Staff Analysis for
Declaratory Statement Request DS-2014-129
10/15/14
Issue: DS-2014-129. The Petitioner, David Kramer, seeks a Declaratory Statement on Chapter 3, Section 307, Protruding Objects, Section 307.2, Protrusion Limits, Section 307.4, Vertical Clearance and Chapter 1, Definitions – Circulation Path of the 2010 Florida Building Code, Accessibility
Petitioner in DS-2014-129 seeks clarification
of the following questions:
Question 1: Would a shower curtain rod with the height of 74inches (AFF) be
considered a head obstruction under the 80 inch vertical clearance
specification in Section 307.4 of the 2010 Florida Building Code,
Accessibility for a person who is visually impaired?
Question 2: Would a toilet room, restroom be
considered within the definition of Circulation Path under the “not limited” to
part of the definition?
Situation:
David Kramer, Building code Administrator for the University of Florida,
seeks clarification of code requirements regarding Accessibility requirements
for the Circulation Path in a toilet room or restroom.
Applicable Codes:
Florida
Building Code, Accessibility Chapter 1,
Definitions – Circulation Path, and Chapter 3 Section 307, Protruding Objects,
Section 307.2, Protrusion Limits, Section 307.4, Vertical Clearance.
Background:
Mr. Kramer has four projects at the University of Florida that are in
design phase, all of which will have showers and wants to make sure they are
providing the best information possible to the design and construction team. A
manufacturer of pre-fabricated showers is contending that their unit is
compliant even though the curtain rod is at 74 3/4 inches AFF and a ¾”
threshold. Mr. Kramer does not want to
require architects and their contractor to adhere to the 80 inch vertical
clearance requirement if his interpretation of the code is incorrect.
MEETING Minutes— Tuesday
December 2, 2014
Considered and
discussed the following Declaratory Statement: DS 2014-129 by David Kramer,
Building Code Administrator, of University of Florida. Larry Schneider
commented that with a ½” curb or no greater it would not be an obstruction but
if it were a roll in shower, it would be an obstruction. Bemmie Eustace commented
that she has talked to DOJ and the Access Board and was told that hotel and
motel shower guest rooms do not have criteria for visually impaired. Brad
Schiffer commented that the cut sheets are needed to determine
what the curb heights are. Brad Schiffer made a motion to differ DS 2014-129 till
cut sheets can be received from the applicant and reviewed by the TAC at the
next meeting. Larry Schneider made a second with unanimous
approval by the TAC.
Relevant Code Sections
Florida Building Code, Accessibility, Chapter 1
106 DEFINITIONS
106.5 Defined Terms.
Circulation Path. An exterior or interior way of
passage provided for pedestrian travel, including but not limited to, walks,
hallways, courtyards, elevators, platform lifts, ramps, stairways, and
landings.
Florida Building Code, Accessibility, Chapter 3
307 PROTRUDING OBJECTS
307.1 General.
Protruding objects shall comply with 307.
307.2 Protrusion Limits.
Objects with leading edges more than 27 inches (685
mm) and not more than 80 inches (2030 mm) above the finish floor or ground
shall protrude 4 inches (100 mm) maximum horizontally into the circulation
path.
EXCEPTION: Handrails shall be permitted to protrude
41/2 inches (115 mm) maximum.
Advisory 307.2 Protrusion Limits.
When a cane is used and the element is in the
detectable range, it gives a person sufficient time to detect the element with
the cane before there is body contact. Elements located on circulation paths,
including operable elements, must comply with requirements for protruding
objects. For example, awnings and their supporting structures cannot reduce the
minimum required vertical clearance. Similarly, casement windows, when open,
cannot encroach more than 4 inches (100 mm) into circulation paths above 27
inches (685 mm).
307.4 Vertical Clearance.
Vertical clearance shall be 80 inches (2030 mm)
high minimum. Guardrails or other barriers shall be provided where the vertical
clearance is less than 80 inches (2030 mm) high. The leading edge of such
guardrail or barrier shall be located 27 inches (685 mm) maximum above the
finish floor or ground.
EXCEPTION: Door closers and door stops shall be
permitted to be 78 inches (1980 mm) minimum above the finish floor or ground.
Staff analysis:
Question 1:
Would a shower curtain
rod with the height of 74inches (AFF) be considered a head obstruction under
the 80 inch vertical clearance specification in Section 307.4 of the 2010 Florida Building Code, Accessibility for a person who is
visually impaired?
Answer: Yes. As per section 307.2 of the 2010 FBC,
Accessibility, the minimum clearance is 80 inches.
Question 2: Would a toilet room, restroom be considered within
the definition of Circulation Path under the “not limited” to part of the
definition?
Answer: Yes As per the definition of the term “Circulation
Path” (See 106.5 Definition) the toilet room in question is part of the
interior path of travel.