Accessible Means of Egress and Entrances

November 20, 2008

In a previous post, I had discussed requirements for accessible means of egress in new construction: Grade Level Accessible Exits

While all means of egress are required to be accessible in new construction, it is not a requirement for renovations or alterations.  From the Texas Accessibility Standards:

4.1.6(1)(g) In alterations, the requirements of 4.1.3(9), 4.3.10 and 4.3.11 do not apply.

Section 4.1.3(9) requires accessible exits in the same number as code required exits and permits areas of rescue assistance (ARAs) to be used when conditions preclude accessible exits;

Section 4.3.10 requires that accessible routes shall also serve as means of egress, and;

Section 4.3.11 defines (ARAs).

Therefore, an existing facility that is being altered is only required to have one accessible entrance.  Extra, existing, exits and entrances (nice alliteration) are not required to be made accessible.

Even if an existing entrance is being altered, it is not necessarilly required to be made accessible:

4.1.6(1)(h)* Entrances: If a planned alteration entails alterations to an entrance, and the building has an accessible principal or primary entrance, the entrance being altered is not required to comply with 4.1.3(8), (except to the extent required by 4.1.6(2)), unless the altered entrance will become a principal or primary entrance by design or function. If a particular entrance is not made accessible, appropriate accessible signage indicating the location of the nearest accessible entrance(s) shall be installed at or near the inaccessible entrance, such that a person with disabilities will not be required to retrace the approach route from the inaccessible entrance.

Now according to section 4.1.5, additions are to be regarded as alterations.  But this does not mean that the new exits from an addition are exempt from access.  “Each space or element added to the existing building or facility shall comply with the applicable provisions of 4.1.1 to 4.1.3…” including accessible exits and/or the provision of ARAs.

You may be wondering why accessible means of egress are not required in existing buildings.  But keep in mind that the Standards are a minimum requirement.