2022 CRC – Aging-in-Place by Jonathan Clark

Happy New Year!

This new year brings a little more than usual because effective January 1st the new California 2022 building codes are in effect.  There are positive and negative effects associated with every code cycle change.  I think many of us don’t have an opinion either way until we are surprised by something we weren’t aware of that we now need to comply with.  Even though classes, seminars, and publications try to prepare us for the changes, there is still some time that is needed for all of us to get comfortable with the changes.

With this article I want to quickly discuss the accessible provisions of the California Residential Code (CRC), and then focus more on new provisions of the CRC that address aging-in-place requirements.

The CRC does have disabled access provisions found in Section R320 Accessibility.  These provisions seem minor and insignificant because they are just a few paragraphs. These are also often overlooked because one and two-family dwelling units (single-family homes or duplexes) fall outside of this section’s scope.  This section aligns with the California Building Code (CBC) Chapter 11A/Housing Accessibility scoping requirements that have been enforced in the state for some time.  Essentially, if residential dwelling units meet a certain number then CBC 11A is applicable and needs to be applied.  The California codes distinguish between privately funded housing (covered by chapter 11A) and publicly funded housing (covered by chapter 11B).  It is important to remember that distinction.  I am often asked about accessibility where differences occur between the two and it is sometimes difficult to explain why we have two and what that means.  The quick takeaway is that if a project is residential (multi-Family, three or more units) in nature and not publicly funded, then CBC chapter 11A applies as a minimum requirement.  Owners and other factors might play into whether or not to provide additional accessibility to the project.

Starting with this code cycle Section R327, titled “Aging-in-Place Design and Fall Prevention” was added to the CRC. For those who are familiar with CBC Chapter 11A, I like to describe it as 11A lite for all housing.  So this section definitely applies to single-family homes and duplexes and any other dwelling units unless they meet one of the exceptions.  The exceptions are straightforward; provide a higher level of accessibility required by CBC 11A or 11B and you don’t need to do the aging-in-place requirements.  Also, some multi-story unit (townhome) projects that comply with CBC 11A as a whole project might still have the aging-in-place requirements applied to dwelling units that aren’t required to meet CBC 11A provisions.

The main aspects of this section address the following subjects:

  1. Reinforcement for grab bars (CRC R327.1.1)
  2. Electrical receptacle outlet, switch and control heights (CRC R327.1.2)
  3. Interior doors (CRC R327.1.3)
  4. Doorbell buttons (CRC R327.1.4)

A lot of times when I need to educate people about the big difference between CBC 11A and 11B I explain it as 11A is designing a space or building to be more easily accessible in the future (the term adaptable is used to covey this idea) versus 11B is designing and providing everything accessible now.  The provisions related to aging-in-place is a mixture of the two concepts.  11A requires that certain items be designed to accommodate future accessibility needs without remodeling the building but other items to be planned for and installed later when the need arises.  The aging-in-place provisions follow this concept.

The first provision requires reinforcement for grab bars in various locations in bathrooms.  These locations are where we typically would see grab bars in a built-out accessible bathroom; around toilets, tubs, and showers.  The requirement is to provide this at an entry level bathroom and if there was no bathroom at the entry level then a bathroom on either the second or third floor.

The second provision describes the heights for electrical outlets, switches, and controls.  Most often standard heights fall within these ranges.  This code now controls these items explicitly and doesn’t allow for deviation without exception.  These heights align very closely with common accessible reach ranges.

The third provision becomes effective July 1, 2024.  This provision requires a typical accessible door clearance in at least one bedroom and one bathroom.  Again, this requirement is similar to the grab bar reinforcement in that it is to be provided at the entry level rooms and if that is not possible at the entry level then at the second or third floor.

The last provision dictates the doorbell controls heights.  This is similar to the electrical provisions.

As we get started with the new code the most impactful part of the aging-in-place provisions are the grab bar reinforcement.  The electrical and doorbell provisions should not be that impactful unless the installer keeps doing things like they have always done.  Because the interior door provision isn’t effective until July 1, 2024 some discussion should be had about implementing that now or waiting.  That would really depend on the project and its duration.  We work on many projects that will start now and not be finished until after the effective date.  So having a plan of attack on how to approach that code provision is important to consider now.

The last thought that I have on the subject is to be aware of what might come in the future.  Like I said in the beginning, I see this as CBC 11A lite.  So I can imagine that in future code cycles that more and more CBC 11A provisions get included in this section to provide more built-in accessibility.

Jonathan Clark
Architect | Principal

Comments from Kerwin Lee, AIA: Jonathan briefly mentioned the differences between Chapter 11A and B regarding housing. The main reason for the State having two Chapters to address disabled access is the origin of the two: One was based on the Fair Housing Amendment Act (FHAA) and the other the Americans With Disabilities Act (ADA), both written by the Federal Government. The FHAA, which is under the Housing and Urban Development (HUD), was first used to apply to Federally Funded Housing Projects and later expanded to apply to all multi-family housing/dwelling. The ADA applies to many aspects, from labor, to Governments and public accommodations, goods and services to the general public. Because the two Acts/Laws are different in where they are applied, therefore we have Chapters 11A and 11B in California.

The concept of aging in place is not new. Any designer who has done so-called senior facilities has seen this concept to include regular housing to assisted or residential care to full non-ambulatory care within a complex or structure. Take this concept into a single family dwelling so that your parents or grandparents can continue to live their lives out. What is in the CRC is truly “lite”. It is always better to exceed the “minimum” of the codes.

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