLD18-1498
Peryour request, Beck & Associates has completed a second structural review of the drawings and
calculations for conformance with the 2015 International Building Code (IBC), as adopted and
amended by the State of Washington and the City of Edmonds.
Our review of the plans and calculations indicates that corrections are necessary prior to permit
issuance. The applicant should address the following comments in itemized letter format in addition
to making corrections & revisions to the drawings. Corrections and revisions to the drawing should
be clouded so that they are clearly identifiable.
Legend:
Faded text initial comment adequately addressed — no further action required
Plain text initial comment (these remain where an additional comment is made)
Blue text additional comment in response to the resubmittal
Geotechnical
General
1) The geotechnical report submitted with Ll 113 permit application is dated June 23, 2017 and is
titled "Showroom and Stormwater Vault Geotechnical Report". The structural drawings
reference a geotechnical report dated April 10, 2017. Please provide a report that addresses the
geotechnical conditions of the Service Center. If a geotechnical report specific to the Service
Center has not been provided, the geotechnical engineer should either provide one or
specifically indicate that the June 23, 2017 geotechnical report contains recommendations that
are applicable to the Service Center site.
Gravity
f-, o narn I
2) Reference the Basis of Design noted on sheet S001. A floor live load of 50 psf is specified.
However, a live load of 60 psf is used for the design.
a) Provide coordination.
16425 SE 66 t h Street, Bellevue, WA 98006 * beckpllc@msn.com * PH: 206-313-3739
Permit BLD18-1498 (Structural — Rvw-2)
March 8, 2019
Page 2 of 4
b) In response to this item, the engineer references correspondence from February 4, 2019. In
that correspondence, we recommended that a minimum live load of 75 psf be used for
storage, but that the engineer would need to provide calculations that demonstrate that the
anticipated load (based on anticipated items stored and how they are stored) does not
exceed 75 psf. These calculations remain to be provided for our review.
Additionally, we indicate in response to the February 4, 2019 correspondence that the
design live load of the parts storage areas is required to be conspicuously posted in that part
of each story where the loads apply (60 psf at storage at existing construction; 75 psf at
storage at new construction). The plans need to specify this. 106.1, IEBC 402.3.1
The category in Table 1607.1 that most closely resembles the specified "Parts Storage" is
"Storage Warehouses" which identifies a 'light storage' live load of 125 psf. IBC 1607.2
indicates that, for occupancies or uses not designated in Table 1607.1, the live load is
required to be determined in accordance with a method approved by the building official.
Either design the new Parts Storage for a live load of 125 psf OR provide detailed
calculations for use of an alternate live load that is consistent with auto parts storage. Revise
the design as required.
Lateral
General
3) The new & existing structures are shown to be integrally connected (no seismic joints are
provided). Reference details 5 & 6/S204. Additionally, reference comments in item 14, below.
a) The effective seismic weight is required to include a minimum of 25% of the floor live load
for all Parts Storage areas (whether existing or new). Revise the design accordingly.
b) The effective seismic weight is required to include contribution of any masonry or concrete
walls. The existence and extent of masonry and concrete walls were previously not clearly
provided within the drawings (either in the architectural drawings or the structural
drawings). Revise the design accordingly.
c) Identify all existing lateral force resisting elements that are being used to resist existing
and/or new lateral loads.
The effective seismic weight is required to include a minimum of 25% of the floor live load for
areas used as storage, such as for Parts Storage. Update the lateral analysis to consider this
increase in seismic weight. ASCE 7-10, 12.7.2
Drawing Sheets
S102 —Second Floor & Low Roof Framing Plan
11) Reference Framing Note #4. A reference is made to Structural Note J.11 & J.12 on sheet S0.1.
This reference is incorrect. Provide coordination.
12) The engineer will need to revise the diaphragm design to consider that the existing and new
structures share a lateral force -resisting system and to consider the required effective seismic
weight. Update the design accordingly. IEBC 403.4; ASCE 7-10, 12.7.2
Provide an analysis of the new diaphragm to transfer loads to the shear wall located along grid
G. Reinforce the diaphragm as determined by the analysis.
16425 SF 66' Street, Bellevue, WA 98006 . beckpllc@msn.com - PH: 206-313-3739
Permit BLD18-1498 (Structural — Rvw-2)
March 8, 2019
Page 3 of 4
13) Detail 8/S204 SIM TYP is specified along grid G. The cantilever concrete retaining wall is full -
height at this location. Provide detailing for the specifics of this condition.
S103 —Roof Framing Plan
14) In response to this item the engineer indicates that existing elements are not being utilized to
(laterally) support the Service Center Addition and that the new structure has been designed to
be laterally self -supported. However, seismic joints have not been provided between the existing
structure and the new structure. Reference details 5 & 6/S204. Where additions are not
structural independent of the existing structure, the existing structure and its addition acting
together as a single structure are required to be shown to meet the requirements of Sections
1609 (Wind) and 1613 (Earthquake). Revise the design to either truly make the existing and new
structures laterally independent (with seismic joints designed per ASCE 7-10) or to consider
them together as a single structure to resist lateral loads. Submit calculations to substantiate the
design for the chosen approach. Update design and detailing as required. 1EBC 402.4
Provide an analysis and detailing for transfer of lateral loads from the high roof (existing) into
the new roof diaphragm (along grids B & F) for transfer of loads to the shear walls along grids A
& G. Provide a complete load path. Additionally, where existing elements are being utilized,
specify what those existing elements are assumed to be and that they must be field verified.
15) Detail 6/S204 is called out along grid F. This detail is not applicable as it depicts T.Ils, whereas the
plans specify roof trusses. Provide coordination and update the detailing accordingly.
S201
16) In response to this item, the engineer indicates that the existing building consists of portions of
masonry walls, in which new door openings will be placed.
a) Update the plans to show the locations and extent of the locations of all existing masonry
walls. The plans must also indicate if the existing masonry walls are reinforced or not, and if
they are, what the reinforcement in the walls is.
b) The IEBC requires existing gravity load -carrying structural elements in which an increase in
design gravity loads of more than 5% occurs to be strengthened, supplemented, replaced, or
otherwise altered as needed to carry the increased gravity load required by the IBC for new
structures. Additionally, any gravity load -carrying structural element whose gravity load -
carrying capacity is decreased as part of the alteration shall be shown to have the capacity
to resist applicable design gravity loads required by the IBC for new structures. Each existing
masonry wall needs to be assessed for increased loads (where new loads are applied to
them) and for decreased capacity (where being modified) to demonstrate compliance with
these requirements. IEBC 402.3, 403.3
c) Unless the existing and new structures are laterally separated from each other with seismic
joints, and if existing masonry walls are used to resist lateral loads, the engineer will need to
demonstrate that the existing masonry (or concrete) walls meet the requirements for design
of new structures. Alternatively, the engineer will need to demonstrate that the
demand/capacity ratio of the structural element with the alteration is not more than 10%
greater than the demand/capacity ratio of the structural element prior to the alteration.
Please note that unless specifically seismically separated from the structure, the walls will
need to be considered as part of the lateral force -resisting system. Alternatively, they must
be seismically separated from the structure so that seismic loads are not imparted to them.
Where no seismic separations are provided, the lateral force -resisting system will need to
16425 SE 66" Street, Bellevue, WA 98006 - beckpllc@msn.com - PH: 206-313-3739
Permit BLD18-1498 (Structural — Rvw-2)
March 8, 2019
Page 4 of 4
consider horizontal and vertical combinations of lateral force -resisting elements in
accordance with ASCE 7-10, Ch. 12. IEBC 403.4
d) If there are unreinforced masonry walls in the existing structure, the alteration work is
required to include installation of wall anchors unless an evaluation demonstrates
compliance of existing wall anchorage. 1EBC 403.6
Reference 4/S201. No masonry is specified on this project. Either identify the location where this
detail is applicable, or if not applicable, delete it from the drawing set.
17) In response to this item, the engineer indicates that the existing building consists of portions of
concrete walls, in which new door openings will be placed.
a) Update the plans to show the locations and extent of the locations of all existing concrete
walls. The plans must identify the reinforcement of the existing concrete walls.
b) The IEBC requires existing gravity load -carrying structural elements in which an increase in
design gravity loads of more than 5% occurs to be strengthened, supplemented, replaced, or
otherwise altered as needed to carry the increased gravity load required by the IBC for new
structures. Additionally, any gravity load -carrying structural element whose gravity load -
carrying capacity is decreased as part of the alteration shall be shown to have the capacity
to resist applicable design gravity loads required by the IBC for new structures. Each existing
concrete wall needs to be assessed for increased loads (where new loads are applied to
them) and for decreased capacity (where being modified) to demonstrate compliance with
these requirements. IEBC 402.3, 403.3
c) Unless the existing and new structures are laterally separated from each other with seismic
joints, and if existing concrete walls are used to resist lateral loads, the engineer will need to
demonstrate that the existing concrete) walls meet the requirements for design of new
structures. Alternatively, the engineer will need to demonstrate that the demand/capacity
ratio of the structural element with the alteration is not more than 10% greater than the
demand/capacity ratio of the structural element prior to the alteration. Please note that
unless specifically seismically separated from the structure, the walls will need to be
considered as part of the lateral force -resisting system. Alternatively, they must be
seismically separated from the structure so that seismic loads are not imparted to them.
IEBC 403.4
Reference 7/S201. This detail is not specified on the plans. Either identify the location where this
detail is applicable, or if not applicable, delete it from the drawing set.
S202
18) Reference comments in item 16, above.
Reference 2/S202. No masonry is specified on this project. Either identify the location where this
detail is applicable, or if not applicable, delete it from the drawing set.
Please contact me should you have any questions.
Respectfully,
Douglas Beck, PE, SE
Beck & Associates, PLLC
16425 SF 66' Street, Bellevue, WA 98006 . beckpllc@msn.com - PH: 206-313-3739
Beck & Associates, PLLC
Structural Engineering & Code Consulting
March 8, 2019
Leif Bjorback
Building Official
City of Edmonds
1215 th Avenue North
Edmonds, WA 98020-3145
Subject: Mazda Service Center Addition (Non-structural Review)
Permit: BLD18-1498
Per your request, Beck & Associates has completed a second non-structural review of the
drawings and calculations for conformance with the 2015 International Building Code (IBC), as
adopted and amended by the State of Washington (WSA) and the City of Edmonds (ECC).
Our review of the plans and calculations indicates that corrections are necessary prior to permit
issuance. The applicant should address the following comments in itemized letter format in
addition to making corrections & revisions to the drawings. Corrections and revisions to the
drawing should be clouded so that they are clearly identifiable.
Legend:
- J__I.. - � — no further action A
Plain text initial comment (these remain where an additional comment is made)
Blue text additional comment in response to the resubmittal
Please reference the New Comments section at the end of this letter.
General
1) Please coordinate between drawing sheets related to existing & new building areas.
a) The Site Plan (A1.0) indicates that the footprint of the existing building is 3,792 square
feet. Provide dimensions of the Existing First Floor Demolition Plan and the Existing
Second Floor Demolition Plan on A2.0 to confirm the existing areas of each level.
Dimensions should be provided from outside face of wall to outside face of wall. If the
results are different from what is provided on the Site Plan, update the Site Plan to be
coordinated with the actual areas.
b) In the Project Information section on AO.0, identify the square footage of both existing &
new areas of both the First and Second floors. Areas should be from outside face of wall
to outside face of wall. Additionally, identify the area of existing structure to be
completely demolished (north portion of the existing Second Floor). The areas provided
should be consistent with the dimensions shown in other locations of the drawing set.
We recommend that the information be provided in tabular format for clarity.
16425 SE 66" Street, Bellevue, WA 98006 - beckpllc@msn.com * PH: 206-313-3739
BILD 18-1498 (INIS — Rvw-2)
March 8, 2019
Page 2 of 4
2) Provide a Site Plan that identifies the distance from the closest face of the building to
adjacent property lines on each side of the building. These are the fire separation distance
used in determining rating of exterior walls in accordance with Table 602. It appears that all
fire separation distances will exceed 10'-0" and the exterior walls will therefore not be
required to be rated. However, this information is required to be provided within the plans to
demonstrate that this is indeed the case. Table 602
3) The plans need to specifically state that a sprinkler system, compliant with NFPA13, is
required to be provided throughout the building. Sprinkler increases are utilized to achieve
the allowable height and area. Ch. 5
4) In response to this item, the architect revised detailing on sheet A1.0. However, the design is
incomplete and no calculations/analysis were provided to substantiate the design.
a) Provide complete gravity and lateral (wind, seismic) calculations to substantiate the
design. Revise the design as determined by the analysis.
i) Please be aware of, and demonstrate compliance with, the requirements of ASCE 7-
10, 12.2.5.2 for cantilever column (lateral) systems. ASCE 7-10, 12.2.5.2
ii) Provide a complete load path for lateral loads to transfer from the roof diaphragm to
the cantilever columns. Connections need to be designed for the specific wind and
seismic forces.
b) Identify the specific members that are required to be preservative -treated per the
definition of 'weather -exposed surfaces' in Ch. 2 of the 113C. Accordingly, all rafters (rafter
ends are exposed), beams, cross beams, and posts are required to be preservative -
treated or of naturally decay -resistant wood. 2303.1.9, 2304.12
c) The footing thickness in detail 7/A1.0 remains to be specified.
Sheet A1.0 shows a Pergola. Provide complete structural analysis and design/detailing for the
construction of the Pergola.
Accessibility (IBC Ch. 11, ICC A117.1-09)
5) At least one accessible route , ,jired to be provided from public
transportation stops and public streets or sidewalks to the accessible building entrance.
Provide plans and detailing that demonstrate how this will be provided. 1104.1
6) At least one accessible route is required to the buildings on this site. Provide plans and
detailing that demonstrate how this will be provided. 1104.1
7) It is clear that the Auto Parts Storage is an area of primary function and that an accessible
route is required. Please note that additions are also considered alterations (IEBC 410.5) and
that the cost of providing accessibility on a project (other than what is already required by
code) is not required to exceed 20% of the costs of the alterations affecting the area(s) of
primary function. Given that the addition is an alteration, the conclusion is that the 'cost of
alterations' is required to include the entire budget of the project. Please reference the
attached sections of the I EBC and associated Commentary which is the basis for determining
requirements.
One potential way to address this issue is to itemize all costs that are going toward accessible
upgrades on this project that are otherwise not required by code. Once 20% of the entire
budget is reached, no more of the budget would be required to be spent on accessibility.
Provide an itemization of the costs of providing each accessible element (such as accessible
parking, accessible toilets, accessible drinking fountains, etc.) and provide a comparison to
16425 SE 66' Street, Bellevue, WA 98006 - beckpllc@msn.com - PH: 206-313-3739
BLD 18-1498 (NS — Rvw-2)
March 8, 2019
Page 3 of 4
the total budget for the project. The total budget for the project, as well as costs of providing
the accessible elements, should be provided to the City as a contractor's bid. Please note that
the entire 20% of the budget is required to be spent on accessible upgrades unless all
accessible requirements are met prior to spending the 20% of the overall cost of the project.
Please reference IEBC 410.7 and the associated Commentary.
At least one accessible route is required to connect each accessible story in multilevel
buildings and facilities unless one of the exceptions of 1104.4 is met. Unfortunately, it does
not appear that the conditions of this project will meet any of the exceptions. An accessible
route is therefore required to connect the First Floor and the Second Floor. Accessible routes
are required to consist of one or more of the following components: walking surfaces, ramps,
and elevators. Update the plans accordingly. IBC 1104.4; ICC A117.1-09, Ch. 4
Drawing Sheets
A2.5 — Roof Plan & Details
16) In response to this item, a portion of the roof was changed to unvented roofing. Reference
A2.5 (Roof Plan), Sections 1-4/A3.1, and Sections 1-3/A3.2
a) A vapor barrier is not permitted to be installed on the ceiling side of the unvented
attic/roof assembly. This needs to be specified on the drawings. 1203.3, item 2
b) Where air -permeable insulation (batt insulation) is provided inside the building thermal
envelope, it is required to be applied in direct contact with the underside of the
structural roof sheathing. Update the sections to show and specify that the batt
insulation is required to be installed in direct contact with the underside of the roof
sheathing. 1203.3, item 5
c) The air -impermeable insulation (rigid insulation on the roof), is required to provide a
minimum insulation value of R-10. This needs to be specified in the Sections. 1203.3,
item 5, Table 1203.3
Provide calculations and specifications for eave and ridge ventilation to demonstrate
adequate roof ventilation will be provided. 1203.2
17) The overflow scupper openings are required to be no less than 4 inches high and have a width
equal to the circumference of the roof drain required for the area served, sized in accordance
with Table 1101.12. This needs to be specified on the drawings. UPC 1101.12
Secondary (emergency) roof drainage is required to be provided in accordance with UPC
1101.12. Scuppers are required to be sized to prevent the depth of poncling water from
exceeding that for which the roof was designed. Scupper openings must be no less than 4
inches high and have a width equal to the circumference of the roof drain required for the
area served, sized in accordance with Table 1101.12. UPC 1101.12
New Comments
24) Based on responses from the structural engineer and from detailing within the structural
drawings, it is our understanding that there are existing masonry and/or concrete walls in the
existing structure that are intended to remain and/or be modified.
16425 SF 66' Street, Bellevue, WA 98006 . beckpllc@msn.com - PH: 206-313-3739
BLD 18-1498 (NS — Rvw-2)
March 8, 2019
Page 4 of 4
a) Architectural drawings need to show the extent of all masonry and/or concrete walls on
the architectural drawings.
b) Clearly show how all masonry and/or concrete walls will be modified (infilled, removed,
etc.).
c) Update sections and detailing to show masonry and/or concrete walls where they occur.
d) Reference the new comments in the 2nd Structural Review letter.
Please contact me should you have any questions.
Respectfully,
Douglas Beck, PE, SE
Beck & Associates, PLLC
16425 SE 66' Street, Bellevue, WA 98006 . beckpllc@msn.com * PH: 206-313-3739
DEFINITIONS
equipment or fixtures. It is important to note that while
the list is quite extensive, the definition does not spe-
cifically exclude the terms "manufacturing," "produc-
tion" or "process equipment."
[A] EXISTING BUILDING. A building erected prior to the
date of adoption of the appropriate code, or one for which a
legal building permit has been issued.
This term is used to identify those structures or build-
ings that were constructed before the current edition
of the code was adopted by the jurisdiction. Often
erected under the provisions of an earlier edition of
the code, the buildings are exempt from compliance
with current code provisions unless otherwise stated
or a hazardous condition is present, or when alter-
ations or changes in building height and areas are
made.
[A] FACILITY. All or any portion of buildings, structures,
site improvements, elements and pedestrian or vehicular
routes located on a site.
4-This term is intentionally broad and includes all por-
tions within a site and all aspects of that site contain-
ing features required to be accessible. This includes
parking areas, exterior walkways leading to accessi-
ble features, recreational facilities such as play-
grounds and picnic areas and any structures on the
site (see also the commentary to the definition of
"Site" in the IBC).
[BS] FLOOD HAZARD AREA. The greater of the follow-
ing two areas:
1. The area within a flood plain subject to a I -percent or
greater chance of flooding in any year.
2. The area designated as a flood hazard area on a com-
munity's flood hazard map, or otherwise legally desig-
nated.
4-The Federal Emergency Management Agency
(FEMA) prepares Flood Insurance Rate Maps
(FIRMs) that delineate the land area subject to inun-
dation by the I -percent annual chance flood. Some
states and local jurisdictions develop and adopt maps
of flood hazard areas that are more extensive than
the areas shown on FEMA's maps. For the purpose
of the code, the flood hazard area in which the
requirements are to be applied is the greater of the
two delineated areas.
[A] HISTORIC BUILDING. Any building or structure that
is one or more of the following:
1. Listed, or certified as eligible for listing, by the State
Historic Preservation Officer or the Keeper of the
National Register of Historic Places, in the National
Register of Historic Places.
2. Designated as historic under an applicable state or local
law.
3. Certified as a contributing resource within a National
Register, state designated or locally designated historic
district.
4-This definition specifies the criteria for consideration
as a historic building. Chapter 11 contains the provi-
sions for buildings that qualify as historic buildings.
LOAD -BEARING ELEMENT. Any column, girder, beam,
joist, truss, rafter, wall, floor or roof sheathing that supports
any vertical load in addition to its own weight or any lateral
load.
-*.-This term relates to all of the load -bearing elements
in a structure. It is important to identify all such load -
bearing elements to ensure that they can continue to
accomplish their designed function of being able to
transfer any vertical load, any lateral load and their
own weight effectively to the earth.
NONCOMBUSTIBLE MATERIAL. A material that, under
the conditions anticipated, will not ignite or burn when sub-
jected to fire or heat. Materials that pass ASTM E 136 are
considered noncombustible materials.
A material that will not ignite or burn when subjected to
fire or heat or that successfully passes the ASTM El 36
test is considered to be noncombustible. The test deter-
mines whether a building material will act to aid com-
bustion or add appreciable heat to a fire. A material
may have a limited amount of combustible content but
not contribute appreciably to a fire; thus, it may still
qualify as noncombustible.
PRIMARY FUNCTION. A primary function is a major
activity for which the facility is intended. Areas that contain a
primary function include, but are not limited to, the customer
services lobby of a bank, the dining area of a cafeteria, the
meeting rooms in a conference center, as well as offices and
other work areas in which the activities of the public accom-
modation or other private entity using the facility are carried
out. Mechanical rooms, boiler rooms, supply storage rooms,
employee lounges or locker rooms, janitorial closets,
entrances, corridors and restrooms are not areas containing a
primary function.
4- Primary function areas contain the major activities for
the building or space. Determination of what consti-
tutes a primary function space can be somewhat sub-
jective. There can be multiple areas containing a
primary function in a single building. Primary function
areas are not limited to public use areas. For exam-
ple, both a bank lobby and the bank's employee
areas, such as the teller areas and walk-in safe, are
primary function areas. Areas that are not primary
function spaces are support and circulation spaces.
Determination of the primary function areas for a
building will also determine when the route to that
area and associated toilet rooms and drinking foun-
tains must be evaluated for accessibility. If these
items are not accessible, additional alternatives may
be necessary (see commentary, Section 705.2).
2015 INTERNATIONAL EXISTING BUILDING CODE" COMMENTARY 2-3
r"
PRESCRIPTIVE COMPLIANCE METHOD
tional Building Code, or Section R322 of the International
Residential Code, as applicable:
Exception: Historic buildings need not be brought into
compliance that are:
1. Listed or preliminarily determined to be eligible for
listing in the National Register of Historic Places;
2. Determined by the Secretary of the U.S. Department
of Interior as contributing to the historical signifi-
cance of a registered historic district or a district pre-
liminarily determined to qualify as an historic
district; or
3. Designated as historic under a state or local historic
preservation program that is approved by the
Department of Interior.
4-With respect to provisions applicable to buildings in
flood hazard areas, the discretion given in Section
408.1 allowing the code official to waive the require-
ments for historic structures extends only to historic
structures that meet the specific limitations in the
exception to this section. Location in a historic district
does not qualify a structure as historic. Care must be
taken to ensure that work on such historic structures
will not cause them to lose their continued listing or
designation. If improvements or repairs cause a
structure to lose its listing or designation as a historic
building, then the code official must enforce the sub-
stantial improvement requirements. Owners of his-
toric structures should consider measures to reduce
flood damage to the extent practical. For additional
guidance, see FEMA P-467-2, Floodplain Manage-
ment Bulletin on Historic Structures, and FEMA P-
758.
SECTION 409
MOVED STRUCTURES
409.1 Conformance. Structures moved into or within the
jurisdiction shall comply with the provisions of the Interna-
tional Building Code for new structures.
Moved structures are required to comply with the pro-
visions applicable to new construction, which is gen-
erally intended to mean the IBC. The moved structure
may comply with the alternative provisions of Chapter
14 instead of the code requirements for new struc-
tures, which may be particularly useful if the moved
structure is older than the effective date of the adop-
tion of the building codes in the jurisdiction. The fire
separation distance of the moved structure must
comply with requirements for new structures even if
the compliance alternative provisions of Chapter 14
are used to meet the code requirements.
SECTION 410
ACCESSIBILITY FOR EXISTING BUILDINGS
410.1 Scope. The provisions of Sections 410.1 through 410.9
apply to maintenance, change of occupancy, additions and
alterations to existing buildings, including those identified as
historic buildings.
4-The purpose of Section 410 is to establish minimum
criteria for accessibility when dealing with existing
buildings and facilities. The history and efforts
involved are similar to those discussed in the com-
mentary for IBC Chapter 11. Access to buildings and
structures for people with physical disabilities has
been a subject that the building codes have regulated
since the early 1970s. They have consistently relied
on a consensus national standard, ICC A117.1,
Accessible and Useable Buildings and Facilities.
Accessibility is not a new subject to the construction
regulatory community. There has been a great deal of
emphasis and awareness placed on the subject of
accessibility through the passage of two federal laws.
The Americans with Disabilities Act (ADA) and the
Fair Housing Amendment Act (FHA) are federal regu-
lations that affect building construction as it relates to
accessibility.
The International Code Council' (ICCO) recog-
nizes the value of consistency between federal laws
and the codes. Efforts for coordination with federal
accessibility requirements are ongoing. Representa-
tives from interested accessibility groups, the Depart-
ment of Housing and Urban Development (HUD) and
the Architectural and Transportation Barriers Compli-
ance Board (ATBCB, commonly referred to as the
Access Board), have been attending and participating
in the code change process for the IBC and ICC
A117.1. In addition, the ICC has participated in the
public comment process on the development of fed-
eral regulations for accessibility. Appendix B includes
information found in the Americans with Disabilities
Act Accessibility Guidelines (ADAAG) that cannot be
enforced through the typical code enforcement pro-
cess, but would provide beneficial information for the
designer/owner for full compliance purposes. The
ICC has worked toward, and will continue to strive
for, accessibility regulations that reflect the highest
possible degree of consistency with federal regula-
tions and, more importantly, reasonable and appro-
priate provisions to meet the needs of people with
disabilities.
Buildings undergoing alterations are generally
expected to fully comply with the accessibility provi-
sions. However, exceptions are then provided to indi-
cate the conditions und*r which less than full
accessibility is permitted.
For example, if a door and frame are removed and
replaced, the door must meet the requirements for
width, height, maneuvering clearances and hard-
ware. If just the doorknob is being removed, it must
be replaced with lever hardware.
If the area undergoing alteration does not contain a
primary function, there are no additional require-
ments; however, if the area contains a primary func-
tion, there is an additional criterion that may require
work not in the original scope to achieve accessibility.
This additional criterion is to provide an accessible
2015 INTERNATIONAL EXISTING BUILDING CODE" COMMENTARY
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route to the altered area, including any toilets and
drinking fountains that serve it. Requirements for an
accessible route might specify that the door previ-
ously discussed be removed and replaced because it
did not have adequate width or maneuvering clear-
ances.
The principle behind this approach to upgrading
existing buildings is that they will become more
accessible over time. A valid time to work toward that
goal is when a structure is being altered. Special con-
siderations are offe(bd because of the difficulty
involved in dealing with existing facilities that may not
have been built with accessibility for physically dis-
abled persons in mind. For example, when a histori-
cally registered home is being made into a museum,
if changing the front door to allow for wheelchair
access would alter the historical significance, alterna-
tives are offered in Section 410.9. Other examples
include the alternatives offered in Section 410.7 if it is
technically infeasible to provide full accessibility in an
existing building. Please note that the term "techni-
cally infeasible" refers to either movement of a major
structural element or other physical constraints. For
example, a ramp to provide entrance or exit from a
particular door may not be possible because of prop-
erty lines or setback constraints.
410.2 Maintenance of facilities. Afacility that is constructed
or altered to be accessible shall be maintained accessible
during occupancy.
4- Continued compliance with the accessibility require-
ments of the code is dependent on maintenance of
such facilities throughout the life of the building. For
example, drinking fountains that are required to be
accessible are of little value if they malfunction
through deterioration or failure of any of the working
parts. In other cases, inoperable elevators, locked
accessible doors and obstructed accessible routes
must be maintained such that they are readily usable
by individuals with disabilities.
410.3 Extent of application. An alteration of an existing
facility shall not impose a requirement for greater accessibil-
ity than that which would be required for new construction.
Alterations shall not reduce or have the effect of reducing
accessibility of afacility or portion of afacility.
The purpose of this section is to clarify where alter-
ations and scoping for alteration requirements apply.
The requirements in Sections 410.6 and 410.7 do not
impose a higher level of accessibility than the level
required in new construction. At the same time, alter-
ations cannot result in a lesser degree of accessibility
than existed before the alterations were undertaken.
410.4 Change of occupancy. Existing buildings that undergo
a change of group or occupancy shall comply with this sec-
tion.
Exception: Type B dwelling or sleeping units required by
Section 1107 of the International Building Code are not
required to be provided in existing buildings and facilities
undergoing a change of occupancy in conjunction with
alterations where the work area is 50 percent or less of the
aggregate area of the building.
When an entire building undergoes a change of occu-
pancy, the building must comply with the provisions in
Section 410.4.2. If a portion of a building undergoes a
change of occupancy, such as when there is a tenant
change or a partial renovation where a space
changes function, then the level of accessibility is
addressed in Section 410.4.1.
The exception notes where Type B dwelling and
sleeping units would not need to be included where
there is a change of occupancy to a Group I or R
building (see Section 1107 of the IBC). Where the
change of occupancy does not involve extensive
alterations (exceeding 50 percent of the square foot-
age of the building), then Type B accessibility require-
ments would not need to be provided in the new or
altered dwelling or sleeping units. This exception is
similar to what is also found in the code for alterations
where less than a Level 3 alteration occurs. A Level 3
alteration is greater than 50 percent of the square
footage of the building. This, therefore, decreases the
burden on many smaller projects. Type B dwelling
units should be provided in larger alterations
because, where major alterations are being per-
formed, there is a prime opportunity to have those
buildings move toward being able to serve a wider
range of the population. With the population of the
United States aging, there will be a steadily increas-
ing demand for units that include accessibility fea-
tures. See the commentary to Section 410.4.2,
Section 410.6, Exception 4, and Section 410.8.8 for
additional information.
410.4.1 Partial change in occupancy. Where a portion of the
building is changed to a new occupancy classification, any
alterations shall comply with Sections 410.6, 410.7 and
410.8.
4-When a building undergoes a partial change of occu-
pancy, such as where there is a tenant change or a
change in function of a specific area, then the level of
accessibility provided must achieve the same level as
if that space were undergoing an alteration. Basically,
the intent is that any spaces or elements being
altered will meet new accessibility provisions unless
technically infeasible (see Section 410.6). If the area
changing occupancy is a primary function of the
space, an evaluation of the accessible route, as well
as bathrooms and drinking fountains serving this
space, must be made. If these elements are not
accessible, improvements must be made. However,
there is a limit to the cost of the additional improve-
ments to a maximum of 20 percent of the cost of the
alteration (see Section 410.7). The reference to Sec-
tion 410.8 provides for additional allowances because
the designer/owner is still dealing with existing build-
ing constraints. For example, the accessible route
could be provided by a platform lift (see Section
410.8.3), while in new construction, this option is lim-
ited (see IBC Sections 1009.5 and 1109.8).
4-18 2015 INTERNATIONAL EXISTING BUILDING CODEO COMMENTARY
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410.4.2 Complete change of occupancy. Where an entire
building undergoes a change of occupancy, it shall comply
with Section 410.4.1 and shall have all of the following
accessible features:
1. At least one accessible building entrance.
2. At least one accessible route from an accessible build-
ing entrance to primary function areas.
3. Signage complying with Section 1111 of the Interna-
tional Building Code.
4. Accessible parking, where parking is being provided.
5. At least one accessible passenger loading zone, when
loading zones are provided.
6. At least one accessible route connecting accessible
parking and accessible passenger loading zones to an
accessible entrance.
Where it is technically infeasible to comply with the new
construction standards for any of these requirements for a
change of group or occupancy, the above items shall conform
to the requirements to the maximum extent technically feasi-
ble.
Exception: The accessible features listed in Items I
through 6 are not required for an accessible route to Type
B units.
4- For a project that involves a complete change of
occupancy with alterations, full compliance with
accessibility requirements is expected and reason-
able for areas being altered, except where technical
infeasibility can be demonstrated. If full compliance is
technically infeasible, the element must be made
accessible to the fullest extent that is feasible. This is
consistent with the general approach that has always
been taken relative to other matters regulated by the
code.
In addition to accessibility requirements in the
space, an accessible route is required to that space.
Six items that make up that accessible route are
listed. This section establishes that when an existing
building undergoes a complete change of occupancy,
compliance with those requirements, at minimum, is
expected. That way, a person with mobility impair-
ments would be able to arrive at the building (see
Items 4 and 5), get to the accessible entrance (see
Items 1, 3 and 6) and have at least one accessible
route throughout the building to all the primary func-
tion areas (see Item 2). Changes between levels
could be via a ramp (see Section 410.8.5), an eleva-
tor (see Section 410.8.2) or a platform lift (see Sec-
tion 410.8.3). If the altered area would not be
required to be served by an accessible route in new
construction, an accessible route would not be
required for a change of occupancy (see Section
410.3).
If the area undergoing a change of occupancy is
being altered and contains a primary function area,
the accessible route provisions in Section 410.7 are
also applicable. This would not only require an acces-
sible route to the change of occupancy area, but
would also include possible upgrades to toilet rooms
and drinking fountains that serve the area. These ele-
ments could use the 20-percent cap on cost offered
in Section 410.7, Exception 1. If full compliance is
technically infeasible, the element must be made
accessible to the fullest extent that is feasible. See
the commentary to Section 410.7 for additional infor-
mation on the exceptions.
Typically, a building undergoing a complete change
of occupancy is being, at least partially, gutted and
undergoing alterations because of changes in func-
tion, possibly caused by increased occupant load,
means of egress requirements, sprinkler require-
ments, or mechanical and plumbing changes. The
intent is to create a balance between the change of
occupancy meeting all new construction require-
ments for accessibility and the fact that the designer/
owner is dealing with some existing building condi-
tions.
This is not based on any specific provisions of the
ADAAG, but parallels the intent of the requirements
for the removal of barriers.
If the change of occupancy results in a Type B
dwelling unit being provided, the exception permits
the building to be exempt from providing the addi-
tional accessible route requirements listed in this sec-
tion. This allowance addresses concerns of site
impracticality for existing structures. This also rein-
forces the intent that the inclusion of Type B units is
not meant to require elevators when alterations are
performed on upper floors in nonelevator buildings
(see the exceptions to Section 1107.7). These areas
would have been exempted if built new under the
FHA and IBC, and should continue to be exempted.
410.5 Additions. Provisions for new construction shall apply
to additions. An addition that affects the accessibility to, or
contains an area of, a primary function shall comply with the
requirements in Section 410.7.
4-Additions must comply with new construction. An
addition, however, is also an alteration to an existing
building; therefore, accessible route provisions for
existing buildings are applicable (see commentary,
Section 410.6). For example, a new dining area is
added in a restaurant. All accessible elements within
the parameter of the addition must be constructed to
be accessible. If the route ib or from the addition, or
the bathrooms or drinking fountains that serve the
addition, are in the existing building, the routes must
be evaluated for accessibility. Section 410.7 specifies
that the accessible route would include the route to
these elements, the toilet rooms themselves, the fix-
tures in the toilet room and the drinking fountains.
410.6 Alterations. Afacility that is altered shall comply with
the applicable provisions in Chapter 11 of the International
Building Code, unless technically infeasible. Where compli-
2015 INTERNATIONAL EXISTING BUILDING CODE" COMMENTARY 4-19
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ance with this section is technically infeasible, the alteration
shall provide access to the maximum extent technically feasi-
ble.
Exceptions:
1. The altered element or space is not required to be on
an accessible route, unless required by Section
410.7.
2. Accessible means of egress required by Chapter 10
of the International Building Code are not required
to be provided in I!xisting facilities.
3. The alteration to Type A individually owned dwell-
ing units within a Group R-2 occupancy shall be
permitted to meet the provision for a Type B dwell-
ing unit.
4. Type B dwelling or sleeping units required by Sec-
tion 1107 of the International Building Code are not
required to be provided in existing buildings and
facilities undergoing a change of occupancy in con-
junction with alterations where the work area is 50
percent or less of the aggregate area of the building.
4-The code approaches the application of accessibility
provisions to a facility that is altered by broadly
requiring full conformance to new construction,
meaning full accessibility is expected. Exceptions are
then provided to indicate the conditions under which
less than full accessibility is permitted.
The circumstance under which full compliance with
accessibility provisions is not required is when it is
deemed to be technically infeasible (see the com-
mentary for the definition of "Technically infeasible" in
Section 202). This is considered reasonable since, if
not provided for, plans for alterations may be other-
wise abandoned by the building owner. The opportu-
nity to upgrade and increase the current level of
accessibility in an existing building would then be lost.
This concern is also embodied in the requirement that
an altered element or space is expected to be made
accessible to the extent to which it is technically fea-
sible to do so. In this manner, the code accomplishes
the greatest degree of accessibility while recognizing
the justifiable difficulties that may be involved in pro-
viding full accessibility. Alterations are not required to
exceed new construction requirements (see Section
410.3).
In accordance with Exception 1, if the area under-
going alteration does not contain a primary function
(see Section 410.7), there are no additional require-
ments past the original scope of the project. However,
if the area contains a primary function, there are addi-
tional criteria to achieve accessibility that may require
work not in the original scope of the project. The addi-
tional criteria are to provide an accessible route to the
altered area, as well as improvements to any toilets
and drinking fountains that serve the altered area.
Exception 2 indicates that accessible means of
egress are not required as a result of undertaking
alterations to existing buildings. Strict compliance
with IBC Section 1009 is often technically infeasible.
The requirement for a 48-inch (1219 mm) clear width
between handrails would require many stairways to
be widened. This often would entail movement of
major structural elements in order to accomplish this
alteration.
Exception 3 addresses the specific circumstances
where an existing Type A dwelling unit is being
altered. While Section 410.2 says that a level of
accessibility must be maintained, in the situations
where a Type A dwelling unit is "individually owned,"
such as a condominium, then it only needs to meet
the technical requirements for a Type B dwelling unit
(see I CC Al 17. 1, Section 1004) when it is altered or
remodeled by the owner. Type B units require a
lesser level of accessibility than Type A units. For
example, if an owner wanted to alter the bathroom in
his or her unit, he or she would only be required to
meet the lesser accessibility requirements of a Type
B unit with the new construction. This exception
would not be applicable to units that are for rent.
Exception 4 allows some partial building alterations
in Group I and R structures to occur without providing
Type B dwelling units and sleeping units (see Section
1107). Where the alteration does not exceed 50 per-
cent of the square footage of the building, then Type
B accessibility requirements would not need to be
provided in the dwelling or sleeping units being
altered (see Sections 410.8.6 and 410.8.7 for alter-
ations where Accessible units and Type A units are
required). This exception is similar to what is also
found in the code for change of occupancy where
less than a Level 3 alteration is occurring. A Level 3
alteration is greater than 50 percent of the square
footage of the building. This decreases the burden on
many smaller projects.
Type B dwelling units must be provided in larger
alterations. Where major alterations are being per-
formed, there is a prime opportunity to have those
buildings move toward being able to serve a wider
range of the population. With the population of the
United States aging, there will be a steadily increas-
ing demand for units that include accessibility fea-
tures. In addition, while the Fair Housing Act (FHA) is
only applicable to new construction, this law was
enacted in 1991. Some buildings constructed after
that time may not be in compliance with the FHA.
When a major alteration/renovation is occurring,
there is an opportunity to bring those buildings into
compliance. See the commentary to Sections 410.4.2
(the exception), 410.8.6, 410.8.7 and 410.8.8 for
additional information.
4-20 2015 INTERNATIONAL EXISTING BUILDING CODE" COMMENTARY
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410.7 Alterations affecting an area containing a primary
function. Where an alteration affects the accessibility to, or
contains an area of primary function, the route to the primary
function area shall be accessible. The accessible route to the
primaryfunction area shall include toilet facilities and drink-
ing fountains serving the area of primary function.
Exceptions:
I . The costs of providing the accessible route are not
required to exceed 20 percent of the costs of the
alterations affecting the area of primary function.
2. This provision does not apply to alterations limited
solely to windows, hardware, operating controls,
electrical outlets and signs.
3. This provision does not apply to alterations limited
solely to mechanical systems, electrical systems,
installation or alteration of fire protection systems
and abatement of hazardous materials.
4. This provision does not apply to alterations under-
taken for the primary purpose of increasing the
accessibility of afacility.
5. This provision does not apply to altered areas lim-
ited to Type B dwelling and sleeping units.
-*.-An area containing a primary function is one in which
a major activity for which the building or facility is
intended is carried out (see the definition of "Primary
function" in Section 202). For example, the lobby of a
hotel in which the registration and check-out desk is
located would be a primary function area. Other
examples would be the dining area of a restaurant,
the meeting rooms or exhibition halls in a conference
center, virtually all office and work areas in a busi-
ness building, and retail display areas in a mercantile
occupancy. The key concept is that a primary func-
tion area is one that contains a major activity of the
facility. Areas that contain activities not related to the
main purpose of the facility would not be considered
a primary function area. For example, a mechanical
equipment room, storage closet, toilet facilities, corri-
dors, lounges and locker rooms would not be consid-
ered primary function areas. With this background, it
is clear that areas containing a primary function are
clearly more critical in terms of the purpose for which
people enter and use the facility; therefore, this sec-
tion reflects that when such areas are altered or
added, it is important to require that an accessible
route to the primary function area be provided. When
an accessible route to a primary function area is
required by this section, an accessible route to such
facilities, including any restrooms and drinking foun-
tains serving the primary function area, must also be
made accessible, even though such facilities and
areas may not by themselves be considered primary
function areas. This is not just the route to the bath-
rooms and drinking fountains; the bathrooms and
drinking fountains themselves must also be improved
when not accessible.
There are conditions under which it may not be
reasonable to strictly enforce this requirement for an
accessible route to an altered or added primary func-
tion area. Exception 1 approaches this by utilizing the
cost of the alterations or addition as a basis for deter-
mining if providing a complete accessible route is rea-
sonable. The requirement for a complete accessible
route does not apply when the cost of providing it
exceeds 20 percent of the cost of the alterations or
addition to the primary function area. These costs are
intended to be based on the actual costs of the
planned alterations or addition to the primary function
area before consideration of the cost Qf_providing an
F-- - - - - - -
accessible route. For example, if the planned alter-
lations will cost $100,000, not including the cost of an
,accessible route to a primary function area, this
I exception would apply if the additional cost of provid-
,ing the accessible route would exceed $20,000.
It is not the intent to exempt all requirements for
accessibility when the total cost for providing the
�accessible route exceeds the 20-percent threshold.
Improvements to the accessible route are required to
ithe extent that costs do not exceed 20 percent of the
Icost to the planned alteration or addition. It is not
,required that the full 20 percent be spent. If the
1accessible route (including accessible bathrooms and
drinking fountains) is already provided, no additional
is required. Note that there is not a prior-
ity-Iia—grven—for—whererrioney shwuid-ue- sp—e—nt-o—n
improving the accessible route. The logical progres-
sion is access to the site, accessible exterior routes
to accessible entrances, access throughout the facil-
ity, access to services in the facility, toilet and bathing
rooms and, finally, drinking fountains. Evaluation on
how and where the money available should best be
spent must be made on a case -by -case basis. For
example, if an accessible route is not available to an
upper level, and the cost of an elevator is more than
20 percent of the cost of the renovation, then other
alternatives could be investigated, such as a platform
lift or limited access elevator, or adding the elevator
pit and shaft at this time, with elevator equipment
added later. If all such items are in excess of the 20-
percent limit, perhaps the money available could be
spent toward making the toilet rooms accessible. The
idea is that existing buildings would become fully
accessible over time.
Exceptions 2 and 3 identify certain alterations that
are not intended to trigger the requirement for provid-
ing an accessible route to a primary function area.
Alterations limited to such, elements as windows,
hardware, operating controls, electrical outlets, sig-
nage, mechanical, electrical and fire protection sys-
tems, including alterations for the purpose of abating
a hazardous materials circumstance, do not affect the
usability of a primary function area in the same man-
ner as alterations that affect the floor plan or the con-
figuration, location or size of rooms or spaces. It is
therefore considered unreasonable to require the
installation of an accessible route when the scope of
alterations is limited to that reflected in these excep-
tions.
2015 INTERNATIONAL EXISTING BUILDING CODE" COMMENTARY
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Note that the costs for these items are not "backed
out" of the total cost for the alteration before applying
Exception 1. Exceptions 2 and 3 are alterations lim-
ited to the specific items referenced.
Exception 4 is intended to avoid penalizing a build-
ing owner who is undertaking alterations or additions
for the purpose of increasing accessibility. It is appro-
priate to encourage owners to make such alterations
without requiring them to do more work simply
because they chose to increase the accessibility of
the space. This coulo otherwise have the opposite
effect of discouraging such alterations to avoid the
expense of undertaking more work and expense than
was originally planned. For example, federal law
(ADA) requires that owners of existing buildings
remove certain existing barriers to accessibility.
Removal of such barriers may require a permit from
the code official. It would be unreasonable to have
such activity trigger the mandatory requirement for
further alterations to accomplish accessibility beyond
the originally planned work. In principle, the code
takes the view that some extent of greater accessibil-
ity is positive progress and should be encouraged,
not penalized.
Where the alterations result in Type B dwelling
units being provided where none previously existed
(Section 410.6, Exception 4), Exception 5 would obvi-
ate the need for any additional money to be spent
toward providing an accessible route to those Type B
dwelling or sleeping units. This is intended to encour-
age the creation of such units without penalizing
building owners. Similar to Section 410.4.2, this
exception is intended to address the concerns of site
impracticality for providing accessible routes to and
into existing buildings providing Type B dwelling
units.
This also reinforces the intent that the inclusion of
Type B units is not meant to require elevators when
alterations are performed on upper floors in nonele-
vator buildings (see exceptions to Section 1107.7).
These areas would have been exempted if built new
under the FHA and IBC, and should continue to be
exempted.
410.8 Scoping for alterations. The provisions of Sections
410.8.1 through 410.8.14 shall apply to alterations to existing
buildings andfacilities.
4-The specific provisions of this section are intended to
reflect conditions under which less than full accessi-
bility, as would be required in new construction, is
permitted in altered areas. As previously discussed,
Section 410.6 requires alterations to comply with the
full range of access i bi I ity-rel ated provisions of the
code for new construction. This section reflects a rea-
sonable set of conditions under which a different level
of accessibility can be provided. Sections 410.8.1
through 410.8.14 are part of the code's coordination
effort with ICC Al 17.1 and the recommendations for
the ADAAG Review Federal Advisory Committee.
410.8.1 Entrances. Accessible entrances shall be provided in
accordance with Section 1105.
Exception: Where an alteration includes alterations to an
entrance, and the facility has an accessible entrance, the
altered entrance is not required to be accessible, unless
required by Section 410.7. Signs complying with Section
I 111 of the International Building Code shall be provided.
This provision is contained here to point to the acces-
sibility provisions of IBC Chapter 11 for entrances. A
facility is not accessible if the entrances into it are
inaccessible. IBC Section 1105 establishes reason-
able criteria for providing accessible entrances. A
facility is not required to have all of its entrances
accessible in order to provide reasonable accommo-
dation to disabled persons. If a facility has multiple
public entrances, it is not considered unreasonable to
require at least 60 percent of the entrances to be
accessible. In addition to the 60-percent accessible
public entrances requirement, entrances that have a
specific function or provide access to only certain por-
tions of the facility must be addressed.
If the building already has the accessible entrances
required by IBC Section 1105, an entrance that is
being altered is not required to be made accessible;
however, if the entrance was required to be made
accessible as part of the route to the altered primary
function area, the exception would not apply. If
entrances are not accessible, appropriate signage
marking such entrances and directing persons with
disabilities to the nearest accessible entrance is
required.
410.8.2 Elevators. Altered elements of existing elevators
shall comply with ASME A 17.1 and ICC A 117. 1. Such ele-
ments shall also be altered in elevators programmed to
respond to the same hall call control as the altered elevator.
Requirements for new construction state that all ele-
vators on an accessible route must be fully accessi-
ble in accordance with ICC Al 17. 1. If a passenger
elevator is altered, the altered element must be
accessible in accordance with the requirements for
existing elevators in Section 407 of ICC Al 17.1. If the
altered elevator is part of a bank of elevators, the
same element must be made accessible in every ele-
vator that is part of that bank. The purpose of this
requirement is to have consistency among elevators
in a bank so that disabled people are not required to
wait for a specific elevator when the general popula-
tion can take the first available elevator. ICC Al 17.1
also provides accessibility requirements for limited
use/limited access (LULA) elevators (ICC A117.1,
Section 408) and private residence elevators (ICC
Al 17.1, Section 409). While these types of elevators
can serve as part of an accessible route, their use is
limited by ASIVIE Al 7. 1.
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410.8.3 Platform lifts. Platform (wheelchair) lifts complying
with ICC A117.1 and installed in accordance with ASME
A18.1 shall be permitted as a component of an accessible
route.
4-This section provides for the use of platform (wheel-
chair) lifts in existing buildings. In order to create an
accessible route where there are changes in floor lev-
els, the provisions for new construction would most
often require the installation of an elevator or ramp.
Platform lifts are allowed in new construction for lim-
ited conditions (see IBC Section 1109.8). If the space
in an existing building precludes the installation of an
elevator or ramp, a platform lift may be the only prac-
tical solution. Given the choice between no accessi-
bility or accessibility by a platform lift, accessibility is
preferable.
Previously, platform lift requirements were
addressed in the elevator standard, ASIVIE Al 7. 1, but
they are now addressed in their own standard, ASIVIE
Al 8. 1. One of the many changes was the removal of
the requirement for key operation, which previously
discouraged independent utilization of platform lifts.
Note that, in accordance with IBC Section 1009.5,
platform lifts are also permitted for an accessible
means of egress; however, accessible means of
egress are not required in existing buildings undergo-
ing alterations in accordance with IBC Section 410.6,
Exception 2.
A chair lift is not acceptable as part of an accessi-
ble route in either new or existing construction. For
examples of the difference between a chair lift and a
platform lift, see the commentary to Section 1109.8 of
the IBC.
410.8.4 Stairways and escalators in existing buildings. In
alterations, change of occupancy or additions where an esca-
lator or stairway is added where none existed previously and
major structural modifications are necessary for installation,
an accessible route shall be provided between the levels
served by the escalator or stairways in accordance with Sec-
tion 1104.4 of the International Building Code.
4- If a stairway or escalator is added as part of an alter-
ation in a location where one did not previously exist,
the alteration must also include an accessible route
between the same two levels. Where major structural
modifications are required to install the stairway,
there is no longer the argument that it is technically
infeasible to add the accessible route to the other
level. If an accessible route is already available
between the two levels, or if the stairway or escalator
is replacing an existing stairway or escalator, this
requirement is not applicable. In conjunction with
Section 410.3, if the requirement for the accessible
route would be in excess of what is required for new
construction, such as an accessible route to an area
that was exempted by IBC Section 1103.2, 1104.4,
1107 or 1108, this requirement is not applicable. The
intent is that if a route is provided between accessible
levels for a nondisabled person to use, it is reason-
able to also expect an accessible route.
410.8.5 Ramps. Where slopes steeper than allowed by Sec-
tion 1012.2 of the International Building Code are necessi-
tated by space limitations, the slope of ramps in or providing
access to existing facilities shall comply with Table 410.8.5.
4-This section recognizes the circumstances where,
due to existing site or configuration constraints, a
ramp with a slope of one unit vertical in 12 units hori-
zontal (1:12) may not be feasible. A steeper slope is
allowed where the elevation change does not exceed
6 inches (152 mm). Further ramp requirements, such
as width, landings, etc., are set forth in IBC Section
1012.
TABLE 410.8.5
RAMPS
SLOPE
MAXIMUM RISE
Steeper than 1: 10 but not steeper than 1: 8
3 inches
Steeper than 1: 12 but not steeper than 1: 10
6 inches
For SI: I inch = 25.4 mm.
In existing buildings, ramps that rise 3 inches (76
mm) or less may have a slope as steep as one unit
vertical in eight units horizontal (1:8). In existing build-
ings, ramps that rise 6 inches (152 mm) or less may
have a slope as steep as one unit vertical in 10 units
horizontal (1:10). If it is possible to provide a lesser
slope, it is desirable to do so. These steeper slopes
should only be utilized when the one unit vertical in
12 units horizontal (1:12) slope is not possible.
410.8.6 Accessible dwelling or sleeping units. Where Group
1-1, 1-2, 1-3, R-1, R-2 or R-4 dwelling or sleeping units are
being altered or added, the requirements of Section 1107 of
the International Building Code for Accessible units apply
only to the quantity of spaces being altered or added.
4-This section sets forth the rate for providing Accessi-
ble dwelling or sleeping units in Groups 1-1, 1-2, 1-3,
R-1, R-2 and R-4 where such facilities are altered or
where units are added. Assuming that Accessible
units are not already provided, the number of Acces-
sible units to be incorporated into each alteration is
based on the number being altered or added. For
example, if a nursing home was being altered a por-
tion at a time, 50 percent of the units being altered
each time would be required to be fully wheelchair
accessible. It is not the intent that all units being
altered are required to be Accessible units until 50
percent of the units in the entire facility are Accessi-
ble. The total number of Ac2essible units in the facility
is not required to exceed Mat required for new con-
struction. It is unreasonable to require a greater level
of accessibility in an existing building than is required
in new construction.
410.8.7 Type A dwelling or sleeping units. Where more
than 20 Group R-2 dwelling or sleeping units are being
altered or added, the requirements of Section 1107 of the
International Building Code for Type A units apply only to
the quantity of the spaces being altered or added.
4-Type A units are required in new construction where
20 or more apartments (including condominium style)
are constructed on a site. Group R-2 requirements for
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Type A units would also include convents and mon-
asteries and could include some townhouse -style
units (see the commentary to IBC Section
1107.6.2.2.1 for additional information).
Note that this requirement is applicable when 20 or
more units are included in the construction project;
not when an individual owner performs alterations to
his or her condo when there are 20 or more units in
the building. This section sets forth the rate for pro-
viding Type A dwelling or sleeping units in Group R-2
facilities in an addition%vhere there is a change to the
function of a space (i.e., a change of occupancy,
such as creating apartments in an old warehouse,
increasing the number of apartments by changing a
storage area to apartment units or reconfiguring
larger units into smaller units) or an alteration.
Assuming that Type A units are not already provided,
the number of Type A units required is based on the
number being added or altered. For example, if a
story was being added to an apartment building or a
story in an apartment building was being altered, the
number of Type A units required would be based on
the number of units in the new story or the area being
altered, not the number of units in the entire building.
If Type A units are provided, the total number of Type
A units in the facility is not required to exceed that
required for new construction, as indicated in Section
410.3. It is unreasonable to require a greater level of
accessibility in an existing building than is required in
new construction.
410.8.8 Type B dwelling or sleeping units. Where four or
more Group 1-1, 1-2, R-1, R-2, R-3 or R-4 dwelling or sleep-
ing units are being added, the requirements of Section 1107
of the International Building Code for Type B units apply
only to the quantity of the spaces being added. Where Group
1-1, 1-2, R-1, R-2, R-3 or R-4 dwelling or sleeping units are
being altered and where the work area is greater than 50 per-
cent of the aggregate area of the building, the requirements of
Section 1107 of the International Building Code for Type B
units apply only to the quantity of the spaces being altered.
In new construction, Type B units are required where
four or more dwelling units or sleeping units are con-
structed together and those units are "intended to be
occupied as a residence" (see commentary, IBC Sec-
tion 1107). The IRC references IBC Group R-3 for
accessibility requirements for IRC units (see the defi-
nition of "Townhouse" and IRC Section R320.1).
This section sets forth the rate for providing Type
B dwelling or sleeping units in Group 1-1, 1-2, R-1, R-
2, R-3 or R-4 facilities. Type B units are required
where more than four units are added in an addition
or where major alterations are occurring that affect
more the 50 percent of the area of the building. The
Type B units in the facility are not required to exceed
that required for new construction, as indicated in
Section 410.3 and IBC Section 1107.7. It is unrea-
sonable to require a greater level of accessibility in an
existing building than is required in new construction.
In consideration of existing site constraints, Sections
410.4.2 and 410.7 also include exceptions for the
additional accessible route requirements in structures
where Type B units are added as part of an alteration
or change of occupancy. Note that this exception is
not applicable to additions where Type B units are
required.
410.8.9 Jury boxes and witness stands. In alterations,
accessible wheelchair spaces are not required to be located
within the defined area of raised jury boxes or witness stands
and shall be permitted to be located outside these spaces
where the ramp or lift access restricts or projects into the
means of egress.
4- This exception for jury boxes and witness stands is
consistent with Sections 231 and 808 of the 2010
ADA Standards for Accessible Design. The intent is
that if ramp access to a jury box or witness stand
would have the ramp limiting or blocking the means
of egress for the general population in the space,
alternative locations for potential jurors or witnesses
are viable. The same alternative is available if a plat-
form lift would effectively be an obstruction for the
general means of egress from the courtroom.
410.8.10 Toilet rooms. Where it is technically infeasible to
alter existing toilet and bathing rooms to be accessible, an
accessible family or assisted -use toilet or bathing room con-
structed in accordance with Section 1109.2.1 of the Interna-
tional Building Code is permitted. The family or assisted -use
toilet or bathing room shall be located on the same floor and
in the same area as the existing toilet or bathing rooms. At the
inaccessible toilet and bathing rooms, provide directional
signs indicating the location of the nearest family or assisted -
use toilet room or bathing room. These directional signs shall
include the International Symbol of Accessibility and sign
characters shall meet the visual character requirements in
accordance with ICC A 117. 1.
4-This section deals with circumstances in which it is
technically infeasible to alter existing toilet facilities to
be accessible. Where new bathrooms are created in
existing buildings or existing bathrooms are part of an
alteration, both the men's and women's facilities
would be required to be accessible. An alternative
solution when it is technically infeasible to alter the
existing toilet rooms would be the creation of a single
unisex toilet or bathing room containing accessible
facilities. The requirements for family or assisted -use
toilet facilities in IBC Sections 1109.2.1 through
1109.2.1.7 provide guidance on what is required in
such toilet rooms. If this alternative is selected, the
room must be located on the same floor and in the
same area as the existing toilet or bathroom. This is
the best alternative to providing fully complying sepa-
rate men's and women's facilities. One might argue
that it is technically infeasible to accomplish either of
these alternatives, since the alternative to altering
existing facilities involves creation of an additional toi-
let or bathroom that was not otherwise contemplated.
This would not be a persuasive argument, since there
is likely to be space available somewhere in the facil-
ity to commit for use as a toilet or bathroom. In any
case, the intent is that some form of an accessible toi-
4-24
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let room or bathing facility is necessary and must be
provided.
It should be noted that this alternative is not
offered as a choice between making the existing sep-
arate -sex toilet rooms accessible or providing a fam-
ily or assisted -use accessible toilet room. The
existing separate -sex toilet rooms must be altered
when it is technically feasible. Consideration of this
alternative is only available when altering the existing
toilet rooms is technically infeasible (see the defini-
tion of "Technically infeasible" in Section 202).
Signage must be provided at the inaccessible toilet
rooms in accordance with IBC Sections 1110.1 and
1110.2 to notify disabled persons where a facility is
not accessible and direct them to the nearest acces-
sible facilities.
410.8.11 Dressing, fitting and locker rooms. Where it is
technically infeasible to provide accessible dressing, fitting or
locker rooms at the same location as similar types of rooms'
one accessible room on the same level shall be provided.
Where separate -sex facilities are provided, accessible rooms
for each sex shall be provided. Separate -sex facilities are not
required where only unisex rooms are provided.
-*.-This section takes a similar approach for dressing
rooms as provided for in Section 410.8.10 for toilet
rooms and bathing facilities. If it is technically infeasi-
ble to alter existing dressing rooms to be accessible,
then space elsewhere on the level -must be commit-
ted to providing no less than one accessible dressing
room. In this case, if the existing dressing rooms pro-
vide separate rooms for each sex, then no less than
one accessible dressing room for each sex must be
provided.
410.8.12 Fuel dispensers. Operable parts of replacement fuel
dispensers shall be permitted to be 54 inches (1370 mm)
maximum, measuring from the surface of the vehicular way
where fuel dispensers are installed on existing curbs.
4-The requirements for new fuel dispensers (i.e., gas
pumps) can be found in Section 1109.14 of the IBC.
Basically, the idea is that the controls must be within
the reach ranges for someone standing on the park-
ing lot surface. However, many existing facilities have
gas pumps located on raised islands as a feature for
protection of the pumps from accidental contact. This
section would allow the new gas pump with the reach
range of 15 inches (380 mm) to 48 inches (1220 mm)
to be located on top of a 6-inch (150 mm) curb and
still meet the maximum reach of 54 inches (1370
mm).
410.8.13 Thresholds. The maximum height of thresholds at
doorways shall be '/4 inch (19.1 mm). Such thresholds shall
have beveled edges on each side.
4- Thresholds at doorways may be 3/4 inch (19.1 mm)
maximum in existing buildings. In new construction, a
typical threshold is 1/, inch (12.7 mm) maximum in
accordance with the IBC. This section recognizes
that such things as differences in floor materials may
create changes in elevation greater than that allowed
in new construction. Edges of thresholds must be
beveled to allow for the passage of a wheelchair.
410.8.14 Amusement rides. Where the structural or opera-
tional characteristics of an amusement ride are altered to the
extent that the amusement ride's performance differs from
that specified by the manufacturer or the original design, the
amusement ride shall comply with requirements for new con-
struction in Section 1110.4.8 of the International Building
Code.
4- To the extent that amusement rides are subject to the
accessibility requirements of IBC Section 1110.4.8,
they should be accessible and usable by individuals
with disabilities. These scoping provisions are flexi-
ble, permitting latitude in terms of the method of
access (e.g., transfer seat, roll-on seat or transfer
device to lift the rider). Mobile and portable rides are
exempted. Rides without seats, designed for children
who are assisted onto the ride or controlled by the
user are also exempted under IBC Section
1110.4.8.2 from providing wheelchair transfer
spaces. Technical criteria can be found in the 2009
ICC A117.1, Section 1102 and includes accessible
routes, load and unload areas, wheelchair spaces on
rides, seats for transfer, and transfer devices. Recog-
nizing the technical issues associated with existing
amusement rides, compliance with accessibility
requirements is required when the amusement ride is
extensively altered.
410.9 Historic buildings. These provisions shall apply to
facilities designated as historic structures that undergo alter-
ations or a change of occupancy, unless technically infeasi-
ble. Where compliance with the requirements for accessible
routes, entrances or toilet rooms would threaten or destroy the
historic significance of the facility, as determined by the
applicable governing authority, the alternative requirements
of Sections 410.9.1 through 410.9.4 for that element shall be
permitted.
Exception: Type B dwelling or sleeping units required by
Section 1107 of the International Building Code are not
required to be provided in historical buildings.
4-The regulations of individual adopting jurisdictions
may provide additional guidance or limitations on the
use of this section. Basic ADA requirements permit
exceptions and alternatives for historic buildings.
These minimum requirements provide reasonable
accommodations for building users.
For this section to be apolicable, the building must
be registered as historic. Historic buildings are
treated much the same as provided for in Sections
410.4 and 410.6, in that a historic building that is
altered or has undergone a change of occupancy is
expected to comply with accessibility requirements,
unless technical infeasibility can be demonstrated;
however, this section also goes on to acknowledge
that the historic character of a building may be
adversely affected by strict compliance with accessi-
bility provisions. For example, compliance with door
width requirements may necessitate the removal of
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an existing set of doors that is critical to the historic
character of the building. To assist the code official in
determining if the required provisions are detrimental
to the historic significance, recommended guidelines
have been incorporated into Appendix B, Section
B101.
This section is intended to exempt such conditions
in order to maintain the historic character of the build-
ing. Because limited extent of accessibility is desired
in all facilities, Sections 410.9.1 through 410.9.4 allow
for alternatives. In adcltion, there is an exception that
would exempt the Type B dwelling or sleeping unit
requirements for historical buildings, including when
the alteration exceeds 50 percent of the building. This
exception is important in that owners will not need to
demonstrate that the addition of such units will
threaten or destroy the historical character of the
building.
In an effort to coordinate with the 2010 ADA Stan-
dards for Accessible Design requirements, items that
cannot be enforced through the typical code enforce-
ment process, but are associated with historical build-
ings, have been included in Appendix B Section
B101.5.
410.9.1 Site arrival points. At least one accessible route
from a site arrival point to an accessible entrance shall be pro-
vided.
Full compliance would require an accessible route
from all site arrival points. If this requirement would
adversely affect the historical significance of the
building, the alternative available is to provide an
accessible route from one site arrival point to an
accessible entrance.
410.9.2 Multilevel buildings and facilities. An accessible
route from an accessible entrance to public spaces on the
level of the accessible entrance shall be provided.
It is not required in building alteration that accessibil-
ity to spaces above or below the level of accessible
entrance be provided. Full compliance for new con-
struction might require an accessible route to levels
above or below, as well as throughout, the entrance
level. If this requirement would adversely affect the
historical significance of the building, the alternative
is to provide an accessible route from the accessible
entrance to all spaces open to the public on the
entrance level. If elevators are provided, but are not
accessible, signage in accordance with IBC Section
1110.2 is required.
410.9.3 Entrances. At least one main entrance shall be acces-
sible.
Exceptions:
1. If a main entrance cannot be made accessible, an
accessible nonpublic entrance that is unlocked while
the building is occupied shall be provided; or
2. If a main entrance cannot be made accessible, a
locked accessible entrance with a notification sys-
tem or remote monitoring shall be provided.
Signs complying with Section 1111 of the International
Building Code shall be provided at the primary entrance and
the accessible entrance.
4-Although uniform building access is the rule for new
construction, older buildings may have main
entrances that are both inaccessible and a significant
element of the building's character. In these cases,
providing access by an alternative route is deemed to
meet the primary intent of the accessibility regula-
tions.
Full compliance would require 60 percent of the
entrances to be accessible. If this requirement would
adversely affect the historical significance of the
building, only one main entrance is required to be
made accessible. If a main entrance cannot be made
accessible, then an employee or service entrance
may serve as the accessible entrance, provided that
it remains unlocked when the building is open. Alter-
natively, a locked entrance, where monitoring or a
notification system is available, could be provided.
Signage must be provided at inaccessible entrances
in accordance with IBC Sections 1111.1 and 1111.2.
410.9.4 Toilet and bathing facilities. Where toilet rooms are
provided, at least one accessible family or assisted -use toilet
room complying with Section 1109.2.1 of the International
Building Code shall be provided.
4- Full compliance would require an accessible toilet/
bathing facility at each location where toilet/bathing
facilities are provided. If altering the existing facilities
to be accessible would adversely affect the historical
significance of the building, only one unisex bathroom
that complies with the accessible family or assisted -
use toilet/bathing requirements in IBC Section
1109.2.1 is required. Signage must be provided at
inaccessible toilet rooms in accordance with IBC Sec-
tion 1110.2.
Bibliography
The following resource materials were used in the
preparation of the commentary for this chapter of the
code.
24 CFR, Fair Housing Accessibility Guidelines (FHAG).
Washington, DC: Department of Housing and Urban
Development, 1991.
36 CFR, Parts 1190 and 1191 Final Rule, The Ameri-
cans with Disabilities Act (ADA) Accessibility Guide-
lines; Architectural Barriers Act (ABA) Accessibility
Guidelines. Washington, DC: Architectural and
Transportation Barriers Compliance Board, July 23,
2004.
E&II
2015 INTERNATIONAL EXISTING BUILDING CODE" COMMENTARY
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42 USC 3601-88, Fair Housing Amendments Act
(FHAA). Washington, DC: United States Code, 1988.
2010 ADA Standards for Accessible Design. Washing-
ton, DC: Department of Justice, September 15, 2010.
ASCE 7-10, Minimum Design Loads for Buildings and
Other Structures. American Society of Civil Engi-
neers, 2011.
DOJ 28 CFR, Part 36-91, Americans with Disabilities
Act (ADA). Washington, DC: Department of Justice,
1991.
FEMA 311-07, Residential Substantial Damage Estima-
tors In Your Community. Washington, DC: Federal
Emergency Management Agency, 2007.
FEMA P-758, Substantial ImprovementlSubstantial
Damage Desk Reference. Washington, DC: Federal
Emergency Management Agency, 2009.
NFPA 13-07, Installation of Sprinkler Systems. Quincy,
MA: National Fire Protection Association, 2007.
2015 INTERNATIONAL EXISTING BUILDING CODE" COMMENTARY 4-27