CPDC Architecture & Engineering

Determining Work Exempt from DSA Access Review

CSU can approve some work for access compliance, but there are strict limitations on this and the Campus Deputy Building Official (CDBO) must sign off on each such acceptance as a part of the Approval to Proceed to Bid (i.e., CSU Building Permit) form.

Typical exemption may include:

  • Maintenance Work: Normal maintenance, re-roofing, painting or wallpapering, asbestos removal or changes to mechanical and electrical systems unless they affect the accessibility of the facility are exempt. Work that includes placement of switches, controls and outlets require a need for access review.

  • Non-public Areas: Projects that have no reasonable availability to or usage by persons with disabilities are exempt. Such projects might include mechanical systems installations and upgrades, roof-top solar arrays in non-public areas, utility tunnels, etc.

  • Infrastructure Project: Civil infrastructure construction activities that include the replacement of street sections, curbs, walkways, etc., building infrastructure projects that revise publicly accessible switches and controls, and fire alarm upgrades that include signaling devices, all require an access review.

  • Faculty/Staff Housing: The determination of exemption for faculty/staff projects is complex and project specific. These projects depending on the particulars of the dwelling unit configuration, may be access review exempt, but street improvements to individual units generally will have access requirements.

  • Cost Threshold: The $25,000 cost threshold exemption for access compliance review is a Field Act exemption and does not apply to CSU projects. The 'unreasonable hardship' or '20% rule' is a scoping determination that DSA makes. It does not sidestep the need for DSA review. Also the 20% consideration for existing facilities does not apply to new construction.

The CDBO is the front-line campus resource to evaluate a projects need for review.