Mezzanine and Egress - Code Questions

In a series of discussions on the building code, I'd like to start today with some thoughts on the building code in general and also about accessibility... specifically for Mezzanines and for accessible egress.

It is always interesting when one of my clients calls out of the blue with a question for me. I never know where the discussion will lead. Helping find the answers to these questions is one of my favorite parts of this job. It can be overwhelming at times, but I am thankful that I can help in this area, so please keep them coming and I'll keep on learning right along with you. I believe we need to keep learning every day and take an interest in the well-being of others. Your questions give me the opportunity to do both!

Thoughts on the Building Code
The building code identifies minimum requirements and we're always free to exceed these requirements in terms of safety, accessibility, and Structural Integrity. We often want to know what the Minimum Requirements are since, except for lottery winners, the project owners typically have limited resources at their disposal.

The building code dictates what we must do in certain areas of our construction projects, and we offset these requirements by building smaller or spending more to provide the dictated features, such as firewalls, sprinklers, and accessibility. In certain situations where expectations of the building code requirements are not clear up front, the code requirements may halt the project as financially infeasible.

Despite the "Thou shalt..." tone, the building code does have a benefit for the safety of the public in mind. We actually heard of commercial roof collapses during the recent snow falls in the Wisconsin... mostly flat roofs as far as I've heard (none of your projects, I'm sure). But in 2006 we saw the collapse of an ice arena in Germany claim 11 lives and 67 lives were lost in the collapse of a Polish trade hall, so we do have cause to say that some measure of rational design is required to insure the safety of the public.

Accessible Mezzanines
Are mezzanines required to be accessible to the wheelchair bound? I sure didn't think so earlier today. Small mezzanines have certainly been approved without an elevator or accessible ramps, but the Wisconsin Commercial Building Code requires all elements of a our commercial buildings to be accessible, with some exceptions.

The exception for non-accessible mezzanines is in Comm 62.1104(4)(b), and states that floors above and below accessible levels with an aggregate area of not more than 3,000 sq. ft. do not require an accessible route to them. In other words, if your mezzanine will be over 3,000 sq. ft., reason for concern, but the cause may not be lost.

Since code questions are typically more simple than the answers: There are some provisions in Comm 62.1003(2)(h) and (i) which identify some general exceptions to accessibility requirements which allow Limited access spaces (h) and Equipment Maintenance and Repair areas (i) not to be accessible. These areas are viewed by the code as areas where work could not reasonably be performed by a person in a wheelchair and so it negates the requirement for an accessible route to them.

Accessible Means of Egress
The building code requires at least one accessible entrance to commercial buildings, but two accessible egresses. It means we may have a door from a building that could be used during emergency as an accessible egress (when the building's on fire) with the assistance of others which would not be an accessible entrance during normal operation of the building.

The accessible entrance is viewed as an equal access provision to provide equal access opportunity in public buildings. The accessible egress is a life safety issue that allows for the fact that during an emergency (fire, for example), the entrance used to gain access to the building may be blocked by the situation causing the emergency. It is assumed that egress may be accomplished by people working together in the event of getting a wheelchair down a flight of steps during an emergency as long as provisions are made for the person in a wheelchair to have access to communication for assistance from a relatively safe and secure location.

These concepts are covered in the code by the terms "Areas of Refuge" (IBC 1003.2.13.5) and "Exterior Areas for Assisted Rescue" (IBC 1003.2.13.7). In building projects without complete accessibility going into and out of the building, remember to consider the egress requirements during emergency situations. It is not enough to say that "nobody in a wheelchair works here and wouldn't have a reason to come here". Public buildings must not be designed with an inherently dangerous situation based on the assumptions of what level of physical ability people must possess before they use that building. That is a type of discrimination we cannot tolerate.