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Hello,

For this months newsletter I will be discussing Employee Work Areas.  I have found that this is an area that is often misunderstood.  It is important to use the context below in its entirety.
TAS/ADA Requirements for Employee Work Areas
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It is important to first understand what qualifies as an Employee Work Area.  The 2012 Texas Accessibility Standards defines the term in 106.5.28.
106.5.28 Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.
So if an area or space is to be occupied, or used, by someone other than an employee, it is not an employee work area.  And if the space is used for things other than work, even if only by employees, it is not an employee work area.  

Now that we know what an Employee Work Area is, lets look at the scoping requirements in Chapter 2 to see what standards apply to them. 
203.9 Employee Work Areas. Spaces and elements within employee work areas shall only be required to comply with 206.2.8, 207.1, and 215.3 and shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area. Employee work areas, or portions of employee work areas, other than raised courtroom stations, that are less than 300 square feet (28 m2) and elevated 7 inches (180 mm) or more above the finish floor or ground where the elevation is essential to the function of the space shall not be required to comply with these requirements or to be on an accessible route.
When reading the scoping below found in 206.2.8, keep in mind that 402 is about Accessible Routes.  If a bathroom, break room, or some other accessible space, is located on a circulation path that passes through an employee work area, an accessible route and doorway clearances would still be required along that circulation path.

206.2.8 Employee Work Areas. Common use circulation paths within employee work areas shall comply with 402.

EXCEPTIONS: 

1. Common use circulation paths located within employee work areas that are less than 1000 square feet (93 m²) and defined by permanently installed partitions, counters, casework, or furnishings shall not be required to comply with 402.
2. Common use circulation paths located within employee work areas that are an integral component of work area equipment shall not be required to comply with 402.
3. Common use circulation paths located within exterior employee work areas that are fully exposed to the weather shall not be required to comply with 402.

207.1 General. Means of egress shall comply with section 1003.2.13 of the International Building Code (2000 edition and 2001 Supplement) or section 1007 of the International Building Code (2003 edition) (incorporated by reference, see "Referenced Standards" in Chapter 1).

EXCEPTIONS: 
1. Where means of egress are permitted by local building or life safety codes to share a common path of egress travel, accessible means of egress shall be permitted to share a common path of egress travel.
2. Areas of refuge shall not be required in detention and correctional facilities.

215.3 Employee Work Areas. Where employee work areas have audible alarm coverage, the wiring system shall be designed so that visible alarms complying with 702 can be integrated into the alarm system.
To further clarify questions regarding Employee Work Areas, TDLR released Technical Memorandum 2013-21.  It helps define the phrase "Approach, Enter, and Exit".  It was not clear in the past if a turning space was required to "Exit" the space.  We now know that it is only required to be able to enter and back out of the space.  A portion of the technical memorandum appears below.  Click the link for the full text.
Approach, Enter, and Exit

Employee work areas are required by TAS 203.9 to be designed and constructed so that individuals with disabilities can approach, enter, and exit the work area. Based on documentation and information provided by the U.S. Access Board, “approach, enter, and exit” means that people using wheelchairs must be able to enter and back out of the space. This applies to all employee work areas except employee works areas that meet the elevation, size, and function requirements identified in TAS 203.9. Employee work area doors, doorways, and gates, therefore, must comply with TAS 404 except the maneuvering clearance is limited to the “enter” side unless required for egress by TAS 207.1.
If you made it to the end, you should now have a pretty comprehensive understanding of what an employee work area is, when an accessible route is required, and where doorway clearances apply.

I hope that you have found this informative. Should you have questions regarding Employee Work Areas, or another area of accessibility, please feel free to reach out to me. 

Justin Walton, RAS

Registered Accessibility Specialist - #00001329

ICC Accessibility Inspector/Plans Examiner - #8210557

Direct - (940) 368-1989


Justin.K.Walton@gmail.com

www.Texas-Accessibility.com

Copyright © 2015 Texas Accessibility Solutions, All rights reserved.



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