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Learning from Accessible Play Areas: Codes

By Kerwin Lee, AIA

Very few architects and designers get into designing play grounds. This is not a project scope that is presented to us often, unless it is part of a school or park. Even then, there is a learning curve on what it is all about.  There were no design criteria for play areas, much less for the disabled, other than some OSHA (safety) standards. When the American with Disabilities Act (ADA) was enacted back in 1991, there was a small section that spoke to having accessibility to recreational areas, which included play areas, but no real rules or criteria. “The Guidelines for Accessible Play Areas” were issued in 2005.

When I was growing up, playgrounds were fairly simple with swings and a climbing structure of some sort. The surface material was sometimes asphalt or just dirt. I feel lucky that I was never seriously injured on these. Play areas are pretty much the same in concept today. Sure the structures or components are more sophisticated using today’s technology, but the approach is still the same. The intent of the regulations is not focused on safety, but equality of access for a child with disabilities. Playing needs to have some levels of risk involved. This is part of the play “experience.” This adds to the excitement/challenge and aids in learning one’s limits.

One of the key parts for people with disabilities is the “play experience.” Opportunity should be available for not only play, but for socialization and learning. A child with a disability will not be able to do everything an able-bodied child can do, but should be able to experience the joy, laughter and feelings other kids have.  Being included and not excluded is the key concept.

The guidelines are available on this website.

The guidelines address the following:
Accessible routes
Ground level/surface – Maneuvering space
Entry Points – Transfer systems
Connected Elevated Components
Play tables
Soft contained play structures – play structures within a building

The guidelines do not specify what types of components are required, but play components, such as swings, slides and climbers, are required to make at least one component accessible. This would include things like transfer points from a wheelchair to a climbing structure or slide. If a sand or water play area is provided, an equal play area for a child in a wheelchair needs to be included.

Equal Facilitation is the concept of using innovative solutions and new technology to being accessible. Alternative designs and materials can be used in order to satisfy the intent of the component and comply with the guidelines. This is more so in the approach for an accessible play area.

One of the hardest things to decide on in a design for a play area is the ground surface. There are a lot of so called “accessible surface” (stable and firm) providing the ability for mobility devices (wheelchair) to gain access. Some types of loose materials (wood fiber and rubber materials) meet the ASTM Standards and may be safer than a harder surface against fall. Loose materials area is a maintenance problem and requires a lot of maintenance to keep it in compliance. Most designers or jurisdictions will opt for a harder surface with less maintenance.

Recently opened is the Lamorinda “all-access” playground at the Moraga Commons Park in Moraga. It was a community effort to bring this together and one of the best examples of a high-level accessible play area. The area contains a variety of components addressing different types of disability and provides a high-level of play experience, socialization and learning for all. The approach for all accessible play areas should be applied to all accessible buildings. What experience does your building provide for its occupants and users, including ones with disabilities?

Comments from Erick Mikiten, AIA:


Growing up as a wheelchair rider, most play areas I encountered were sandy, and the only way I could get access was if my parents painstakingly dragged my wheelchair through the send, over to the equipment. But even then, the equipment was mostly unusable for someone at a seated level. And as my friends ran around the playground, I could not follow them.

Fast forward 38 years when I had a son of my own, with my same weak bone condition, although he doesn’t need a wheelchair. There were many things that he wouldn’t ever be able to do, but the change in playground design, and the requirements of the ADA gave him more options than I had.

But still, many playgrounds, even if they had equipment from more “enlightened” manufacturers, still didn’t have surfaces that I could wheel over to stay close and help him. And even if I could reach a climbing structure, I probably couldn’t get my wheelchair to all sides of it to spot him as he played.

So if you do get a chance to design a playground (I’ve done a few and they’re great fun to design), think not only about the kids playing, and the surfaces, but think about how parents might interact with kids. Provide access for wheelchairs everywhere (including two or three kids in wheelchairs coming to play together), provide seats for older grandparents to sit and monitor kids, etc. I find that the more creatively we think about our audience and the different things they’ll want to do in playgrounds, the more exciting and creative the playgrounds become for everyone.

Next Time You Design A House: Codes

Erick Mikiten, AIA, LEED-AP

This month we’re going to consider accessibility in housing. The ADA and CBC don’t directly apply to single-family homes, but you could easily argue that this locus of family and life needs more attention. After all, one of an architect’s jobs is to help clients anticipate their needs. Recent research has begun to illustrate the intersection between disabilities and aging, which has significant implications on residential design goals.

It’s easy to assume that people with disabilities are in a separate group, but the fact is that most of us will move into that group during some part of our lives, some temporarily and others permanently. Aging shows us, in incremental degrees, where our homes fail us. Even for a young person, a fall or an accident can reveal the many barriers that exist in our homes to performing simple everyday tasks.

Consider this: 17 percent of women aged 16 to 64 have one or more disabilities. For the 65 and over group, it’s 43 percent. And of course that increases over time.

It’s not just the percentage of people who experience periods of disability. It’s also important for an architect to at least understand common disabilities and design with some sensitivity. For example, 27 percent of people over 65 report having a lot of trouble hearing. What does this have to do with design? Blaring televisions are a common complaint between residents of a household, so an architect could consider sound attenuation strategies in the rooms most likely to contain a television. Resilient channels between the wall board and the studs can make a difference. So can insulation in the interior wall cavities. There are STC (Sound Transmission Coefficient) requirements for walls and floor/ceiling assemblies that are required by the CBC between dwelling units, but why not apply some of those to single-family homes as well?

Mobility challenges can easily arise, so why not put blocking in the bathroom walls so that installation of grab bars can be done in an hour if needed. Blocking should surround the toilet area, bath tub, shower walls, and any long stretch of wall where you could imagine a handrail (or a towel bar, for that matter, which is often used as a grab bar whether you intend it to be or not). My standard approach for showers is to install 1/2” plywood everywhere, behind the tile backer board. That way, nobody has to remember where the 2x blocking is within the wall for a grab bar, to allow attachment at any angle or location, they will have a solid attachment.

Don’t forget doorways. Simply incorporating 36 inch doors can allow someone to remain in his house, even if a walker or wheelchair is needed, short or long term. If that feels too wide for a remodel project where you’d like to match existing doors, specify at least 32 inch doors with swing-clear hinges. Also called offset hinges, these move the door outside the doorway opening, so that the door thickness isn’t in the way.

If you can, include a stair-free entry into the house, or at least consider where a ramp could be added if needed later. Recognize that the entrance will make it possible for guests and aging parents to at least visit. If you have a project with one step, I can pretty much guarantee that you can have a zero-step threshold. Providing cover above for rain can help make this more realistic. And GreenPoints requires entrance rain protection anyway, so you’re “covered” here in two ways.

Don’t forget vision. More than two-thirds of adults over 65 have vision impairments. The causes include cataracts, macular degeneration, glaucoma, and diabetic retinopathy. Architects should anticipate that the need for good lighting will go up as we age, and build in some excess capacity. A great lighting designer friend says “always over-light and dim down.” With LED fixtures this is easy to do and still meet Title 24.

A little advanced planning, thoughtful and totally inconspicuous, can make the difference  between living at home and the incredible upheaval of needing to move (especially if you’re in the midst of dealing with a new disability). Think about your own grand parents – if they are still at home, think about the upheaval for them to have to relocate just because their beloved home doesn’t work for them anymore.

A home that accommodates its owner can also make the difference between being able to care for oneself and needing help from other family members. Having a sense of self-control and independence is a powerful feeling, and can lead to a more positive attitude and better physical health.

And finally, with the huge increase in ADU (Accessory Dwelling Unit) projects in California and the changes in State ADU Law, there are more people pursuing ADUs with the idea of retiring there or bringing their aging parents in to live there. So it’s all the more important that we as architects ensure that these and other residential projects are designed to be what I call future-proof. So go forth and accessify.

Kerwin Lee, AIA, CASp

Kerwin’s Comments

The concept of aging in place is not a new concept. Many senior living facilities have multiple levels of accommodation from independent care, assisted care and beyond. This is just good business practice.

Although the American with Disabilities Act (ADA) and California Building codes do not directly apply to single family dwellings, they do if you have a public accommodation within the dwelling. If you have a home business and have clients come to you, you are a public accommodation and all the rules for disabled access apply, from parking, to path of travel to even toilets rooms.

Code Changes through Legislation: Codes

Kerwin Lee, AIA, CASp

Changes to the Code come through many channels. We have our national code development process through the International Code Conference (ICC). Legislation created the Americans with Disabilities Act (ADA), which is a Civil Rights Law. From the ADA, the basic original guidelines were written into the Act as Appendix 28, CFR Part 36.  A lot of the details/interpretations were created by the Access Board for compliance with the ADA. The latest set of standards (2010) were created by the Access Board. The problem with code language being written into law is that it’s there forever unless the law is changed through legislation. It took 20 years for the original ADA guidelines to be changed.

In our great state of California, our legislation loves to write laws because many of the laws are driven by special interest. There are currently over 4,500 bills being introduced in the state this coming year. Some could have an effect on construction of our built environment. Again, many of the proposed bills stem from current events or a reaction to a disaster.

Here are some of the proposed bills that could affect our work:

AB565 – The bill authorizes city or county alternative building regulations for the conversion of commercial/industrial buildings to joint living/work quarters and includes provisions for housing artists, artisans and other similarly situated individuals.  It is unclear what the real intent of this bill is other than to perhaps encourage live/work occupancies, which the code already addresses. It appears to be more of an attempt to change zoning regulations to allow more live/work occupancies in industrial areas.

AB1857 – This bill would require the commission to adopt earthquake standards for engineered buildings meeting “immediate occupancy” standards, as defined, to be included in the next triennial edition of the California Building Code, as specified. Until the immediate occupancy standard is adopted, the bill would require the commission to adopt strength and stiffness standards, as defined, for engineered buildings that is 1.5 times the level of the current standard. Here is a case where the legislation includes a design value with little or no engineering basis – why 1.5 times the current standards? The basic intent is to strengthen buildings to withstand an earthquake. Since every value in the code is arbitrary to start with, justification of any number is needed. This proposed bill missed the deadline for the current code cycle and will have to wait until the next cycle to be included, if passed.

AB2911 – This bill would require the State Fire Marshal, by no later than January 31, 2019, in consultation with the Director of Forestry and Fire Protection and the Director of Housing and Community Development, to recommend updated building standards that provide comprehensive site and structure fire risk reduction. This protects structures from fires spreading, as specified, based on lessons learned from the wildfires of 2017 and develops a list of low-cost retrofits that provide comprehensive site and structure fire risk reduction, as provided. This is another knee jerk reaction to a recent event. This bill should look at what more the code can address that is not already in Chapter 7A – Urban/Wildand interface.

There are a number of proposed bills that aim to increase dwellings and allow for more Accessories Dwelling Units (ADUs). AB2939 addresses unlimited ADUs in multi-dwelling zones, so an additional dwelling could be added almost anywhere. SB827 addresses transit-rich housing development exempt density, FAR, parking and height limitations, allowing an automatic 55 to 85 foot height limit. Other proposed bills address housing concerns near colleges and universities. All of these bills will impact local zoning and building authorities. The basic intent is to provide more housing near transit centers, but is a blanket statewide bill needed? Does a small town like Orinda want denser housing in and around their BART Station?

Perhaps bills are a way of getting things done. Some of the proposed bills don’t make much sense and begs the question why do we need this? AB2929 says it will require grab bars in public restroom. Don’t we already have code requirements for this? Other proposed bills reduce permitting fees for all types of construction, not sure if this will spur construction in the state.

AIACC’s Government Regulations program represents the AIA before the State Legislature, regulatory agencies, boards and commissions. Go to their website for more information on proposed and current legislative actions:

ANSI A117 – Everything Old is New Again: Codes

Erick Mikiten, AIA, LEED-AP

Change is on the horizon for accessibility requirements.

The ADA and the CBC (California Building Code) are both based on 1970’s studies that determined things like turning radius, clear space, and reach. It was good work, but the sample sizes were small, and some mobility devices—like scooters—didn’t exist.

This column previously explored the history of the1959 standard “ICC/ANSI A117.1 Accessible and Usable Buildings and Facilities.” The authors of that first version of A117 had impressive foresight in thinking about what people with disabilities needed to navigate the built environment.

A few years ago the US Access Board (the federal agency that issues the ADA) sponsored a new research project to collect data on 500 people with disabilities, mainly focusing on wheeled mobility devices. It was done by the IDeA Center (Center for Inclusive Design and Environmental Access) at the University of Buffalo. For this article, I contacted the center’s director, Edward Steinfeld, AIA, Arch.D and Jonathan White, who worked on the new study. That study informed the new 2017 version of ANSI A117, which – over time – will precipitate changes to the ADA guidelines and the CBC.

The new standards make many adjustments to maneuvering spaces, reach ranges, and other clearances that are more realistic today. Some seem broad and others dramatic, but it’s notable that in many areas, Australian and UK code have space requirements that are larger than in the new A117.

The Changes

A117 updated and added interesting technical requirements such as classroom acoustics, sign language interpreter stations and video relay service booths. But I’ll focus here on a few spatial changes.

Clear Space

A117 makes a fundamental change to the length of a wheelchair clear space. This grew from 48 inches to 52 inches. Those four inches don’t sound like much, but the effect ripples through other requirements, such as restroom stalls, auditorium seating, platform lifts, etc.

The larger clear space increases the required turning space from 60 to 67 inches. This odd number is a little awkward to work with, but is an example of the push and pull that happens in the public negotiation process.

We have a lot of existing buildings that don’t meet this and many  of the other new standards, so A117 splits many requirements into two categories: New Buildings and Existing Buildings.

In the example of turning space, a wheelchair was previously allowed to turn underneath a countertop, sink, or other obstruction that provided knee and toe clearance. That overlap was limited to the 25 inches of toe clearance defined elsewhere.

Now A117 has two standards: for existing buildings we retain the 60-inch circle and 25-inch maximum overlap with knee and toe space. But new buildings have the 67-inch circle with a maximum overlap of ten inches. This is an improvement for access. Even with a compact manual wheelchair, I’ve encountered many restrooms where I’m barely threading myself through these overlapping clearances that would be impossible with an electric chair or a scooter. This change will enlarge restrooms, changing rooms, and many other spaces, giving people with larger devices a chance for equal use.These are just a few examples of the many changes in A117. Other big ones are 90-degree and 180-degree turns in accessible routes, changes to the T-shaped turning space and new clear space requirements for front-approach doors.


Here’s an interesting diagram from the IDeA Center’s anthropometric study. It shows reach ranges for people in manual wheelchairs, with numbers on a grid indicating the percentage of people able to reach certain distances. Similar analyses were done for people in electric wheelchairs and people using scooters.

This graphic shows that for the standard 48-inch-high element, 99 percent of people can reach it if it’s close to their torso, but that percentages drops quickly down to 69 percent if it’s at the same height above their toes. For scooter users, it’s only 46 percent.

Even with this new data, the committee did not make any changes to reach standards in the new A117, but you can use the information to inform your own work and we should all expect changes in the next update.

The Future

Changes to the ADA are slow, and with Washington in a quagmire, don’t expect any of the A117 requirements to show up in the ADA soon.

Changes to the CBC are also slow. But since it’s based on the IBC, and the IBC creators (ICC – the International Code Council) may incorporate the new A117 sooner, my guess is that it will trickle down from ICC to CBC before we see it in the ADA.

So what’s an architect to do now? Get a copy of the new standard, and use the design principles to make your architecture better serve your community. Architects are innovators, not followers, and if we can get some experience with these new standards in the next few years, we will be in a position to influence changes to Title 24. Not only will you be doing a great service to people with disabilities, but you can tell your clients that you’re looking ahead, and doing what you can to help them future-proof their building, both for their legal protection and in service of our aging population.

I will be interested to see what you design! And as the Accessibility Representative on California’s Building Standards Commission, I’ll be eager to share your experiences in Sacramento.

Comments from Kerwin Lee, AIA, CASp:

It needs to be understood that the authors of the A-117.1 Standards are part of the ICC code process. ICC is a private organization not directly tied to the Government. Supposedly, it is an open public process and anyone can write a code change. These new standard are controversial and were debated at great lengths in committee and at the open ICC code development hearings. It did not make it into the 2016 edition of the IBC and some say that it may or may not make it into a future edition. Because it is not codified in the American with Disabilities Act (ADA) Standards, it is not required for compliance with the ADA, at least at this time.

Remember that California does not adopt or use ANSI A-117.1 as a standard for their building code; we have our own Chapter 11B, which is unique and different from the IBC, which does reference the A-117.1 Standard. California is just beginning their code development cycle for the next edition of the codes. It will be interesting to see what of the new standards makes its way into the CBC and in what form. The biggest issue I see is the proposed separation of “New” and “Existing” buildings. The application and use of the “Path of Travel” requirements in the CBC will need to be addressed in detail on how this works. There are many questions that need to be addressed if any of these are added to the CBC.


2017 and Beyond: Codes

Kerwin Lee, AIA, CASp

As we look back on 2017 and what events had the most impact on codes – it was disasters. The wildfires in Northern and Southern California being the most recent disasters. This always sparks the discussion on what more can be done in the codes to prevent or lessen these types of events.

It was after the 1991 Oakland Hills fire that the state wrote and incorporated Chapter 7A, addressing wildland/urban interface. It was a move to reduce the effects of a wildfire on areas where the urban landscape and construction border on spaces deemed a potential exposure to wildfires. This is usually urban developments that are backed up against open spaces or wooded areas, including areas on hillsides that made firefighting more difficult (because of limited access). The level of risk increases as development continues to push into these areas.

Chapter 7A addresses where urban/wildland interface is considered. For a detailed map of what is classified as “Wildland Interface Fire Area,” there are maps by county, and some by city, defining these hazardous areas where Chapter 7A applies. Here is the link to the state Fire Marshals’ website for the maps and other information related to wildland/urban interface:

If you find that your project falls in these moderate to high hazard areas, compliance with Chapter 7A is required. This chapter addresses the following:

  • Ignition resistant construction, including roofing, vents and exterior coverings
  • Exterior flooring, such as decks and other construction
  • Exterior windows and doors
  • Vegetation Management

Vegetation is important in our environment. We want to have trees and shrubs around our homes, but there may be a price to pay in the increased risk of wildfires. Vegetation management is addressed in detail in the Fire Code, Section 4906. This drawing is from the state Fire Marshals’ website on defensible space:

The recent wildfires in the California go beyond what Chapter 7A covers. Even if you complied with the current state requirements, your building could still have burned. This is mainly because the fires have been so unique and beyond what the code addresses. There are three main elements in a fire: fuel, ignition source and oxygen (air). The air or oxygen in these fires has been ferocious, driven by extreme winds. It is the winds that make the fires so difficult to control and contain. The fuel load and terrain where the fires are located add to this. It will be interesting to see what (if anything) will come out of these events in the form of legislation and/or codes changes. It will be like after 9/11 and the World Trade Center attack, with people saying something needed to be done in the code to prevent this from happening again. We do not design buildings to take the impact of an airplane with tens of thousands of gallons of flammable liquid. And we do not design buildings to withstand a blowtorch or to sit in a furnace.

Going into 2018 we can expect new changes in the code. The state will be working on amending and issuing our next set of codes, the 2019 edition. Things to be looking at will be environmental issues incorporated into building construction and more energy regulations. Disabled access will continue to expand its application. One thing being worked on is incorporating changes in the latest edition of ANSI A-117.1, 2017, which has not been adopted into the IBC for the 2018 edition. It may be adopted in the 2021 edition. There are some significant space changes in the requirements that will affect all designs, including larger wheelchair space and larger maneuvering space. We will have to wait and see how all of these will affect the codes, if adopted.

If the codes do change, we want it to better society and its needs.


Erick Mikiten, AIA

Erick’s Comments

One of the lessons of the North Bay fires is that just following the Building Code is not necessarily enough. As Kerwin said, the codes are always changing in response to new events and research. As licensed architects, we have a responsibility to design thoughtfully – which can mean going beyond the code minimums.

That’s especially true when changes to the building code are in process, which can take years. Lessons from the terrible balcony collapse in Berkeley in 2015 took over two years to get into the state building code. Less-dramatic but still important changes can take much longer. But there’s nothing stopping us from trying to design our buildings to address these issues right away.

This is something I lecture about a lot in universal design, where change is particularly slow. Next month we’ll look at the new 2017 version of ANSI A117.1 that Kerwin mentions and see the changes coming down the pike. You can start incorporating them now – even before they trickle into the California Building Code.

Accessible Path of…Exit…Route…?

Erick Mikiten, AIA, LEED-AP

As architects talk about accessibility, three terms often get caught in a bit of a mash-up, as they did in my title: Accessible Route, Path of Travel, and Accessible Means of Egress. Here’s a brief summary to help you see the differences, followed by a more detailed explanation:

Accessible Route

This is a general term for the floor surface or exterior surface that allows someone with a wheelchair or other mobility aid to get from one accessible part of a building or site to another.

Path of Travel

This is a subset of Accessible Routes; it’s used only in California Building Code (CBC) Chapter 11B in relation to alteration projects.

Accessible Means of Egress

For this phrase, think of Egress as the focus; it’s about getting out of a building in an emergency, and may not be the route or path people use to get in.

Now let’s get into more detail:

Chapter 2 (Definitions) of the CBC describes Accessible Route as “a continuous unobstructed path connecting accessible elements and spaces of an accessible site, building or facility that can be negotiated by a person with a disability using a wheelchair, and that is also safe for and usable by persons with other disabilities. Interior accessible routes may include corridors, hallways, floors, ramps, elevators and lifts. Exterior accessible routes may include parking access aisles, curb ramps, crosswalks at vehicular ways, walks, ramps and lifts.”

An Accessible Route should not be confused with a “Circulation Path,” which is a more general term for all the paths pedestrians use to get from one place to another, which can be the same elements as the Accessible Route, but can also include elements like stairs and landings, which are not accessible elements.

The Accessible Route on your site starts at Site Arrival Points, which can be accessible parking spaces and/or passenger loading zones, public streets and sidewalks, and public transportation stops, and extend to the accessible building entrance. If you have multiple Site Arrival Points, they all need to have an Accessible Route to the entrance. If you are not otherwise providing pedestrian access (a site with only vehicular access), then you don’t have to create a separate Accessible Route.

Next, Path of Travel: This is the code terminology, but think of it as “Accessible Path of Travel” because it is specifically intended to be accessible. As stated above, this is a subset of Accessible Routes applicable to an existing site, building, or facility that’s used to approach, enter, or exit an area.

The Path of Travel extends from the area of work (alterations or addition) to the building entrance and may include Site Arrival Points (sidewalks, streets, parking, and passenger loading zones on site). Inside, the path may also include certain building elements such as toilet and bathing facilities, telephones, drinking fountains and signs serving the area of work. Next time one of your colleagues talks about the Path of Travel in a new building you’re working on together, you can gently correct them and explain that they mean Accessible Route.

An Accessible Means of Egress (Section 1007), is a subset of a general Means of Egress (MOE), Chapter 10 which consists of three components: 1)The Exit (typically a door leading outside, or in a multistory building an enclosed exit stairway), and the paths on either side of it. Those are: 2) the Exit Access (the path from anywhere in the building to the Exit), and 3) the Exit Discharge (the path from the Exit to the Public Way, generally a street or alley).

Those components might include both accessible and inaccessible elements. For example, people may enter a building through a lobby and elevators, but in an emergency, the elevators may not be usable and are not part of the general Means of Egress. In a multi-story building, the occupants have to exit using the stair. Although the stair have usability aspects to them (rise and run requirements, gripable handrails, etc.), they are not part of an Accessible Route, so an Area of Refuge may be required, except in buildings equipped with an  automatic sprinkler system.

There are situations where the Means of Egress are not accessible, such as exiting from an upper level or basement. In those cases people who can’t use stairs need to be protected from a hazard. In most cases, an automatic sprinkler system provides this. If the building does not have an automatic sprinklers system the ability to get to the safety of the stairwells or to an elevator may be required. This would be an “Area of Refuge” under section 1007.6. In this case, both the enclosed stairways and elevator may need to be provided with an Areas of Refuge, which are designated areas outside the required exit path where people can await assistance. Two-way communication is required so that people in these areas can contact rescue personnel.

Similarly, the Exit Discharge on the exterior side of the Exit may sometimes open directly to an alley with no space for a ramp, or have other conditions such as steep terrain that is not wheelchair-accessible. So the code requires either an Area of Refuge inside the building or an Exterior Area of Rescue Assistance separated by the building by at least a one-hour wall. This is often preferable to the interior Area of Refuge, as it is open-air (no potential trapped smoke) and people with disabilities awaiting assistance are more visible to emergency personnel.

Kerwin Lee, AIA

Kerwin’s Comments: Means of Egress for people with disabilities has always been a second thought in the code. Early requirements for people with disabilities was to get them into a building, with no requirements for getting them out. It has only been recently that the code recognizes elevators as not only usable by the Fire Service to access a building, but to use for evacuation and even part of a required means of egress for high-rise buildings. What is not covered in the code is having evacuation plans, especially for people with disabilities. The worst thing in an emergency is to see everyone leaving the building and potentially leaving a person with disabilities behind.

Tiny Homes: Codes

Kerwin Lee, AIA, CASp

Sparked by all of the conservation efforts, tiny homes have recently been presented in TV programs and other forms of media.  Call it a social movement – where people are choosing to downsize the space they live in. The most popular reasons for downsizing includes environmental concerns, financial concerns, and the desire for more time and freedom from the cost and effort of having a large home. One solution is to live smaller. While tiny houses are not for everyone, there are some good aspects for this approach. The typical American home is over 2,000 square feet, whereas the typical small or tiny house is between 100 and 400 square feet.

There are some huddles for taking this approach that need to be addressed in the rules and regulations associated with construction. Both the local zoning regulations and building codes have many elements that could prevent construction of tiny homes in our cities and/or neighborhoods. We will only look some of the building code issues associated with this movement.

First, if the tiny home is on a foundation it will be regulated by the building codes. If the tiny home is on wheels or axles, it is considered a mobile home and would be regulated under those rules. Factory built homes also fall under a different set of regulations, outside of the building code. Currently the state does not have any specific regulations addressing tiny homes, but Housing and Community Development (HCD) has issued a bulletin (Bulletin 2016-01) on what current regulations do cover. Every building in the State needs to comply with something. Here is a link to the Bulletin issued by HCD:

The current building codes, California Building Code or California Residential Code would place some limitations on tiny homes and perhaps would end up not making them so tiny. Currently the codes do address the following in some way:

  • Minimum floor areas
  • Minimum ceiling heights
  • Minimum stair geometries, including handrails and guards
  • Exit and egress windows

If one were to design and build a tiny home – how would you go about getting through the building approval process? Using the code as is today, it is possible to come up with something that is less than 400 sf and would still be comfortable. If one were to design something smaller and push the design envelope beyond the code, the best way under the current code would be to approach it with the use of Section 104.11: Alternative Materials, Design and Methods of Construction. Even using this code approach, one would have to justify why a smaller stair geometry, for example, meets the intent and provides a reasonable level of safety. One would have to do some research in finding justification through test data that a different geometry is as safe as what is in the code.

There is another approach and some light at the end of the tunnel. Proposed for the 2018 edition of the International Residential Code is a new appendix section V. This new appendix will address some of the issues in permitting tiny homes, such as ceiling heights and stair geometry. It is proposed as an appendix section, which makes it optional for the local building official to use and/or adopt. The 2018 edition of the International Codes will be available soon. To even allow this appendix to be in the code was controversial. If the standards for tiny homes are acceptable, why not apply these to all homes since the code is a minimum standard? Some building officials thought the appendix would open a can of worms for smaller/lesser standards to be used everywhere and therefore compromising the already minimum safety standards.

If we expand our use of tiny homes to tiny condos/apartments, sometimes called efficiency dwelling units, we need to address and include people with disabilities. This is another area, totally dependent on space.

Codes: Exterior Elevated Elements (EEE)

Kerwin Lee, AIA, CASp

It has been over two years since the tragic balcony collapse in Berkeley. The city reacted by creating their own ordinance to address the issues, mainly focusing on maintenance. The state has enacted their own Emergency Amendment to the code, which was enacted  at the end of January of this year for a 18-month period. The Building Standards Commission has extended the Emergency Amendment.

The requirements, which amends Part two of the Title 24 and Part ten for existing buildings, has three main points:

  1. Waterproofing documentation
  2. Ventilation of concealed spaces, and
  3. Maintenance

Details of the code requirements can be found in Bulletin 17-01, Dated February 2, 2017 from the Building Standards Commission at:

Let’s start with “Maintenance.” This responsibility falls on the local jurisdiction as to how to implement this. When the city of Berkeley looked at this, it was estimated that 6,000 letters would be sent of building owners.  Each local jurisdiction will deal with this as they see fit.

Item 2 “Ventilation” is new to the code.  The code currently does not address, require or is silent on the issue of ventilation for enclosed balconies or other types of projections.  Ventilation is generally associated with moisture with condensation related to a temperature difference between spaces.  Although the code addresses keeping moisture (weather protection) out of these areas, the basic assumption of the new section is that if there is moisture within these assembles, the ventilation will help mitigate the problem.  The addition of ventilation will also provide visual opportunity to inspect the enclosed or sealed off areas more easily.  The alternative is to provide access panels or performing destructive demolition for inspection and repairs.  So the venting in the ordinance is different from venting in the current code.

The addition of the vents may address one issue, but may also create another issue related to fire protection of the structure.  All new R-1 and R-2 structures are required to be fire resistive in design, Type A construction.  This would include projections, like decks and balconies.  These projections are considered floor or floor/roof assemblies and required to have the same fire resistance as the rest of the building.  By adding all of these vents, which is required in the ordinance to be a minimum 1/150th of the area of the space ventilated, this may compromise the fire resistance integrity of the balcony.  For an 8 x 10 foot deck, a minimum of about 77 square inches of venting is required.  This is potentially a lot of unprotected openings.

Item #1 “Documentation” has a big effect on how drawings are created. The code change requires designers to show the waterproofing associated with the types of exterior elevated elements. First of all how many designers are competent with waterproofing? One can find many details for roofing, decking and opening protections, but what happens when these elements are joined together? What happens when a door opens on to a balcony or deck? Now we have a door opening intersecting a balcony, a horizontal element. This can be a very complicated detail for waterproofing. Perhaps the code change addresses this by requiring venting and physical inspection, with the assumption of waterproofing failure. This issue could be a big responsibility and liability for the designer.

Comments from Steve Winkel, FAIA

I cannot comment in detail on what the CBSC Exterior Elevated Element  (EEE) subcommittee will recommend, as we are in the midst of developing those recommendations. But Kerwin’s comments are all spot-on. The issue of documentation is one where architects who do not consider themselves adept at specifying and detailing deck waterproofing may need to seek expert consulting advice. They also need to be very aware that these issues involve intersections of multiple systems of walls, doors, windows and decks where there are transitions between waterproofing elements, all of which can lead to failures to prevent water intrusion. The one issue Kerwin did not mention was about increased requirements in the new provisions for inspections prior to enclosing deck elements. Designers should consider inclusion of special inspection provisions for decks and balconies under the provisions of CBC Chapter 17.

More Fire Disasters

Kerwin Lee, AIA, CASp

Oakland Construction Site Fire, Alta Waverly – The most recent fire in Oakland shows the vulnerability of buildings under construction. They are easy targets for a catastrophic fire. There have been several major fires in the Bay Area associated with buildings under construction: Santana Row, 2002, San Francisco, China Basin 2014, and Emeryville 2016. All of these were wood framed construction with just the framing up. Fortunately in all of these cases, there was no loss of life. So how does one protect a structure under construction?

Chapter 33 of the California Building Code addresses safety during construction. Also, NFPA-241, which is referenced in the code, is the Standards for Safeguarding Construction, Alterations and Demolition Operations. This would include hazard awareness, ignition prevention and fire protection during construction, mainly water supply and fire department access. The most common cause of construction site fire is associated with “hot work” like welding and grinding of metal. But when it is arson, the code is silent. This becomes a security issue.

Grenfell Tower, London – It is still too early to draw any conclusions from this fire and what went wrong, but the first thing people ask is can this happen in the USA? This should not happen if the construction follows the building codes. Our code, for about the last 20 years, does not permit, or at least limits, combustible construction on or in high-rise buildings. High-rise buildings continue to be the safest type of construction we have. There are a lot of questions about whether there was an operating fire alarm and sprinkler system in the Grenfell Tower.

One of the discussion lines has been on the egress approach and whether shelter in place is appropriate. The standard for evacuation of a high-rise building associated with a fire is to alarm the floor below and two floors above. Setting off the fire alarm system for the entire building would overwhelm the egress system (enclosed stairs). It has been calculated and tested through evacuation drills that for a large high-rise it could take hours to evacuate the entire building. If and when there are high-rise fires, they are usually contained to the floor of origin by the sprinkler system. So this methodology does work. If for any reason the fire expands, the fire department will make the call to expand the evacuation if necessary.

There are many other evacuation options now used, including the use of elevators for evacuations. When the fire department deems it necessary to use the elevators for evacuation, it should be in a logical and orderly manner. Since this approach has never been tested in a true emergency to my knowledge, how it works has a lot of unanswered questions. Who get the use of elevators first? How does one know to use the elevators and how do you know when? People are not going to just wait in the elevator lobby.

When evacuation is required, the most vulnerable people are the ones with disabilities. They really have to depend on the shelter in place concept. A visually impaired person would have a tough time finding the exits alone. There is no simple answer to all of these situations. The best is knowledge of your surroundings and having a plan for self preservation. This is most important for people with disabilities.


Erick Mikiten, AIA, LEED-AP

When we’re designing complex buildings, Means of Egress should be one of the first things we start with. This doesn’t sound exciting, but understanding the basic needs of how to get your building’s occupants out of various spaces and to the Public Way will create the framework for your entire design. There’s nothing worse than getting a great schematic design together, then realizing you don’t have enough exit stairs, or that another rated corridor is needed right where you wanted something else to happen.

One of the benefits of having that framework early is that you can incorporate the ideas of an Accessible Means of Egress well, per Section 1009 of the CBC. This can be a philosophically vexing issue. On the one hand, the ability to exit the building the way you came in is ideal. This is cognitively clear, and in an emergency situation, clarity is critical. But for people with disabilities in a multistory building that often means elevators and the front door.

But what if it’s an older building and that front door is the only accessible entrance and exit? Then someone with a disability might be confronted with stairwells, rated corridors, and stairs at a side or rear exit door. That can be a pretty terrible situation in the midst of a chaotic evacuation during an earthquake or fire. So what to do?

Well, if you think about exiting early on, you’ll have a fighting chance to incorporate better accessible means of egress into your design. So maybe that second exit on the side of your building, with a couple of steps, can be designed with none. Then all people can use it’s impossible to use the accessible entrance lobby. When we are providing  Areas of Refuge in stairwells (Section 1009.3), think about larger wheelchairs and the possibility of having more people in wheelchairs than the code requires. Or someone might have an attendant with them who wants to stay in that space. So make that space larger than the minimum so that that a larger electric wheelchair, or an attendant with someone in a wheelchair, isn’t in the way of the rest of the occupants going down the stairwell.

And when you do introduce an exit component such as an Area of Refuge or Exterior Area for Assisted Rescue (Section 1009.7), take particular care to make your signage extra clear, since the layperson with a disability is generally not aware of these code devices. That will make your buildings safer, more usable, and help everyone exit them in an orderly fashion when needed.

Codes: Building Code and Spell Check

Erick Mikiten, AIA, LEED-AP

How many of you have attended a seminar on the ADA and/or California Building Code (CBC) Chapter 11 and have been bored out of your mind?

This is because a code-based approach to design is about as interesting as a spell check based approach to writing.

Think about it. We have code requirements for every element: floors, walls, roofs and everything in between. When you design those elements, do you feel satisfied with your work if it’s merely code compliant? Do you look to the building code for design inspiration Of course not.

I try to share the underlying principles of accessible design so that architects will be able to design experiences that engage and delight people, or are so seamless that people are free to focus on the wider beauty of your architecture.

Let’s talk about seamless entrance sequences. I am often called in to design or retrofit an existing building entrance. This is because when people are doing alteration to an existing building, CBC chapter 11B-Section 202.4 requires the following:

“When alterations or additions are made to existing buildings or facilities, an accessible path of travel to the specific area of alteration or addition shall be provided. The primary accessible path of travel shall include:

1. A primary entrance to the building or facility,

2. Toilet and bathing facilities serving the area,

3. Drinking fountains serving the area,

4. Public telephones serving the area, and

5. Signs”

So you start at the primary entrance. Very often, the architect or contractor is trying to connect the sidewalk level with the entrance level, so they turn to the tool prescribed by code: The Ramp. Then they start trying to carve the ramp into the stairs, along with the required landings and the whole thing quickly becomes ugly and expensive.

But wait…push the ramp out of your mind for just a minute, and look at the ground plane. Where is it closest in elevation to the building entrance? Can you connect those two points with a gentle walkway? Here’s an example where a level walkway through a former planting strip became an effortless entrance to the Berkeley YWCA, and because it wasn’t a ramp requiring handrails, the edge could become a much-used seat wall.

I can’t tell you how many times I have eliminated the need for ramps completely by constructing level or near level walkways between two points. I suspect that architects and contractors overlook these solutions so often because when one thinks about accessible level changes, our minds naturally go to the code-prescribed ramp.

So back up. Keep in mind that we’re finding architectural solutions to code accessibility, with architecture first – not the other way around. You’re better than spell check.


Kerwin Lee, Architect, CASp

Kerwin’s Comments – The key to using the code is not to just read the text, but to understand the  “intent” of the code. If you understand why the code wants something, you can be better in achieving what the code requires and creating a great design. Sometimes it requires bending the standard interpretation of what the code requires, but meeting the intent. Ask yourself what is the code trying to achieve here? Whether it is life safety or accessibility, it is the same. A lot of accessibility requirements are as simple as getting from point A to point B. As a design, we create the experience of getting from point A to point B. That should be no different for people with disabilities. The first thought is that the experience should be the same for all users, even if the physical aspects may be different. A child in a playground that is in a wheelchair may not be able to use every piece of play equipment, but should be able to experience what is happening. Being with other kids is a big part of the experience. This applies to all elements of the physical environment. The basic original intent of all accessibility requirements is to allow the people with disabilities to be a part of society: inclusion not exclusion.