I have been challenged on plan check and want to make sure I am not being too conservative in my interpretation of 11B-206.4., and would appreciate knowing what others think.


Entrances and exterior ground floor exits.
All entrances and exterior ground-floor exits to buildings
and facilities shall comply with Section 11B-404.

The picture indicates the situation at issue. The trucker's entrance at the truck dock is via steps. I think it is an entrance subject to 11B-206.4


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I see it:

2. Exits in excess of those required by Chapter 10,
and which are more than 24 inches (610 mm)
above grade shall not be required to comply with
Section 11B-404. Such doors shall have warning
signs complying with Section 11B-703.5, stating
that they are not accessible.

This is an entrance/exit, not an exit so does not apply. believe me I am trying to find a way that this does not have to be accessible, since there are other ways to get into the building that are accessible. CA's requirement that every entrance be accessible is the problem.  The only thing I can think of is that we can classify this as an exit-only, but everyone knows it is an entrance for the truck driver. 


Things like this are frustrating.  A number of years ago I had a plan reviewer demand I show an accessible counter in a FedEx truckers checkin office.  I asked him when was the last time he saw a disabled FedEx driver.  Another time I had to provide a ramp to a switchgear elec room.  It appears there is an exception for mech rooms but not elec rooms.  AARGH

What about 11B-206.4.7?  then you only need to comply with 11B-404 and not 402 which is the section that hurts you.  Per CBC definitions

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.

My analysis so far leaves an intent question (see last line) that I will have to ask of DSA.

General Exemptions don’t help:We have our general exemptions that do not apply. I can forget about those although here are the ones that are close just for reference in case I am missing something:

11B-203.1 General. Sites, buildings, facilities, and elements are exempt from these requirements to the extent specified by 11B-203. 

11B-203.5 Machinery spaces. Spaces frequented only by service personnel for maintenance, repair or occasional monitoring of equipment shall not be required to comply with these requirements or to be on an accessible route. Machinery spaces include, but are not limited to, elevator pits or elevator penthouses; mechanical, electrical or communications equipment rooms; piping or equipment catwalks; water or sewage treatment pump rooms and stations; electric substations and transformer vaults; and highway and tunnel utility facilities 

11B-203.6 Single occupant structures. Single occupant structures accessed only by passageways below grade or elevated above standard curb height, including but not limited to, toll booths that are accessed only by underground tunnels, shall not be required to comply with these requirements or to be on an accessible route. 

The general requirement for entrances:If an area containing the entrance is not subject to general exemptions then every entrance is covered by 206.4:

 11B-206.4 Entrances. Entrances shall be provided in accordance with Section 11B-206.4. Entrance doors, doorways, and gates shall comply with Section 11B-404 and shall be on an accessible route complying with Section 11B-402.

 Restricted entrance provision:Public entrance, restricted entrance and service entrance are all defined so the fact that 206.4 does not distinguish between them means it may apply to all these types of entrances. Strangely, there is section 206.4.7 that follows 206.4, feels like an exception, but is not placed as an exception to it. It seems to suggest a partial exclusion for restricted entrances because it requires the door to be accessible (404) but not that it be on an accessible route (402). 

11B-206.4.7 Restricted entrances. Where restricted entrances are provided to a building or facility, all restricted entrances to the building or facility shall comply with Section 11B-404.

 This is a restricted entrance, not a service entrance:The definition of restricted entrance excludes entrances that are primarily service entrances, and that is ok because this is not an entrance primarily for the delivery of goods or services, only occasionally when the package is small; usually goods are coming through the roll-up door, not the man-door entrance: 

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.

SERVICE ENTRANCE. An entrance intended primarily for delivery of goods or services.

 Conclusion:If 11B-206.4.7 is meant to be an exception of sorts for the full requirement of 206.4, then a restricted entrance may comply with 404 and not 402, and this appears to be a restricted entrance. I am still left with doubts as to whether 206.4.7 is intended to trump 206.4 in this regard.

One time I called DSA with a similar question and the first question they asked was what type of project it was.  Once they found out it was a privately funded project they told me to call the local bldg official.  Said they were the ones who interpreted the Code for privately funded projects


"No alternate accessible route to an accessible entrance"

To address Mr. Handler's question, there is an accessible entrance somewhere that the driver (and everyone else) can use to enter... right?



"There needs to be an accessible entrance."

Agreed. But, 11B-206.5.1 suggests that there are some entrances that do not need to comply with 11B-206.4 or 11B-404. For instance, 11B-206.4.8 indicates that if a Service Entrance is not the only entrance to the building or to a tenancy in a facility then it is not required to comply with 11B-404. Also, according to 11B-206.4.6 secondary entrances to a residential dwelling unit needn't comply either.

"Maybe not that one but one nearby."

How closely nearby?

"With signage directing the driver to the entrance point."

Do any other parking spaces or doors, that are specifically exempted from the requirement to be part of an accessible route, also require this signage?

"A buzzer does not cut it."


Thank you gentlemen. I'm trying to understand these requirements.

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