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Minnesota Department of Labor and Industry

Opinion: Group S occupancy




Group S Occupancy

Code Reference:

2006 IBC Section 1104.4, Exception 2

Submitted by:


Prepared by:

Curt Wiehle, Building Code Representative

Approved by:

Thomas Anderson, State Building Official

Issue Date:

August 22, 2007 


Does 1104.4, Exception 2 apply to all Group S occupancies? 


A discussion with ICC has resulted in a different interpretation and application of the 2006 IBC Section 1104.4, Exception 2 than was previously understood and presented at several Accessibility Code seminars. The prior interpretation expressed at the code seminars was that Exception 2 gave a general exception for the provision of an accessible route to mezzanines and stories in all Group S occupancies. According to ICC, the intent of Exception 2 is that it only applies to the spaces and areas in the referenced Sections 1107 and 1108. The only area of a Group S occupancy addressed in Section 1108 is self-service storage facilities. Therefore, Section 1104.4, Exception 2 only applies to self-service storage facilities and no other type of Group S occupancy. Other uses within the Group S classification are subject to Section 1104.4, Exception 1, as amended at Minnesota Rules, 1341.0011 Subp. 4 A.

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