Thursday, July 5, 2012

California State Disabled Access Code Regulations

BOMA San Francisco Members:

BOMA San Francisco Codes and Regulations Committee members - Gordon L'Estrange, Senior Associate at Lionakis and staff from the San Francisco Department of Building Inspection -  have identified and summarized the following issue for your consideration.  

In California, we are regulated by two 'codes' that identify the minimum technical construction guidelines required to ensure commercial buildings are accessible to those with disabilities: the 2010 California Building Code Chapter 11B, and the Federal 2010 ADA Standards for Accessible Design (which is a part of the overall Americans with Disabilities Act of 1990 [ADA]).

The next code adoption cycle for the California Building Code (CBC) is mid-year 2013, going into formal effect January 2014. The Division of the State Architect is currently working on revisions to the CBC in anticipation of this new adoption cycle but there are some interesting timing issues with this process that will potentially cause interpretation issues and confusion for BOMA members.

The CBC requirements are generally aligned with the Federal ADA Standards but there are some examples where one or the other code is more stringent. Typically, the approach has been to apply the stricter of the two and, thus, both codes are satisfied. However, with the adoption of the new Federal 2010 Standards, there are a limited number of cases where compliance with one will be a violation with the other. The Division of the state Architect recently attempted to pass emergency legislation that would amend the 2010 California Building Code to bring it into line with the Federal ADA Standards and remove this potential ambiguity but, the legislation failed at the California Building Standards Commission.

Most of these items can be addressed with careful design during renovations. The items in conflict that could potentially affect BOMA members include:
  • Tactile signage mounting height and character requirements;
  • Baby changing tables in restrooms;
  • Toilet paper dispensers within accessible stalls in restrooms; 
  • Drinking fountain spout location and water flow requirements;
  • Door hardware mounting height.
The findings of the emergency legislation can be reviewed by clicking here and here.

The Division of the State Architect is attempting to revise the entire California Building Code Chapter 11B regulations for accessible design so that they reconcile with the 2010 Federal ADA Standards and the existing California-specific Standards. They are currently holding a series of day-long access code forums around the State, between now and the end of July, to gather stakeholders’ input in the formatting of the revised code.  Participation is available to everyone and agendas and the draft proposed language of the revised code is available here.

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