LAX APM ADA Coordinator Files (LINXS)
Selected accessibility references from the building code and other resources are provided here for general information and educational purposes only. Limited excerpts are generally protected by the “fair use doctrine” of Section 107 of federal copyright law. Ultimate copyright is reserved to the original author and/or publisher as appropriate.
The following questions and answers refer to accessibility requirements and references and may not be applicable to non-accessibility topics.
Answer: Sections 4450(a), 4450(b), 4451(c), and 4452 of the California Goverment Code direct the State Architect (as the Division of the State Architect or DSA) to establish accessibility standards for “all buildings, structures, sidewalks, curbs, and related facilities, constructed in this state by the use of state, county, or municipal funds, or the funds of any political subdivision of the state” as codified in the California Building Standards Code, also known as Title 24 of the California Code of Regulations (CCR). Part 2 of Title 24 is known as the California Building Code (CBC). CBC Chapter 11B (Accessibility to Public Buildings, Public Accommodations, Commercial Buildings and Public Housing) “contains scoping and technical requirements for accessibility to sites, facilities, buildings, and elements by individuals with disabilities.” While most of DSA’s accessibility standards are codified in CBC Chapter 11B, some provisions are located in other CBC chapters, especially Chapter 2 (Definitions), and in a few other parts of Title 24 (including Part 1). The authority of DSA to establish accessibility standards within the CBC and enforce them is described by CBC Section 1.9.1.
A mostly complete reference of applicable California accessibility provisions are published by DSA as the California Access Compliance Advisory Reference Manual, which is available at their Access Compliance Reference Materials page. In addition, the current and last few previous triennial editions of Title 24 CCR are available for free viewing online through links provided by the California Building Standards Commission (BSC).
Answer: In most cases, the APM project is reviewed and approved under the 2016 Triennial Edition of Title 24 CCR, including the “intervening code cycle update” that became effective on July 1, 2018. (References to “CBC” should be assumed to be to this version unless otherwise noted.) However, regulations for accessibility compliance dictate that the applicable code version is based on the date of initial submittal for permitting or approval by the “authority having jurisdiction” (AHJ), so some portions of the project that were not included in the initial regulatory approval process under the 2016 (supplemental) edition may be subject to the 2019 Triennial Edition of Title 24, which became effective on January 1, 2020; furthermore, this may inlcude the “intervening code cycle update” that became effective on July 1, 2021, based on the date of initial submittal of each portion of the project.
Answer: No. Interpretations and avisories are always subordinate to published code text. As noted in the preamble to DSA’s California Access Compliance Advisory Reference Manual:
It is important to note that the remarks in this manual are intended to be informative but they are not a substitute for the requirements of the code. Also, despite the informative nature of this manual, it is the appropriate jurisdictional code official who possesses the exclusive authority to enforce and interpret the requirements of the building code. This manual provides informal assistance regarding California accessibility requirements only for DSA’s code-enforcement jurisdiction. The information contained in this manual is not binding on the Division of the State Architect and is not intended or designed to give any legal advice on compliance with federal, state, or local laws and regulations. It should be noted that laws, regulations, and standards are subject to revisions, additions, or deletions, at any time.
However, code interpretations and advisory notes provide useful insight into the intent of code provisions, inlcuding their intended scope or application, that may be considered authoritative by any given authority having jurisdiciton (AHJ). While not legally binding on the AHJ or courts, both entities tend to give deference to code interpretations and advisory notes, and the ADAC makes use of this information in its assessment of the project design and construction.
The following excerpts from accessibility standards are provided for reference. Comments, advisories, and interpretations by Authorities Having Jurisdiction and/or the ADA Coordinator are provided where available. “Section” references are from the California Building Code (CBC) unless otherwise noted.