Upon reading the new Sentence 3.8.2.5.(2) amended by decree 1419-2021, and a commentary from the Régie du bâtiment du Québec (RBQ) about this article in the Guide sur l’accessibilité des bâtiments (available in French only), we’ve questioned ourselves regarding barrier-free parking spaces and the barrier-free traffic zone for vehicles. Are barrier-free parking spaces now required on each storey of an interior storage garage?
Figure 1 – Page 40 of the Guide sur l’accessibilité des bâtiments (available in French only, free translation provided here)
In the RBQ commentary, the verb “may” (peuvent in French) is very important because the text does not say that the parking spaces “shall” be uniformly distributed between the levels.
If this were mandatory, this would imply providing barrier-free parking spaces on all garage levels, with these spaces requiring a clear height of not less than 2300 mm at the pull-up space and along the vehicle access and egress routes. As such, this would have a major impact in the design of basement storage garages, for a deeper excavation would now be required.
Hence, it is important to correctly distinguish between the barrier-free path of travel for persons with physical disabilities who need to use a passenger elevator, as required by Sentence 3.8.2.5.(2), and the barrier-free parking spaces for vehicles, which must be designed in conformance with the requirements of Sentence 3.8.3.4.(2), the number of which must be determined according to Sentence 3.8.2.5.(4).
Figure 2 – An explanation of the application of Sentences 3.8.2.5.(2) and (4) ¬– Parking areas
Where a passenger elevator serves a building, the objective of Sentence 3.8.2.4.(2) is to ensure that the passenger elevator provides a barrier-free path of travel allowing access to at least one level of each storage garage storey.
As such, when the passenger elevator provides access to the interior parking floors, a person with physical disabilities must be able to access these floor areas without encountering steps.
In some storage garage projects, the possibility to group all barrier-free parking spaces on a single level sometimes led designers to conclude that the other storeys were exempted from providing a barrier-free path of travel.
Persons with physical disabilities who are using a cane, or a walker do not always have a disabled parking permit to allow them to park in the barrier-free designated spaces. There is also the case where these people may be sporadic passengers inside a vehicle.
A vehicle having a person with physical disabilities inside might thus be parked on a different storey than the one having the barrier-free parking spaces. It can therefore be difficult for this person to reach the passenger elevator, sometimes because of the steepness of the vehicular ramps’ slopes or the elevator landing doors stopping levels. The person must then use steps or a ramp with a slope steeper than 1 in 20, in order to reach the elevator.
It must now be ensured that at least one level of each interior storage garage’s storey can be accessed through ramps that are in compliant with Article 3.8.3.5. or floors no steeper than 1 in 20.
However, it is not required to have barrier-free parking spaces on every parking level. They can be grouped on a single level.
The objective of the new Sentence 3.8.2.4.(2) is to ensure that at least one level of each of the storage garage levels is accessible to a person having a physical disability.
Also, remember that when you locate 1% of the parking spaces required by Sentence 3.8.2.5.(4) on a single storage garage level, the number of spaces must be calculated separately for each type of parking. For example, if your project includes both an interior and an exterior parking, the required number of barrier-free parking spaces for each type must be calculated separately.
As such, for any interior storage garage having more than 25 parking spaces, the interior garage entrance doors should always indicate a clear height of 2300 mm so that they meet the requirements of Clause 3.8.3.4.(2)(c). In addition, make sure to include the vehicles stopping areas at the parking entrance and exit gates, and along the entire path of travel of the vehicles. Also, don’t forget to provide appropriate signage if the rest of the parking complies with the minimum clear height required by Sentence 3.3.5.4.(5).
