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DSA IR 11B-9: Accessibility Requirements for Solar Photovoltaic Systems at School Sites

Note: This document or portion of document references a state or local requirement that is NOT required by the 2010 ADA Standards.

3. Roof Mounted PV Systems

  1. Roof mounted PV systems qualify for the machinery space exception; there are no accessibility requirements for the area of work on the roof.2

  2. Roof mounted PV systems are not considered alteration projects that would trigger path of travel accessibility work elsewhere in the facility.3 4

  3. To qualify for the machinery space and path of travel exceptions, access to rooftop areas with PV systems must be by ladders or narrow passageways5 or otherwise restricted to operations and maintenance personnel.6

  4. The BOS equipment, which may be located away from the rooftop equipment, also qualifies for the machinery space and path of travel exceptions, see 1.1 above. 

2 2013 California Building Code §11B-203.5 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, . . . mechanical, electrical or communications equipment rooms; . . .”

3 Op. cit. p. 2. 2013 California Building Code §11B-202.4 Path of travel requirements in alterations, additions and structural repairs. Exceptions: 7.

4 2013 California Building Code §202 definition of Alterations provides that “. . . changes to mechanical and electrical systems are not alterations unless they affect the usability of the building or facility.”

5 2013 California Building Code §11B-203.4 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.”

6 Op. cit. p. 2. 2013 California Building Code §11B-203.5 Machinery spaces.  

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