Administrative and General Design Subcommittee
CODE ADVISORY COMMITTEE
Notice of
Regular Meeting of the
Administrative & General Design Subcommittee
DATE: March 20, 2002 (Wednesday)
TIME: 8:00 a.m. to 9:00 a.m.
LOCATION: 1660 Mission Street, Room 2001
This subcommittee meets regularly every third Wednesday of the month at 1660 Mission Street, Room 2001. If you wish to be placed on a mailing list for agendas, please call (415) 558-6205.
Note: Public comment is welcome and will be heard during each agenda item. Reference documents relating to agenda are available for review at the 1650 Mission Street, Suite 302. For information, please call Alan Tokugawa at (415) 558-6004.
AGENDA
1.0 Call to Order and Roll Call
Members: Frederic Freund, Chair; Dorie Lee; Arnold Lerner, AIA; Zachary Nathan, AIA; Tony Sanchez-Corea, III.
2.0 Approval of Minutes of the subcommittee meeting of February 20, 2002.
3.0 Discussion and possible action regarding a proposed Administrative Bulletin No. 95-11, "The Area of Remodel in an Existing Building." This bulletin will provide guidelines for determining the area of remodel in an existing building in order to assess the level of access required within and triggered by the renovation, structural repair, remodeling, addition or alteration. The possible action will be to formulate a recommendation to the full Code Advisory Committee for their further action.
4.0 Discussion and possible action regarding proposed revisions, corrections and additions to the 1998 California Building Code in preparation for the 2001 edition of the San Francisco Building Code. The following chapters will be discussed:
Chapter 1* Administration
Chapter 2* Definitions and Abbreviations
Chapter 10A* Security Requirements
Chapter 12* Interior Environment
Chapter 14* Exterior Wall Coverings
Chapter 15* Roofs and Roof Structures
App. Chap.15* Re-roofing
Chapter 24 Glass and Glazing
Chapter 25* Gypsum Board and Plaster
Chapter 26* Plastic
Chapter 30* Elevators, Dumbwaiters, Escalators and Moving Walks
Chapter 31* Special Construction
Chapter 31B Public Swimming Pools
Chapter 31F* Signs
Chapter 32* Construction in the Public Right-of-Way
Chapter 35 Uniform Building Code Standards
* San Francisco amendments made to this chapter.
5.0 Subcommittee Members' and Staff's identification of new agenda items, as well as current agenda items to be continued to another subcommittee regular meeting or special meeting. Subcommittee discussion and possible action regarding administrative issues related to building codes.
6.0 Public Comment: Public comment will be heard on items not on this agenda but within the jurisdiction of the Code Advisory Committee. Comment time is limited to 3 minutes per person or at the call of the Chair.
7.0 Adjournment.
Note to Committee Members: Please review the appropriate material and be prepared to discuss at the meeting. If you are unable to attend, please call Chair Frederic Freund at (415) 981-5780. The meeting will begin promptly.
DRAFT
ADMINISTRATIVE BULLETIN
August 26, 1997
NO.AB.
SUBJECT : The Area of Remodel in an Existing Building
TITLE : Area of Remodel - A Definition.
PURPOSE : The purpose of this Bulletin is to provide guidelines for determining the area of remodel in an existing building in order to assess the level of access required within and triggered by the renovation, structural repair, remodeling, addition, or alteration.
By applying these guidelines, the design professional may be able to design a code complying level of access into projects valued either above or below the threshold amount for administrative approval by the Department of Building Inspection.
REFERENCES : California Code of Regulations (CCR), Title 24, Part 2, Section 402(n), Section 3109A, Section 3112A(a).
DISCUSSION : Most existing buildings and facilities are required to be made accessible when alterations, structural repairs, or additions are made to such buildings or facilities under Section 3112A(a). These requirements apply to the specific area of remodel, which must generally be made accessible under the same standards as if the building were newly constructed. In addition, certain key accessible requirements are triggered by the remodeling and include a primary entrance, a primary path of travel, restroom facilities, telephones, and drinking fountains serving (but typically outside of) the area of remodel.
Sometimes it is difficult for both permit applicants and plan checkers to clearly define the area of remodel for purposes of assessing the level of access triggered by the improvement. A large tenant improvement taking place on each level of a three story tenant space in some instances would trigger an elevator (path of travel) or at least improvements to an existing elevator, as well as restrooms, drinking fountains, and telephones on three different levels. A smaller tenant improvement occurring on the ground floor of the same tenant space might only trigger a primary entrance, path of travel, and restrooms on the ground level.
A seismic retrofit that requires relatively minor bolting of floor and wall frame elements throughout the entire structure might have no localized definable area of remodel, because the work could take place with relatively no disruption to the interior elements or within non-occupiable spaces.
But more commonly, a tenant will undertake a remodeling venture within a very specific portion of the tenant space or building. This interpretation and ruling provide a method for identifying these specific areas so that designers, plan checkers, and building inspectors can ensure that a reasonable, code complying level of access is provided with each individual remodeling project.
It is the interpretation of this Department that the area of remodel is narrowly defined by the actual work performed in the specific area of a building or facility, and also by its relationship with adjoining elements. Partitions, walls, and corridors which redefine or improve existing spaces, and enclose or draw boundaries around an area, create a box within which generally everything shall comply with all of the requirements for a new building. Exceptions are when individual elements remain untouched within this area.
Example: An applicant submits plans to the Building Department to remodel an existing restaurant. The scope of work includes relocating partitions, enlarging the kitchen with new counters, and the installation of new built-in seating booths with some movable tables. An existing bar and counter remain untouched except for the application of a new coat of varnish. In this case, all of the new partitions and associated doors, corridors, aisles, and counters, and seating, would be considered the area of remodel and would need to comply with the provisions for new construction. In addition, a primary entrance and restrooms, drinking fountains, and telephones serving the area of remodel would have to be made accessible. The existing bar however was not remodeled and even though it may be physically located within a space which was remodeled around it, would not be subject to the access requirements.
Path of travel features such as stairs, ramps, doors, and elevators, when newly constructed or remodeled, may be closely linked with other elements which together become a more inclusive feature such as entrances.
Example: An applicant submits plans to install a new door in an existing location. The new door would need to meet all of the requirements for new construction such as width, height, hardware, etc.. The door however opens out over an existing landing which is sloped steeper than 1/4" per foot and adjoins a ramp which lacks handrails. Since these three elements, ramp, landing, and door, together constitute an entrance, all of these elements would be considered the area of remodel and would have to comply. The landing may require reconstruction, and the ramp would require handrails etc.
Just because a tenant occupies multiple levels and is under going substantial improvements does not necessarily mean that all of the levels are being remodeled and therefore that a vertical path of travel via ramp or elevator is triggered to connect the multiple levels.
Example: An applicant submits plans to construct new partitions, new restrooms, and built-in casework within a space that includes a legal mezzanine. There will be offices located on the mezzanine level, but the only improvements taking place up there are of a cosmetic (painting) nature. All of the new work on the ground floor would have to comply with the new code requirements because that work is taking place within the area of remodel, but since the mezzanine is not actually being altered with the exception of painting which does not trigger access, there would be no requirement to provide a path of travel to that level since it is not a part of the area of remodel.
A structural repair such as dry-rot repair or a seismic retrofit, may take place on the exterior of a building, or within spaces which are not typically occupied. Section 3103A(a) Exception 1 exempts the requirement to provide an accessible path of travel by ramp or elevator to floors or portions of floors which are not customarily occupied. However it is important to remember that structural repairs still trigger access, and the code very clearly requires at least the entrance, restrooms, drinking fountains, telephones, and parking serving the area of remodel. Furthermore, there are no accessibility requirements for anchor bolts, exterior diagonal braces, or crawl space basement wall framing within the area of remodel, other than the access which is triggered by the structural repair. These types of projects may have no definable area of remodel for purposes of assessing an entrance, path of travel, and number of restrooms serving the area..
Example: An applicant submits plans for the seismic retrofit (structural repair) of a two story commercial building. The value of the work is $150,000.00 and consists of upgrades to the foundation within a crawl space, anchor ties to the underside of the floor joists, and improvements to the roof diaphragm. The majority of this work takes place in non-occupiable spaces within the crawl space or on top of the roof. The remainder of the work involves very minor localized plaster demolition at individual anchor locations. In this example there is no definable area of remodel outside of the non-occupiable spaces.
The access triggered by this project would be an accessible entrance, restrooms for each gender on the ground floor, and drinking fountains, telephones, and parking if provided. An elevator or other path of travel to the basement or roof would not be triggered.
Buildings or portions of buildings may contain more than one occupancy or use, only one of which may be subject to the accessibility requirements. A seismic retrofit or structural repair in a building like this may have work which occurs throughout the entire building but for purposes of assessing the area of remodel, only that portion of the building subject to the accessibility requirements would be considered.
Example: An applicant submits plans for the seismic retrofit of a four story mixed-use unreinforced masonry building. The upper three stories are existing residential units which are exempt from the access requirements due to their original construction pre-dating 1986. The ground floor is occupied by three small commercial units. The seismic retrofit work will affect the entire building and is valued at $200,000.00.
Since the upper levels are an exempt occupancy, there is no requirement to provide access at all either to or on the upper levels. For purposes of evaluating the amount of access required on the ground floor commercial level, it would be appropriate to place a value upon the amount of seismic strengthening taking place on that level. This may be accomplished by either dividing the total value of the project by the number of floors in the building, or by relying upon a verifiable estimate provided by a design professional or contractor. In this example, if we divide the total value $200,000.00 by the number of floors (4), then we arrive at a total amount per floor equal to $50,000.00. Since only the ground floor is subject to the access requirements, then the total value of seismic work subject to the access requirements is $50,000.00. This project would then be eligible to use the 20% disproportionality rule for projects valued under the threshold. In this case the area of remodel subject to the access requirements would only be the ground floor areas affected by the work.
There are a number of buildings and occupancies which were previously exempt from the access requirements but since the code revision of 1994 which incorporated more restrictive requirements from the Americans with Disabilities Act (ADA), are no longer exempt. Those buildings are listed in Section 3112 A (a) Exception 2 and they are eligible to use the 20% disproportionality clause for areas above and below the ground floor regardless of the total construction cost. In evaluating the area of remodel in these buildings for purposes of assessing the level of access serving that area, it may be necessary to look at the work on a floor by floor basis similar to the example above.
Example: An applicant submits plans to seismically retrofit a three story building through the installation of a moment resisting brace frame, collector beams, and anchors which involve the penetration and substantial alteration of all three levels. The value of the work is $450,000.00. The ground floor must clearly be fully accessible since this level has always been subject to the access requirements and since the value of the work is over the threshold. The upper two stories were previously exempt however under Section 3112A(a) Exception 2 and are eligible to use the 20% rule. For purposes of assessing the level of access required on the upper levels it would again be appropriate to divide the total value of the work, $450,000.00 by the total number of floors, three, to arrive at a figure which represents the amount of work done on each floor. A verifiable estimate from the engineer, contractor, or design professional would also suffice. In this example, the figure we arrive at is $150,000.00 per floor. The upper two stories must each be provided with the accessible features at the rate of 20% of $150,000.00 which equals $30,000.00 per floor. Access shall be provided in the priority listed with first priority the front entrance, second priority the path of travel, and third priority restrooms for each gender.
DISTRIBUTION:
AIA (5) BOA (1) CA (2) DPW/DAC ( 1)
AGC (5) BOE (1) CAO (1) PSF ( 1)
ASHRAE (1) BOMA (2) DCP (5) SEAONC ( 1)
BCM (1) BPA (1) DPW (2) SFFD (12)
SPUR ( 1)
Access Appeals Commission ( 5 )
Board of Examiners ( 8 )
Building Code Advisory Committee (15)
Chamber of Commerce ( 1 )
Daily Pacific Builder ( 1 )
Housing Construction ( 1 )
Mayor's Office ( 1 )
Residential Home Realtors ( 1 )
Seismic Safety Program ( 1 )
S.F. Board Realtors ( 1 )
Unreinforced Masonry Building Appeals Board ( 9 )
Department of Building Inspection:
Director ( 1 )
Deputy Directors ( 2 )
Administration ( 6 )
Building Inspection (40)
Central Permit/Records Management (40)
Code Enforcement Division ( 2 )
Commercial Plan Check (20)
Customer Services (40)
Disability Access Complaints ( 4 )
Electrical Inspection (22)
Housing Inspection (20)
Management Information Systems ( 1 )
Plumbing Inspection (15)
Residential Plan Check ( 6 )
UMB/Major Projects ( 8 )
Mechanical Plan Check ( 2 )
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