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A-02 Accessibility for New Agricultural Processing Facilities, Conversions, Additions, Wine Caves, and Accessory Structures

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The purpose of this technical bulletin is to clarify the accessibility requirements for several types of projects involving agricultural processing. Applicable facilities include wineries, cheese production, olive oil extraction and similar processing, and also new facilities, building conversions, additions and the construction of new buildings within existing facilities, including wine caves. Buildings that are issued an agricultural exemption are required to meet all code requirements.

Effective Date: 07/14/2008
Revised: 09/25/2012, 04/26/2013, 11/01/2013, 10/23/2014

General

Section 11B-201.2 of the California Building Code (CBC) reads as follows:

  • “Where a site, building, facility, room, or space contains more than one use, each portion shall comply with the applicable requirements for that use.”

An accessible route complying with Section 11B-202.4, 11B-206.2.2 and 11B-401 shall connect all elements and spaces within a building or facility.

There are exceptions for:

  • Limited access spaces: Spaces not customarily occupied and accessed only by ladders, catwalks, crawl spaces or very narrow passageways shall not be required to comply with these requirements or to be on an accessible route” (11B-203.4).
  • 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-203.5)

The application of this section to agricultural processing facilities, especially additions and conversions at existing facilities, raises several complex issues. These are addressed below. The intent of this technical bulletin is not to summarize all the requirements for agricultural processing facilities, which are distributed throughout Chapter 11B, but to clarify several issues that arise repeatedly, and to achieve consistency in the plan check and inspection of new agricultural processing facilities and remodels or additions to existing facilities.

Definitions

Agricultural Processing – The act of changing an agricultural product from its natural state to a different form, as grapes to wine, apples to juice or sauce, etc.

Facility – A building, structure, room, site, complex or any other portion thereof that is built, altered, improved or developed to serve a particular purpose. Facilities include all or any portion of buildings, structures, site development, complexes, equipment, roads, walks, sidewalks, passageways, parking lots and other property.

Central facility – The areas used by the public for tasting, sales, tours, dining, events, picnic areas, walks, gardens, sculpture viewing areas or other similar uses. The central facility also includes production and storage areas within 100 feet of the areas used by the public as described above, and offices and sanitary facilities serving any of the above areas.

Remote facility – Any area of the agricultural processing facility not used by the public for tasting, sales, tours, dining, events or other uses, and more than 100 feet from any portion of the central facility, measured in a straight line between nearest points of the buildings or structures.

Small agricultural production facility – A agricultural production facility which has a Group R, Division 3 occupancy (single family dwelling), has no tasting room, no on site sales, no events, no permanent employees, and which has a maximum area for production and/or storage of 3000 sq. ft. and limited to the following maximum annual production:

  • Wineries – less than 5000 cases per year.
  • Cheese Production – all production, aging and storage with the 3000 sq. ft. area
  • Olive Oil – all production, bottling and storage with the 3000 sq. ft. area

Production and storage areas – Includes areas where agricultural products are processed and/or stored, including wine caves, barrel storage areas, bottling areas, crush pads and cheese aging rooms. Dairy milking barns are not considered production area.

Technical Details

Accessibility requirements for new agricultural processing facilities and new buildings at existing facilities – Agricultural processing facilities often consists of several types of buildings distributed over a large site. It is best viewed as consisting of several facilities, as defined above, for the purpose of accessible route. For new facilities, and for new buildings at existing facilities, accessible features shall be required as follows:

  1. Tool sheds, feed storage barns, pump stations, dairy loafing barns, machinery platforms and rooms, tanks and tank pads, and other similar buildings or portions of buildings are considered machinery rooms. The exception to CBC Section 11B-203.5 referenced above for machinery rooms applies, and such rooms are not required to be accessible. This exception does not apply to buildings or portions of buildings used for vehicle storage and/or repair.
  2. An accessible route shall connect all elements and spaces within any building, subject to the exceptions in item 1 above and the work station requirements in item 6 below.
  3. Except for those buildings specified in item 1 above, an accessible route shall connect all buildings in the area of the central facility.
  4. Except for those buildings specified in item 1 above, an accessible route shall connect all buildings in the area of the central facility with the public way and with public transportation facilities adjacent to the central facility. When there are no public transportation facilities or public way sidewalks adjacent to the central facility, this requirement does not apply.
  5. The exception above for machinery rooms and similar areas does not apply to production and storage areas. The accessible path of travel within the building or cave must include a path to these areas.
  6. Employee work areas shall be designed and constructed so that individuals with disabilities can approach, enter and exit the work area (11B-203.9)
  7. Ladders, catwalks, and tanks are not required to be accessible unless the catwalks form part of the egress system for other parts of the facility (such as an office or break room) or are used by the public for any purpose.
  8. Except for those buildings specified in item 1 above, an accessible route shall connect all buildings or structures in the remote facility with the buildings or structures in the central facility, OR it shall be possible to drive to a designated accessible parking space with an accessible path of travel to the accessible entrance to such buildings in the remote facility. Other entrances shall be accessible as required by the code.
  9. All new bathrooms shall be accessible. Buildings specified in item number 1 above may be constructed without a bathroom, and bathrooms in existing buildings are not required to be modified when buildings specified in item number 1 above are constructed. However, the plumbing code requires that all other buildings shall be provided with sanitary facilities, and that separate facilities for each sex must be provided when the number of occupants exceeds 10. The occupant load for this purpose shall be calculated using the tables in Chapter 4 of the California Plumbing Code.

Accessible routes for existing agricultural production facilities – For additions or remodels at existing facilities, CBC Section 11B-202.4 applies.

  1. The above requirements apply to the area of alteration, the parking for and path of travel to the new construction, and sanitary facilities, pay phones, signs, and drinking fountains serving the area of alteration.
  2. Hardship exception – Hardship exceptions allowed by CBC Section 11B-202.4 #8 are based on the “. . . adjusted cost of alterations, structural repairs, or additions . . .” The question often arises as to what work is included in this cost. “Alteration” is defined for this purpose by the California Division of the State Architect (DSA) in Section 202 of the CBC. It is a very inclusive definition which includes the cost of any work to the building or structure, or change in primary function or use of the structure, but does not include the cost of equipment, furniture, or movable partitions, or accessible features.

Small Agricultural Production conversions – PRMD receives numerous building permit applications to convert a garage, barn, or other structure to a small agricultural production facility, as defined above.

  1. Such conversions are not considered a change of occupancy for the purpose of determining accessibility requirements, and accessible parking, path of travel, and sanitary facilities are not required. The structure shall continue to be classified at the occupancy before conversion. However, any work done where accessibility requirements apply must comply with present code. Conversions of such structures to agricultural production which are NOT an agricultural production facility are considered a change to a more hazardous occupancy and must meet the accessibility requirements for new construction. Note that if a small agricultural production facility makes changes so that it no longer meets the definition of small agricultural production, it is considered a change to a more hazardous occupancy and must comply with all accessibility provisions of the present code.
  2. Such conversions are not considered a change of occupancy for the purpose of determining whether they must meet the structural and life safety provisions of the current code. However, any work done must comply with the present code. Conversions of such structures which are NOT a small agricultural production are considered a change to a more hazardous occupancy and must meet all the requirements of the presently adopted code for a new winery. Note that if a small agricultural production facility makes changes so that it no longer meets the definition, it is considered a change to a more hazardous occupancy and must comply with all structural and life safety provisions of the present code. (See Section 3408.4 of the CBC for details regarding the seismic provisions.)

Other requirements

  • Tasting rooms – Occupancy Classification – Wine tasting rooms in which the only function of the space is display and sale of merchandise to the public shall be classified as Mercantile Group M occupancy, per CBC Section 309. Small samples of goods for sale may be provided to the public in Group M occupancy. When the tasting room is intended for food or drink consumption, recreation, or social gatherings the tasting room shall be classified as Assembly Group A-2 occupancy, per CBC Section 303. Smaller assembly type wine tasting rooms accessory to another occupancy with an occupant load of less than 50 or an area of less than 750 square feet may be classified as a Group B occupancy or as part of that occupancy, per CBC 303.1.2.
  • Employee areas – The requirements of for the items above for fixed or built in benches, dining surfaces, and counters apply to employee common rooms and break rooms.

References

2013 California Building Code, Chapter 11B