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Minnesota Department of Labor and Industry

Opinion: Accessibility to work spaces




Accessibility to work spaces


1994 UBC Sections 1103.2.2

Submitted By:

Building Codes and Standards Division

Approved By:

Thomas R. Joachim, State Building Official

Issue Date: 

October 14, 1996 


When 1103.2.2 states "...an accessible route shall be provided to all portions of the building..." does this mean the accessible route must pass through all employee work areas such as office cubicles, factory work stations, commercial kitchens etc.? 


We believe the intent of the UBC in this matter can be determined from section 4.1.1 (3) of the ADA Accessibility Guidelines where it states,

Areas that are used only as work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas. These guidelines do not require that any areas used only as work areas be constructed to permit maneuvering within the work area or be constructed or equipped to be accessible.

Although the application of the accessible route provision of 1103.2.2 to work areas will have to be reviewed on a case by case basis, we believe that the accessible route must access all portions of the building but generally not through employee work areas.

Approved by Building Codes and Standards Access Committee September 26, 1996.

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