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TAS/ADA Entrances. When is an Accessible Route required? And when do you have to provide maneuvering clearances and compliant hardware?
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As usual, we will start with the definitions from the 2012 TAS. We will start with what qualifies as an "entrance".
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106.5.29 Entrance. Any access point to a building or portion of a building or facility used for the purpose of entering. An entrance includes the approach walk, the vertical access leading to the entrance platform, the entrance platform itself, vestibule if provided, the entry door or gate, and the hardware of the entry door or gate.
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It is important to note that a door intended for exiting the building only, like an emergency exit, is not considered an entrance. These are considered Means of Egress and would be required to comply with whatever version of the IBC the local AHJ requires.
Here are the different types of entrances recognized and defined in the 2012 TAS.
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106.5.49 Public Entrance. An entrance that is not a service entrance or a restricted entrance.
106.5.55 Restricted Entrance. An entrance that is made available for common use on a controlled basis but not public use and that is not a service entrance.
106.5.59 Service Entrance. An entrance intended primarily for delivery of goods or services.
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Next, lets look at the scoping requirements in Chapter 2 to see when an entrance requires an accessible route complying with 402, and when the entrance must comply with 404.
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Next, lets look at the scoping requirements in Chapter 2 to see when an entrance requires an accessible route complying with 402, and when the entrance must comply with 404, which talks about doors, doorways, and gates.
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206.4 Entrances. Entrances shall be provided in accordance with 206.4. Entrance doors, doorways, and gates shall comply with 404 and shall be on an accessible route complying with 402.
EXCEPTIONS:
1. Where an alteration includes alterations to an entrance, and the building or facility has another entrance complying with 404 that is on an accessible route, the altered entrance shall not be required to comply with 206.4 unless required by 202.4.
2. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, no more than one public entrance shall be required to comply with 206.4. Where no public entrance can comply with 206.4 under criteria established in 202.5 Exception, then either an unlocked entrance not used by the public shall comply with 206.4; or a locked entrance complying with 206.4 with a notification system or remote monitoring shall be provided.
206.4.1 Public Entrances. In addition to entrances required by 206.4.2 through 206.4.9, at least 60 percent of all public entrances shall comply with 404.
206.4.2 Parking Structure Entrances. Where direct access is provided for pedestrians from a parking structure to a building or facility entrance, each direct access to the building or facility entrance shall comply with 404.
206.4.7 Restricted Entrances. Where restricted entrances are provided to a building or facility, at least one restricted entrance to the building or facility shall comply with 404.
206.4.8 Service Entrances. If a service entrance is the only entrance to a building or to a tenancy in a facility, that entrance shall comply with 404.
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It is important to note that in 206.4 it specifically states that all entrances must be on an accessible route. Exception 1 exempts the accessible route requirements, and 404, when the alteration already has an entrance complying with both. The other caveats in 206.4.1 - 206.4.8 give an exemption for 404 which is Doors, Doorways, and Gates. 404 is more about clearances and door hardware. Not accessible routes.
For more on Primary Function Areas, see my previous newsletter here.
Also keep in mind that if the alteration is to what is considered a "Primary Function Area", then you can't use the exception.
In my opinion, it sounds like they want to make sure that in new construction all entrances are easily adaptable for full compliance in the future if the building use or layout changes.
Hopefully you now understand when 402 Accessible Routes must be complied with when it comes to entrances, as well as which entrances must comply with 404 Doors, Doorways, and Gates.
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Should you have any questions regarding this newsletter, or another area of accessibility, please feel free to reach out to me.
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