maybe i am not reading the CBC correctly but it appears that it does not require an accessible work surface in kitchens at places of education such as college apartments.  this doesn't seem right but section 11B-804.3 indicates that the requirements only apply to residential dwelling units subject to 11B-809, which does not include housing at a place of education, which is subject to the requirements for transient lodging.  am i correct?

Paul L. Bishop, Architect
Original Post

Yet 11B-806.2.5 requires compliance with 11B-804. Are we to believe that 11B-804.3 is exclusively for residential dwelling units? This wasn't the case under the previous CBC - see 1111B.4.4.

Oversight? Or code change?

I bet it's an oversight, unless it doesn't agree with the federal law. There is a big push by the State Architect to (in my opinion) lower many of our long-time more stringent standards to comply with lower federal standards. I have no idea why we would have a state government (governor and his appointed state architect) who would not be very proud of our leadership in the field of disabled access. I always have been, and have been happy to talk about it on a national level. I am often met with comments of "how lucky you are to be in California, where this is taken seriously." 

Well, there is this:

The Department of Justice’s revised ADA title II regulation (35.151(f)) and title III
regulation (36.406(e)) at require the following:

Housing at a place of education. Housing at a place of education that is subject to this part [of the title III regulation or to this section of the title II regulation] shall comply with the provisions of the 2010 Standards applicable to transient lodging, including, but not limited to, the requirements for transient lodging guest rooms in sections 224 and 806, subject to the following exceptions. For the purposes of the application of this section, the term "sleeping room" is intended to be used interchangeably with the term "guest room" as it is used in the transient lodging standards.

(1) Kitchens within housing units containing accessible sleeping rooms with mobility features (including suites and clustered sleeping rooms) or on floors containing accessible sleeping rooms with mobility features shall provide turning spaces that comply with section 809.2.2 of the 2010 Standards and kitchen work surfaces that comply with section 804.3 of the 2010 Standards.


thanks for the help everybody.  i see it now in 11B-806.2.5, as well as in 11B-224.7 exception 1.  it is just unfortunate that the 2013 CBC was written by incorporating the text of the 2010 ADAS, but then also adding additional text such as 11B-224.7.  the result is maintaining the original 2010 ADAS text such as found in 11B-804.3, which says "in residential dwelling units required to comply with Section 11B-809...", even though the following requirement also applies in other circumstances, such as in housing at a place of education.  there should be additional language in 11B-804.3 that states "and where required elsewhere in this chapter...".  but it doesn't.

paul l. bishop_SanDiego,CA posted:

... there should be additional language in 11B-804.3 that states "and where required elsewhere in this chapter...".  but it doesn't.

Good idea. Suggest it for the 2019 Code Cycle

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