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Technical Memorandum TM 2013-21 Employee Work Areas

Technical Memorandum, 2012 TAS, Texas Department of Licensing and Regulation Architectural Barriers

TM 2013-21

Employee Work Areas

Effective Date: October 3, 2013

2012 TAS Reference: 203.9 and 206.2.8 

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.

Common Use Circulation Paths

In addition to the approach, enter, and exit requirements of TAS 203.9, employee work areas must also comply with the circulation path requirements of TAS 206.2.8.

Based on TAS 206.2.8, common use circulation paths located within employee work areas must comply with the accessible route requirements of TAS 402 unless the circulation paths meet one of the Exceptions in TAS 206.2.8. The term “circulation path” is defined in TAS 106.5.19.

This means that walks, hallways, and other exterior and interior pedestrian routes connecting other work areas, spaces, and elements within employee work areas must now be accessible unless exempted. There are, however, Exceptions for walking surfaces and ramps in TAS 403.5, 405.5, or 405.8.

Dumpster Enclosures

Dumpster enclosures used exclusively by employees shall be considered employee work areas based on TAS 201.1; therefore, they must comply with TAS 203.9. The common use circulation path to the dumpster enclosure, however, shall not be required to comply with TAS 402 if the employee work area is fully exposed to the weather based on TAS 206.2.8, Exception 3.

Automotive Work Pits

An accessible route shall not be required to automotive work pits used exclusively by employees if the building or facility meets one of the Exceptions in TAS 206.2.3 based on TAS 201.1(i)(v).


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