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STF2007-0018 App letter dated 7-10-07.pdfJeannine Graf RECEIVEDCity Official City of Edmonds .J4L 10 2007 Hand Delivered BUILDING Subject: Alternate Design Request / Old Milltown / Fire Protection Yard along South Property Line: Dear Ms Graf; We are requesting that the city consider an alternate design request to create a fire protection yard along the south property line of the subject property for the purpose of allowing openings along the south wall of the existing building that is currently proposed for renovation. Firstly, the following code sections establish the need and rationale for the requirement: IBC Section 1014.1 clearly states that an area related to our mixed use occupancies shall require a second exit where the occupant load exceeds 50 or more. From the information provided in our submitted plans we are clearly required to have access to two means of egress from the space and these have been provided IBC Section 1104 requires that the project provide an accessible route within the site from the building to the public way. The combination of our Accessible parking stall shown in the area of easement, and the confirmation of the acceptable accessible slopes along the City Alley and the easternmost edge of the south site, that we are in compliance in this area. IBC Section 1007 clearly requires that both means of egress from the second floor are accessible and that the Stairway shown, and the Accessible route indicated both satisfy the requirements of this section. We are proposing to establish this yard within the full area of a 15 foot accessibility easement running east to west across the full depth of the south adjacent lot, essentially running from the 5t' ave property line to the west to the property line adjoining the city alley at the easternmost line of the south property. The properties are as you know, under the same ownership, that of GPA inc, 51 W Dayton Street, Edmonds, Wa. 9927 Fust Alley Seattle, WA 98101 p 206-957-9800 f 206-682-3159 www.graceorchitectsplic.com We propose that providing the above described yard is equivalent to providing the fire separation distance to a property line required by IBC Table 704.8. A yard is defined as an "open space unobstructed from the ground to the sky,..." in ICB Section 202. Fire separation distance is defined as the distance measured from the building face to the closes interior lot line, measured at right angles from the face of the wall" in IBC Section 702.1 We are proposing that this yard exist completely within the referenced 15 foot easement. Per Table 704.8 (copy attached) the 15' yard in a protected building will allow us up to 45% of the wall running along the northernmost line of the yard to consist of exterior wall openings. Our current design proposes windows and doors making up a total of 23% of the total wall area, well under the total amount allowed. The Chart below illustrates our inventory of designed openings at this wall, and tabulates the relative percentage of exterior wall opening area. As you can see, we have designed a total of 476 s.f. of exterior wall openings in the south wall that is 2054 s.f. in total area. Mark South Wall Opening areas Ext. South wall of 5th and Dayton building 93 21 s.f. 2054 s.f. 92 39.27 s.f. 89/90/91 103.75 s.f. 88 39.27 s.f. Percentage of exterior wall openings 87 39.27 s.f. 475.761 2054 = 23% 86 40.1 s.f. 85 40.1 s.f. 47 153 s.f. 475.76 s.f. Jeannine, I hope that this is adequate to serve as our request for consideration as an alternate design for the creation of a fire yard at the south property of the Old Milltown Project. We have forwarded this document to the property owner, for their use in preparing a binding covenant to run with the land. 1927 Post Alley Seattle, WA 98101 p 206-957-9800 f 206-682-3159 www,gracearchitect.5plic.com Thanks Ralph W. Allen Principal Att: IBC Table 704.8 IBC Sections 1014, 1007 and 1104 Revised plan A2.1 1927 Past Ailey .Seattle, WA 98101 p 206-957-9800 f 206-682-3159 www. gracearchitectspllc. cam FIRE -RESISTANCE -RATED CONSTRUCTION TA13LE 704.8 MAXIMUM AREA OF EXTERIOR WALL OPENINGSa For SI: I foot = 304.8 mm. a. Values given are percentage of the area of the exterior wall. b. Foroccupancies in Group R-3, as applicable in Section 101.2, the maximum percentage of unprotected and protected exterior wall openings shall be 25 percent. c. The area of openings in an open parking structure with a fire separation distance of greater than 10 feet shall not be limited - d. For occupancies in Group H-2 or H-3, unprotected openings shall not be permitted for openings with a fire separation distance of 15 feet or less. e. For requirements for fire walls for buildings with differing roof heights, see Section 705.6.l - f. The area of unprotected and protected openings is not limited for occupancies in Group R-3, as applicable in Section 101-2, with a fire separation distance greater than 5 feet. g. Buildings whose exterior bearing wall, exterior nonbearing wall and exterior structural frame are not required to be fire -resistance rated shall be permitted to have unlimited unprotected openings. b- Includes accessory buildings to Group R-3 as applicable in Section 101.2. 704.10 Vertical exposure. For buildings on the same lot, ap- proved protectives shall be provided in every opening that is less than 15 feet (4572 turn) vertically above the roof of an ad- joining building or adjacent structure that is within a horizontal fire separation distance of 15 feet (4572 mm) of the wall in which the opening is located. Exception: Opening protectives are not required where the roof construction has a fire -resistance rating of not less than I hour for a minimum distance of 10 feet (3048 mm) from the adjoining building and the entire length and span of the supporting elements for the fire -resistance -rated roof as- sembly has a fire -resistance rating of not less than 1 hour. 704.11 Parapets. Parapets shall be provided on exterior walls of buildings. Exceptions: A parapet need not be provided on an exterior wall where any of the following conditions exist: I. The wait is not required to be fire -resistance rated in accordance with Table 602 because of fire separation distance. 2. The building has an area of not more than 1,000 square feet (93 m2) on any floor. 3. Walls that terminate at roofs of not less than 2 -hour fire -resistance -rated construction or where the roof, including the deck and supporting construction, is constructed entirely of noncombustible materials. 4. One-hour fire -resistance -rated exterior walls that ter- minate at the underside of the roof sheathing, deck or slab, provided: 4.1. Where the roof/ceiling framing elements are parallel to the walls, such framing and ele- ments supporting such framing shall not be of less than 1 -hour fire -resistance -rated con- struction for a width of 4 feet (1220 mm) mea- sured from the interior side of the wall for Groups R and U and 10 feet (3048 mm) for other occupancies. 4.2. Where roof/ceiling framing elements are not parallel to the wall, the entire span of such framing and elements supporting such fram- ing shall not be of less than 1 -hour fire -resis- tance -rated construction. 4.3. Openings in the roof shall not be located within 5 feet (1524 mm) of the 1 -hour fire -re- sistance -rated exterior wall for Groups R and U and 10 feet (3048 mm) for other occupan- cies. 4.4. The entire building shall be provided with not less than a Class B roof covering - 5. In occupancies of Groups R-2 and R-3 as applicable in Section 101.2, both provided with a Class C roof covering, the exterior wall shall be permitted to termi- nate at the roof sheathing or deck in Type III, IV and V construction provided: 5.1. The roof sheathing or deck is constructed of approved noncombustible materials or of fire -retardant -treated wood, for a distance of 4 feet (1220 mm); or 5.2. The roof is protected with 0.625 -inch (15.88 mm) Type X gypsum board directly beneath the underside of the roof sheathing or deck, supported by a minimum of nominal 2 -inch (51 mm) ledgers attached to the sides of the roof framing members, for a minimum dis- tance of 4 feet (1220 mm). 6. Where the wall is permitted to have at least 25 percent of the exterior wall areas containing unprotected openings based on fire separation distance as deter- mined in accordance with Section 704.8. 704.11.1 Parapet construction. Parapets shall have the same fire -resistance rating as that required for the support- ing wall, and on any side adjacent to a roof surface, shall have noncombustible faces for the uppermost 18 inches (457 mm), including counterflashing and coping materials. 2003 INTERNATIONAL BUILDING CODE@ 89 FIRE SEPARATION DISTANCE (feet) CLASSIFICATION Greater Greater Greater Greater Greater Greater Greater OF OPENING 0 to 301 than 3 to 5° than 5 to'lOd•f than 10 to 15c•dj than 15 to 200 than 20 to 25w f than 25 to 30c, f than 30 Unprotected Not Not 10%9 15%9 25%9 45%9 70%a No Limit L'erttuttedg Pert g Protected Not 15% 25% 45% 75% No Limit No Limit No Limit permitted For SI: I foot = 304.8 mm. a. Values given are percentage of the area of the exterior wall. b. Foroccupancies in Group R-3, as applicable in Section 101.2, the maximum percentage of unprotected and protected exterior wall openings shall be 25 percent. c. The area of openings in an open parking structure with a fire separation distance of greater than 10 feet shall not be limited - d. For occupancies in Group H-2 or H-3, unprotected openings shall not be permitted for openings with a fire separation distance of 15 feet or less. e. For requirements for fire walls for buildings with differing roof heights, see Section 705.6.l - f. The area of unprotected and protected openings is not limited for occupancies in Group R-3, as applicable in Section 101-2, with a fire separation distance greater than 5 feet. g. Buildings whose exterior bearing wall, exterior nonbearing wall and exterior structural frame are not required to be fire -resistance rated shall be permitted to have unlimited unprotected openings. b- Includes accessory buildings to Group R-3 as applicable in Section 101.2. 704.10 Vertical exposure. For buildings on the same lot, ap- proved protectives shall be provided in every opening that is less than 15 feet (4572 turn) vertically above the roof of an ad- joining building or adjacent structure that is within a horizontal fire separation distance of 15 feet (4572 mm) of the wall in which the opening is located. Exception: Opening protectives are not required where the roof construction has a fire -resistance rating of not less than I hour for a minimum distance of 10 feet (3048 mm) from the adjoining building and the entire length and span of the supporting elements for the fire -resistance -rated roof as- sembly has a fire -resistance rating of not less than 1 hour. 704.11 Parapets. Parapets shall be provided on exterior walls of buildings. Exceptions: A parapet need not be provided on an exterior wall where any of the following conditions exist: I. The wait is not required to be fire -resistance rated in accordance with Table 602 because of fire separation distance. 2. The building has an area of not more than 1,000 square feet (93 m2) on any floor. 3. Walls that terminate at roofs of not less than 2 -hour fire -resistance -rated construction or where the roof, including the deck and supporting construction, is constructed entirely of noncombustible materials. 4. One-hour fire -resistance -rated exterior walls that ter- minate at the underside of the roof sheathing, deck or slab, provided: 4.1. Where the roof/ceiling framing elements are parallel to the walls, such framing and ele- ments supporting such framing shall not be of less than 1 -hour fire -resistance -rated con- struction for a width of 4 feet (1220 mm) mea- sured from the interior side of the wall for Groups R and U and 10 feet (3048 mm) for other occupancies. 4.2. Where roof/ceiling framing elements are not parallel to the wall, the entire span of such framing and elements supporting such fram- ing shall not be of less than 1 -hour fire -resis- tance -rated construction. 4.3. Openings in the roof shall not be located within 5 feet (1524 mm) of the 1 -hour fire -re- sistance -rated exterior wall for Groups R and U and 10 feet (3048 mm) for other occupan- cies. 4.4. The entire building shall be provided with not less than a Class B roof covering - 5. In occupancies of Groups R-2 and R-3 as applicable in Section 101.2, both provided with a Class C roof covering, the exterior wall shall be permitted to termi- nate at the roof sheathing or deck in Type III, IV and V construction provided: 5.1. The roof sheathing or deck is constructed of approved noncombustible materials or of fire -retardant -treated wood, for a distance of 4 feet (1220 mm); or 5.2. The roof is protected with 0.625 -inch (15.88 mm) Type X gypsum board directly beneath the underside of the roof sheathing or deck, supported by a minimum of nominal 2 -inch (51 mm) ledgers attached to the sides of the roof framing members, for a minimum dis- tance of 4 feet (1220 mm). 6. Where the wall is permitted to have at least 25 percent of the exterior wall areas containing unprotected openings based on fire separation distance as deter- mined in accordance with Section 704.8. 704.11.1 Parapet construction. Parapets shall have the same fire -resistance rating as that required for the support- ing wall, and on any side adjacent to a roof surface, shall have noncombustible faces for the uppermost 18 inches (457 mm), including counterflashing and coping materials. 2003 INTERNATIONAL BUILDING CODE@ 89 MEANS OF EGRESS 'Section 1024. Aisles serving reviewing stands, grandstands and bleachers shall also comply with Section 1024. The required width of aisles shall be unobstructed. Exception: Doors, when fully opened, and handrails shall not reduce the required width by more than 7 inches (178 mm). Doors in any position shall not reduce the required width by more than one-half. Other nonstructural projec- tions such as trim and similar decorative features are permit- ted to project into the required width 1.5 inches (38 mm) from each side. 1013.4.1 Groups B and M. In Group B and M occupancies, the minimum clear aisle width shall be determined by Sec- tion 1005-1 for the occupant load served, but shall not be less than 36 inches (914 mm). Exception: Nonpublic aisles serving less than 50 peo- ple, and not required to be accessible by Chapter 11 need not exceed 28 inches (711 mm) in width. 1013.4.2 Seating at tables. Where seating is located at a ta- ble or counter and is adjacent to an aisle or aisle accessway, the measurement of required clear width of the aisle or aisle accessway shall be made to a line 19 inches (483 mm) away from and parallel to the edge of the table or counter. The 19 -inch (483 mm) distance shall be measured perpendicular to the side of the table or counter. In the case of other side boundaries for aisle or aisle accessways, the clear width shall be measured to walls, edges of seating and tread edges, except that handrail projections are permitted. Exception: Where tables or counters are served by fixed seats, the width of the aisle accessway shall be measured from the back of the seat. 1013.4.2.1 Aisle accessway for tables and seating. Aisle accessways serving arrangements of seating at ta- bles or counters shall have sufficient clear width to con- form to the capacity requirements of Section 1005.1 but shall not have less than the appropriate minimum clear width specified in Section 1013.4.1. 1013.4.2.2 Table and seating accessway width. Aisle accessways shall provide a minimum of 12 inches (305 mm) of width plus 0.5 inch (12.7 mm) of width for each additional 1 foot (305 mm), or fraction thereof, beyond 12 feet (3658 mm) of aisle accessway length measured from the center of the seat farthest from an aisle. Exception: Portions of an aisle accessway having a length not exceeding 6 feet (1829 mm) and used by a total of not more than four persons. 1013.4.2.3 Table and seating aisle accessway length. The length of travel along the aisle accessway shall not exceed 30 feet (9144 mull) from any seat to the point where a person has a choice of two or more paths of egress travel to separate exits. 1013.5 Egress balconies. Balconies used for egress purposes shall conform to the same requirements as corridors for width, headroom, dead ends and projections. Exterior balconies shall be designed to minimize accumulation of snow or ice that im- pedes the means of egress. Exception: Exterior balconies and concourses in outdoor stadiums shall be exempt from the design requirement to protect against the accumulation of snow or ice. 1013.5.1 Wall separation. Exterior egress balconies shall be separated from the interior of the building by walls and opening protectives as required for corridors. Exception: Separation is not required where the exterior egress balcony is served by at least two stairs and a dead-end travel condition does not require travel past an unprotected opening to reach a stair. 1013.5.2 Openness. The long side of an egress balcony shall be at least 50 percent open, and the open area above the guards shall be so distributed as to minimize the accumula- tion of smoke or toxic gases. ? lee/70.­' IGY, iPr T ///0 IUDs $ SECTION 1014 CEXIT AND EXIT ACCESS DOORWAYS 1014.1 Exit or exit access doorways required. Two exits or exit access doorways from any space shall be provided where one of the following conditions exists: 1. The occupant load of the space exceeds the values in Ta- ble 1014.1. 2. The common path of egress travel exceeds the limitations of Section 1013.3. 3. Where required by Sections 10 143, 1014.4 and 1014.5. Exception: Group I-2 occupancies shall comply with Sec- tion 1013.2.2. TABLE 1014.1 SPACES WITH ONE MEANS OF EGRESS OCCUPANCY MAXIMUM OCCUPANT LOAD A, B, E, F,M,U 50 H- t, H-2, H-3 3 H-4, H-5,1-1,1-3,1-4, R to S 30 1014.1.1 Three or more exits. Access to three or more exits shall be .provided from a floor area where required by Sec- tion 1018.1. 1014.2 Exit or exit access doorway arrangement. Required exits shall be located in a manner that makes their availability obvious. Exits shall be unobstructed at all times. Exit and exit access doorways shall be arranged in accordance with Sections 1014.2.1 and 1014.2.2. 1014.2.1 Two exits or exit access doorways. Where two exits or exit access doorways are required from any portion of the exit access, the exit doors or exit access doorways shall be placed a distance apart equal to not less than one-half of the length of the maximum overall diagonal di- mension of the building or area to be served measured in a 210 2003 INTERNATIONAL BUILDING CODE@ SECTION 1006 MEANS OF EGRESS ILLUMINATION 1006.1 Illumination required. The means of egress, including the exit discharge, shall be illuminated at all times the building space served by the means of egress is occupied. Exceptions: 1. Occupancies in Group U. 2. Aisle accessways in Group A. 3. Dwelling units and sleeping units in Groups R-1, R-2 and R-3. 4. Sleeping units of Group I occupancies. 1006.2 Illumination level. The means of egress illumination level shall not be less than I foot-candle (I I lux) at the floor level. Exception: For auditoriums, theaters, concert or opera halls and similar assembly occupancies, the illumination at the floor level is permitted to be reduced during performances to not less than 0.2 foot-candle (2.15 lux) provided that the re- quired illumination is automatically restored upon activa- tion of a premise's fire alarm system where such system is provided. 1006.3 Illumination emergency power. The power supply for means of egress illumination shall normally be provided by the premise's electrical supply. In the event of power supply failure, an emergency electrical system shall automatically illuminate the following areas: 1. Exit access corridors, passageways and aisles in rooms and spaces which require two or more means of egress. 2. Exit access corridors and exit stairways located in build- ings required to have two or more exits. 3. Exterior egress components at other than the level of exit discharge until exit discharge is accomplished for build- ings required to have two or more exits. 4. Interior exit discharge elements, as permitted in Section 1023. 1, in buildings required to have two or more exits. 5. The portion of the exterior exit discharge immediately adjacent to exit discharge doorways in buildings required to have two or more exits. The emergency power system shall provide power for a du- ration of not less than 90 minutes and shall consist of storage batteries, unit equipment or an on-site generator. The installa- tion of the emergency power system shall be in accordance with Section 2702. 1006.4 Performance of system. Emergency lighting facilities shall be arranged to provide initial illumination that is at least an average of k foot-candle (11 lux) and a minimum at any point of 0.1 foot-candle (I lux) measured along the path of egress at floor level. Illumination levels shall be permitted to decline to 0.6 foot-candle (6 lux) average and a minimum at any point of 0.06 foot-candle (0.6 lux) at the end of the emergency lighting time duration. A maximum -to -minimum illumination uniformity ratio of 40 to I shall not be exceeded. MEANS OF EGRESS SECTION 1007 ACCESSIBLE MEANS OF EGRESS 1007.1 Accessible means of egress required. Accessible means of egress shall comply with this section. Accessible spaces shall be provided with not less than one accessible means of egress. Where more than one means of egress is re- quired by Section 1014.1 or 1018.1 from any accessible space, each accessible portion of the space shall be served by not less than two accessible means of egress. Exceptions: 1. Accessible means of egress are not required in alter- ations to existing buildings. 2. One accessible means of egress is required from an accessible mezzanine level in accordance with Sec- tion t007.3 or 1007.4. 3. In assembly spaces with sloped floors, one accessible means of egress is required from a space where the common path of travel of the accessible route for ac- cess to the wheelchair spaces meets the requirements in Section 1024.9. 1007.2 Continuity and. components. Each required accessi- ble means of egress shall be continuous to a public way and shall consist of one or more of the following components: 1. Accessible routes complying with Section 1104. 2. Stairways within exit enclosures complying with Sec- tions 1007.3 and 1019.1. 3. Elevators complying with Section 1007.4. 4. Platform lifts complying with Section 1007.5. 5. Horizontal exits. 6. Smoke barriers. Exceptions: 1. Where the exit discharge is not accessible, an exterior area for assisted rescue must be provided in accor- dance with Section 1007.8. 2. Where the exit stairway is open to the exterior, the ac- cessible means of egress shall include either an area of refuge in accordance with Section 1007.6 or an exte- rior area for assisted rescue in accordance with Sec- tion 1007.8. 1007.2.1 Buildings with four or more stories. In buildings where a required accessible floor is four or more stories above or below a level of exit discharge, at least one required accessible means of egress shall be an elevator complying with Section 1007.4. Exceptions: 1. In buildings equipped throughout with an auto- matic sprinkler system installed in accordance with Section 903.3.1.1 or 903.3.1.2, the elevator shall not be required on floors provided with a hor- izontal exit and located at or above the level of exit discharge. 2. In buildings equipped throughout with an auto- matic sprinkler system installed in accordance with Section 903.3.1.1 or 903.3.1.2, the elevator 2003 INTERNATIONAL BUILDING CODE@ 197 ACCESSIBILITY ties can approach, enter and exit the work area. Work areas, or portions of work areas, that are less than 150 square feet (14 m2) in area and elevated 7 inches (178 mm) or more above the ground or finish floor where the elevation is es- sential to the function of the space shall be exempt from all requirements. 1103.2.4 Detached dwellings. Detached one and two-fam- ily dwellings and accessory structures, and their associated sites and facilities as applicable in Section 101. 2, are not re- quired to be accessible. used only by inmates or detainees and security personnel, and that do not serve holding cells or housing cells required to be accessible, are not required to be accessible or to be served by an accessible route. 1103.2.14 Fuel -dispensing systems. The operable parts on fuel -,dispensing devices shall comply with ICC A117.1, Section 8.2.1 or 308.3.1. SECTION 1104 1103.2.5 Utility buildings. Occupancies in Group U are ex- ACCESSIBLE ROUTE empt from the requirements of this chapter other than the 1104.1 Site arrival points. Accessible routes within the site following: shall be provided from public transportation stops, accessible 1. In agricultural buildings, access is required to paved parking and accessible passenger loading zones and public work areas and areas open to the general public. streets or sidewalks to the accessible building entrance served. 2. Private garages or carports that contain required accessible parking. 1103.2.6 Construction sites. Structures, sites and equip- ment directly associated with the actual processes of con- struction including, but not limited to, scaffolding, bridging, materials hoists, materials storage or construction trailers are not required to be accessible. 1103.2.7 Raised areas. Raised areas used primarily for pur- poses of security, life safety or fire safety including, but not limited to, observation galleries, prison guard towers, fire towers or lifeguard stands are not required to be accessible or to be served by an accessible route. 1103.2.8 Limited access spaces. Nonoccupiable spaces ac- cessed only by Iadders, catwalks, crawl spaces, freight ele- vators or very narrow passageways are not required to be accessible. 1103.2.9 Equipment spaces. Spaces frequented only by personnel for maintenance, repair or monitoring of equip- ment are not required to be accessible, Such spaces include, but are not limited to, elevator pits, elevator penthouses, me- chanical, electrical or communications equipment rooms, piping or equipment catwalks, water or sewage treatment pump rooms and stations, electric substations and trans- former vaults, and highway and tunnel utility facilities. 1103.2.10 Single -occupant structures. Single -occupant structures accessed only by passageways below grade or el- evated above grade including, but not -limited to, toll booths that are accessed only by underground tunnels, are not re- quired to be accessible. 1103.2.11 Residential Group R-1. Buildings of Group R-1 containing not more than five sleeping units for rent or hire that are also occupied as the residence of the proprietor are not required to be accessible. 1103.2.12 Day care facilities. Where a day care facility (Groups A-3, E,1-4 and R-3) is part of a dwelling unit, only the portion of the structure utilized for the day care facility is required to be accessible. 1103.2.13 Detention and correctional facilities. In deten- tion and correctional facilities, common use areas that are Exception: An accessible route shall not be required be- tween site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing for pedestrian access. 1104.2 Within a site. At least one accessible route shall con- nect accessible buildings, accessible facilities, accessible ele- ments and accessible spaces that are on the same site. Exception: An accessible route is not required between ac- cessible buildings, accessible facilities, accessible elements' and accessible spaces that have, as the only means of access between them, a vehicular way not providing for pedestrian access. 1104.3 Connected spaces. When a building, or portion of a building, is required to be accessible, an accessible route shall be provided to each portion of the building, to accessible build- ing entrances connecting accessible pedestrian walkways and the public way. Where only one accessible route is provided, the accessible route shall not pass through kitchens, storage rooms, restrooms, closets or similar spaces. Exceptions: 1. In assembly areas with fixed seating required to be accessible, an accessible route shall not be required to serve fixed seating where wheelchair spaces or desig- nated aisle seats required to be on an accessible route are not provided. 2. Accessible routes shall not be required to mezzanines provided that the building or facility has no more than one story, or where multiple stories are not connected by an accessible route as permitted by Section 1104.4. 3. A single accessible route is permitted to pass through a kitchen or storage room in an accessible dwelling unit. 1104.3.1 Employee work areas. Common use circulation paths within employee work areas shall be accessible routes. Exceptions: 1. 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