Oregon Building Code Updates
October 2011
Having come into the Code business from an architectural design & construction business, I’ve always believed that the Building Code was intended to tell one what they can build, rather than what they can’t build. In my moments of reflection, which are far too many at present, I realize that the reason I’m no longer in the government side of the Code business is that I wasn’t able to conform to a can’t/won’t perspective. I really dislike rules that have no productive purpose. However, it could be worse—from the San Diego Zoning Code:|
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http://www.ada.gov/2010ADAstandards_index.htm
“...Oregon Building Codes Division (BCD) is working closely with stakeholders in the preparation of an amended version of the 2009 IBC Chapter 11. Oregon amendments are necessary in keeping with statutorily driven accessibility requirements which provide for greater accessibility than the Federal standards. Consistent with the U.S. Attorney General’s implementation timelines noted above, BCD anticipates adoption of the amended IBC Chapter 11 with an effective date of January 1, 2012.”
The Guidance document, to some extent, appears to have been written for me; there are all sorts of explanations as to why portions of the Code were written, and in many cases, there are explanations as to where Building Officials have the wrong understanding of the ADA provisions:Commenters stated that the requirements set out in the 2010 Standards for accessible common use circulation paths in employee work areas are inappropriate, particularly in commercial kitchens, storerooms, and behind cocktail bars where wheelchairs would not be easily accommodated...
These commenters misunderstand the scope of the provision. Nothing in the 2010 Standards requires all circulation paths in non-exempt areas to be accessible. The Department recognizes that building codes and fire and life safety codes, which are adopted by all of the states, require primary circulation paths in facilities, including employee work areas, to be at least 36 inches wide for purposes of emergency egress. Accessible routes also are at least 36 inches wide. Therefore, the Department anticipates that covered entities will be able to satisfy the requirement to provide accessible circulation paths by ensuring that their required primary circulation paths are accessible.
...In addition, the 2010 Standards include exceptions for common use circulation paths in employee work areas where it may be difficult to comply with the technical requirements for accessible routes due to the size or function of the areas. The Department believes that these exceptions will provide the flexibility necessary to ensure that this requirement does not interfere with legitimate business operations. [emphasis added]
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at long last, some flexibility in toilet room design. However, the flexibility
is really only found in the Guidance document. The rest of the Guidelines
read like Code...
The Department recognizes that there are many design choices that can affect the size of a room or space. Choices to install additional features may result in more space being needed to provide sufficient clear floor space for that additional feature to comply. However, many facilities that have these extra features also tend to have ample space to meet accessibility requirements. ...Additional floor plans of single-user toilet rooms are now included in further response to the commentary received. So,
if one looks in the Guidance document, one finds this interesting arrangement
[yes, including the in-swinging door clearance]: Some
of the new arrangements actually add a couple of square feet to the area;
but provide far more flexibility.
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More on this stuff next time.
marty@mjarts.com
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