Code Application Notice (CAN) 2-11B, 09-09-2014

 INTERPRETATION

For the purposes of this CAN, the specific area of alteration is equivalent to the altered element or space described in Section 11B-202.3 in this CAN.

The language "primary accessible path of travel shall include" indicates that, in most projects, accessibility must be demonstrated and/or provided outside of the specific area of alteration as required by Section 11B-202.4. Every project subject to the requirements of Section 11B-202.4 shall demonstrate compliance for a primary entrance; primary path of travel to the specific area; and toilet and/or bathing facilities, drinking fountains, signs, and public telephones serving the area. These elements are required pursuant to Section 11B-202 and yet they may be located outside of the specific area of alteration.

Path of travel as defined in CBC Section 202: "An identifiable accessible route within an existing site, building or facility by means of which a particular area may be approached, entered and exited, and which connects a particular area with an exterior approach (including sidewalks, streets and parking areas), an entrance to the facility, and other parts of the facility. When alterations, structural repairs or additions are made to existing buildings or facilities, the term "path of travel" also includes the toilet and bathing facilities, telephones, drinking fountains, and signs serving the area of work."

Primary entrance is the "primary entry" defined in Section 202, which states: "Primary Entry. The principal entrance through which most people enter the building, as designated by the building official."

For the purposes of this CAN, the primary entrance is equivalent to the "primary entry."

Toilet and bathing facilities serving the area must meet the requirements of Section 11B-213 and include those required for each user group as stipulated in Section 11B-213.1.1 which states: "Where separate toilet facilities are provided for the exclusive use of separate user groups, the toilet facilities serving each user group shall comply with Section 11B-213."

The California Plumbing Code (CPC) Section 422.2.1 [OSHPD 1, 2, 3 & 4] requires: "Separate toilet facilities shall be provided for the use of patients, staff personnel and visitors." Consequently, if the area of work serves more than one of these user groups, each user group served must have accessible toilets as a part of the path of travel requirements.

Example: An alteration of an Imaging Department, including outpatient services, will require an accessible patient toilet serving the specific altered space, men’s and women’s staff toilets serving the department, and men’s and women’s public/visitor toilets serving the waiting area.

Example: An alteration of a "non-accessible" patient room within a nursing unit will require accessible men’s and women’s staff toilets serving the nursing unit, and men’s and women’s public/visitor toilets on the path of travel from the main entrance. Note that in nursing units, patient rooms are already segregated into those requiring accessible patient facilities and those that are not required to have accessible facilities. Consequently, the patient toilet serving the non-accessible patient room may not need to be made accessible. In all other service areas, patient toilets are common use facilities for all patients and thus are required to be accessible. Note that this code application is not intended to countermand the requirements of Section 11B-223.2.1 for the minimum number of accessible patient rooms. Refer to the application under Section 11B-223.1.1 for facilities that do not currently comply with Section 11B-223.2.1.

Example: An alteration of an area limited to staff personnel only, such as Central Sterile Supply, will only have one user group. Thus only the men’s and women’s staff toilets serving the area are required to be accessible.

Toilet and bathing facilities are regulated in Section 11B-213 and include toilet rooms and bathing rooms. "Toilet room" is defined in CPC Section 222.0 as: "A room within or on the premises containing water closets, urinals, and other required facilities."

Serving the area is specific to those toilet and bathing facilities that are most directly related to the area of alteration. Toilet and bathing facilities are not required to be on the immediate path of travel to the area to be considered as serving the area, but they must be within a reasonable distance of the area. In no case shall the distance exceed 200 feet of travel or more than one floor above or below the area for access to staff toilets. Note that some departments such as Surgery and Dietary require dedicated staff toilets that may not be shared with other departments and therefore the 200 feet rule does not apply.

Example: A nurse’s station is remodeled on the first floor of a hospital, but the toilet rooms for those nurses are not accessible and are located on the second floor. As a result of this remodel project, the inaccessible toilet rooms must be made accessible, because they are the only staff toilet facilities within a reasonable distance that serve the area.

Example: Alternately, given the same situation as in the example above, the facility could choose to provide new accessible toilet rooms to serve that specific nurses’ station on the same floor and in close proximity to the remodeled nurses’ station. In this case, they would not be required to upgrade the toilet rooms on the second floor, because they would be providing new toilet rooms to serve the area on the first floor.

When there is more than one toilet facility that is within a reasonable distance from the specific area of alteration and each can be considered as serving the area, only one of each required toilet facility must be made accessible. The facility may designate the toilet facilities that will be considered as serving the area as long as they are within a reasonable distance, even if they are located further from the specific area of alteration than other sanitary facilities.

Example: A pharmacy remodel project on the second floor of a hospital requires that accessible toilet rooms be provided (both male and female) for the public, as well as separate accessible toilet rooms for staff. Accessible public toilet rooms (both male and female) are already available approximately 80 feet away, which satisfies Section 11B-202.4.2 for public use. The existing staff toilet rooms within the pharmacy are not accessible, but there are also accessible separate male and female staff toilet rooms on the first floor, with a total distance to the specific area of alteration of 120 feet (including elevator travel). However, in this case the facility may not designate the first floor staff toilet rooms as "serving the specific area of alteration" for the purpose of this remodel project as this is not "convenient access" from the pharmacy as required by CBC Section 1224.19.1.2 and thus additional construction work to provide accessible staff toilets will be required.