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 inches AFF. 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.

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. 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. It is an interior path of travel.