A small tenant build-out has been submitted to the Chicago Department of Buildings for Permit Review. While there are some minor changes to the configuration of the floor plan, there are no significant changes. When the plans are released from DOB, there is a correction from the Accessibility Plan Examiner, which typically states:
“Architect to comply with the alteration section CBC (Chicago Building Code) Chapter 18-11-1117.3.4 regarding “alterations affecting an area containing a primary function. Also review the Exceptions section regarding the cost to provide the accessible route is not required to exceed 20 % of the costs of the alterations affecting the area of primary function. In addition, review any existing toilet rooms and drinking fountains, (if any), for full accessibility.”
Chicago Building Code notes that if an alteration affects the accessibility to an area of primary function, or contains an area of primary function, the route to the primary function area shall be accessible. The accessible route to the primary function area shall include an accessible entrance to the building, vertical accessibility, toilet facilities or drinking fountains serving the area of primary function.
It is our understanding that the area of primary function is the space being altered. Where a tenant space is being altered and the estimated alteration costs divided by the estimated reproduction costs is less than 15%, only requiring the areas being altered to be accessible, if a toilet room is not accessible and not being altered, and accessibility modifications could be done at 20% of the alteration cost for the project, it should be incorporated into the scope of work. If existing toilet rooms appear to meet compliance, an assessment should be done to determine if any additional modifications would be required to meet the current accessibility requirements such as vertical grab bars, coat hooks, toilet paper dispenser location, etc.
In order to address this correction, the drawings should demonstrate that:
1) Compliance can’t be met at 20% of the alteration costs;
2) The existing elements meet full compliance or;
3) Specific elements that are being altered shall show compliance with these requirements.
Submitted by Leah Riley