How does the new 2016 CBC affect my CASp Report or drawings?

I absolutely love this time of year as the weather begins to cool and change is in the air!

And speaking of changes, did you know that California is introducing the new 2016 California Building Code in January?

The 2016 California Building Code becomes enforceable January 1, 2017.

While local City and County building departments are gearing up, here at ADA Compliance Consultants, our collective heads are neck-deep in the new codes as we update our inspection forms and our design department’s standard details and formats.

This new 2016 CBC is effectively a “code cycle” change which means all permitted T.I’s, alterations or new construction starting next January will be reviewed and inspected based on this new code and not the 2013 CBC we are currently working from.

There are several very important things happening here, and as I have been explaining to multiple clients over the last few months, many of the same questions came up over and over.

Here are a few common questions:

  • What does this mean for those of us that had CASp inspection reports done within the last 3 years and we have completed some of the barrier removal items spelled out in the report?
  • What if my inspection report was completed over 3 years ago and we haven’t completed any of the barrier removal items spelled out in the report?
  • When should I update my report or re-inspect my property?
  • How does this affect my “on-going” barrier removal plan that I started 5 years ago?
  • Can the city or county force me to tear out work that was done 2 years ago now that the codes are changing?

First, let me just say that any time you complete any barrier removal projects spelled out in your report, a Post-Construction Inspection needs to happen so that we can update your CASp report and keep it current and valid!

ANSWERS:

  • If your CASp inspection report was completed from January 1st of 2014 to present and some work has been done but not all, then the work that was completed needs to be inspected to confirm it was done correctly and meets the current building code standards. If everything checks out, then the compliant work completed during the current building code cycle will not be required to be modified even if the next code cycle changes these requirements. In other words, if you just modified your disabled parking stall areas, corrected the surface slope, striping, and signage and the new code requires a different stall length, width or loading zone layout, you will not be required to change this work until the next code cycle in 2019. There have to be two code cycles in order for the change to be required.
  • If your report was completed in December 2013 (or before) then you are about to have the “2 code cycle” change happen to you. This means that your report is outdated and in need of an update or a new CASp inspection needs to be done. If your report falls into this category, then there are only a few scenarios here.
  1. No work has been completed since the time of the inspection and report being produced. (In this case, a new inspection is required)
  2. Some work has been completed but none of it was inspected and received final approval and sign off. (In this case, a new inspection is required)
  3. Some work has been completed and all of it was inspected and received final approval and sign off. (In this case, the work completed and approved should be ok and the items not completed yet need re-inspection)
  • A CASp inspection report should be updated every time work is completed that is spelled out in the report. Whether it be “voluntary barrier removal” through your own phased program or an isolated barrier removal required by the building department during a permitted project to satisfy the 20% additional clause … or every 6 years!
  • Your on-going barrier removal plan created 5 years ago is a moving and breathing plan. Things change, tenants move out/in and codes change. So should your multi-year phase plan. We help our clients keep these plans updated, current and valid at all times. If your construction documents are a year old or more, they need to be updated prior to your next project permit submittal.
  • Can the City force you to tear out work done 2 years ago just because the codes are changing? Maybe! If the work completed was inspected and signed off and shown to meet the current code, then “NO” they shouldn’t. The CBC states that just because one code cycle change happens if the work completed meets the standards of the previous code then it can remain. But once a second code cycle change takes place and if the requirements have changed, then these areas will be required to be modified during the next permitted project.

With so many changes happening so quickly, it’s easy to lose track of where your inspection reports stand, what has been done and whether it was done correctly. Take this time leading into the holidays and pull out your reports and construction documents. How old are they?

Now is the perfect time to get them current and ready for the new 2016 California Building Code cycle.

If you have any questions regarding this post or if I can help you navigate the world of ADA compliance, please give me a call.  — Chris Taylor

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