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Minnesota Department of Labor and Industry

Opinion: Multi-tenant group M mezzanine area




Multi-tenant group M mezzanine area


1996 MSBC 1340.1105 Subpart 3

Submitted by:

Building Codes and Standards Division

Approved by:

Thomas R. Joachim, State Building Official

Issue date: 

March 27, 1997


Does the requirement of UBC section 1103.2.2 to provide an accessible route to multi-tenant group M retail occupancies apply to a mezzanine area within an individual tenant space when the tenant is located in a multi-tenant building? 


We believe the intent of the UBC in this section is to assure that the public has access to all retail areas within the multi-tenant occupancy. If the mezzanine area is a M occupancy, UBC section 1103.2.2 would require that the mezzanine(s) be located on an accessible route regardless of the size of the mezzanine(s). If, however, the mezzanine area can legitimately be classified as any other occupancy than those specific occupancies included in the exception to 1103.2.2, the requirement to provide an accessible route would be dependant upon the aggregate square foot and aggregate occupant load of the mezzanine(s) located within the individual tenant space. 

Division comments:

If the mezzanine is used as a retail sales area (group M occupancy), an accessible route to the mezzanine is required. If the mezzanine meets the requirements for a storage area, and it is less than 3,000 square feet with an occupant load of less than 50, an accessible route would not be required. The aggregate requirements for the mezzanine area(s) would be determined within the individual tenant space and would not be based on the entire group M facility. If multiple tenants have mezzanines which are interconnected, the requirement for an accessible route would be determined by the aggregate area and occupant load of the interconnected mezzanines.

Approved by Building Codes and Standards Access Committee March 7, 1997.

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