Title III Technical Assistance Manual (with 1994 supplement)

III−7.3130 General exceptions (ADAAG §4.1.1(5)). Accessibility is not required to --

1) Observation galleries used primarily for security purposes; or

2) Nonoccupiable spaces accessed only by ladders, crawl spaces, very narrow passageways, or freight (nonpassenger) elevators, and frequented only by service personnel for repair purposes. This includes elevator pits, elevator penthouses, piping or equipment catwalks, cooling towers, and utility tunnels.

What about mechanical rooms or closets not accessed by ladders or narrow passageways? They are not exempt. However, they are work areas subject to the limited exemption discussed above. In addition, mechanical rooms are exempt from the elevator requirement (§4.1.3(5), Exception 2).