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2013 California Standards for Accessible Design Pocket Guide

c)         Changes.  As stated above, the Building Code is republished every three years.  In the interim, errata and/or supplements are issued at least once per year.  In other words, change is constant.  Since many building projects require more than one year to complete, it is not unusual for the pertinent Building Code requirements to change during construction.  In some cases, the permitting process can also require multiple years.  The requirements applicable to a specific project are those that were in effect when the permit application was made (except for errata, which can be applicable retroactively), but it can be extremely difficult to identify those after completion.  If a Drawing Cover Sheet lists 2013 California Building Code as one of the Applicable Codes, one still must ask, "Which version?".  This Pocket Guide is based on the initial publication of 2013 CBC, with Errata issued retroactive to January 1, 2014, and the Supplement dated July 1, 2015.

The ADA undergoes significant formal changes infrequently.  The Americans with Disabilities Act Accessibility Guidelines (ADAAG) issued in 1991 were supplemented in 1994, but were not rewritten by the U.S. Access Board until 2004.  The U.S. Department of Transportation (DOT) adopted by reference the revised ADAAG as regulatory standards effective November 29, 2006, and added or modified four sections. These sections are included in this Pocket Guide within ETA Editor’s Notes.  DOJ adopted the revised ADAAG on September 15, 2010 -- see also the discussion of Safe Harbors.  Evan Terry Associates has developed a detailed (line-by-line) reverse sortable analysis to show how the 2010 ADA Standards compare to the 1991 ADA Standards. It is available at http://www.adastandardscomparison.com/ as a free download for all interested parties, in MS Excel spreadsheet format. The Access Board has less detailed comparisons of its 2004 Guidelines with the 2010 ADA Standards and with the IBC 2003 and 2006 Standards and the NFPA 5000 Standard at http://www.Access-Board.gov/Guidelines-and-Standards/Buildings-and-Sites/About-the-ADA-Standards/Background/IBC-Comparison.  It bears mentioning that the application and interpretations of the ADA are also affected by technical assistance, advisories and opinions issued by DOJ, DOT, and the Access Board, as well as precedent-setting legal cases.  See also the list of upcoming revisions to the ADA Standards at the end of this Introduction.

These implications of the fundamental difference between a Building Code and a Civil Rights Law are enumerated to emphasize that an element of the built environment that is subject to accessibility requirements must comply with both.  If a Building Official or other AHJ does not enforce a particular accessibility requirement of the Building Code, or enforces it to a lesser degree than required by the ADA, the ADA requirement remains in effect, and must be met, despite the fact that no one is reviewing or approving the condition for ADA compliance.  ETA has incorporated Editor's Notes at certain locations in this Pocket Guide to reemphasize this point, including the Special Conditions Appeals, Equivalent Facilitation and Path of Travel Requirements.

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