Does chapter 11b apply to medical office buildings certified access specialist institute

This throws some readers into a false notion that the entire section 11B-223 is all about ‘licensed’ facilities ‘where the period of stay exceeds 24 hours’. They frequently argue that a medical office building is not a ‘licensed’ facility, and they do not have periods of stay that exceed 24 hours… therefore, this whole section doesn’t apply to medical office buildings. That is not true. It simply happens to be the first subsection. In reality, Section 11B-223 covers ‘medical care and long-term care facilities’, whether the period of stay is over or under 24 hours. As we see in the subsections of 11B-223, it covers:

An important, but somewhat obvious point needs to be made here: Yes, when we talk about ‘medical office buildings’ they are essentially the same thing as the ‘professional offices of healthcare providers’.


Technically, they aren’t exactly the same thing, but when discussing the implications, we end up with the same result. For the sake of accuracy, a medical office building is just a building, and as such, it could be viewed as a generic, non-medical office building. Once a tenant is defined as a ‘medical provider’, then section 11B-223.4 is applicable. For the purposes of this discussion, it is understood that when we talk about ‘medical office buildings’, we are talking about the specific tenant space of a medical provider. Medical Care Facilities

To me, the ultimate ‘proof’ is simply in the non-technical understanding of the term ‘professional office of healthcare provider’. Is the office space intended for people to go seek medical advice or treatment? Do we fully expect that doctors and nurses will be practicing there? Are the people that deliver this advice and/or treatment somehow licensed or certified to practice in the State of California?

DSA effectively lifted the 2010 Section 1109B.3.2.4 as it has existed for a long, long time, and re-inserted it in the 2013 CBC at the most logical place that there is in scoping… Section 223, and created a sub-number 4 (which does not exist in the ADA version of 223). Especially note that the ‘pointer’ to the ‘OSHPD’ section (previously 1109B, now 11B-805) has always been there.

• DSA now uses the term ‘professional offices of healthcare providers’. In what I assume was a DSA effort to standardize the code language, DSA changed the term from ‘professional medical and dental offices’ to ‘professional offices of healthcare providers’. I believe this to be an effort to align with the elevator exception language of 11B-206.2.3 Exception 1.1 which speaks to the issue of not needing an elevator in specific multi-story office buildings…except when it is the “professional office of a healthcare provider”. I believe this change to be inconsequential.

• OSHPD Proposed Big Changes for the 2013 CBC. While DSA made every effort to remain access-neutral in the re-formatting efforts of the 2013 CBC, OSHPD cut across the grain, and proposed some substantial changes in what had previously been an ‘I” occupancy section of code (1109B). The changes were not access-neutral, and in my opinion expand the accessibility requirements in an unprecedented way.

As most of you know, under California law, DSA has the responsibility to develop access language for non-residential uses. Therefore, the OSHPD proposal had to be worked into the DSA framework for the newly formatted 2013 CBC. DSA choose to accept the OSHPD proposal despite its non-neutral expansions, and placed the new language quite logically in 11B-805.

For well over a year now, I have participated in countless discussions regarding this topic. Each time that an architect, building official, or building owner encounter these requirements for the first time, there is a massive “OMG! This can’t possibly be!” These discussions often include nearly-desperate questioning of the code language and intent. Unfortunately, as much as I would like to come to a different conclusion…this is our new reality. 11B-805 does indeed apply to the ‘professional offices of healthcare providers’. Not just in my opinion, but also in the opinion of both DSA and OSHPD.