Accessible Route vs. Path of Travel: What’s the Difference?

When we inspect a facility, we have to look at these two terms through very different lenses:

1. The Accessible Route (The Physical Path)

An accessible route is the actual, physical pathway that connects accessible spaces. According to both 2025 CBC 11B-402.2 and 2010 ADA 402.2, this route can only consist of walking surfaces, doorways, ramps, curb ramps, elevators, and platform lifts.

Notice what's missing? Stairs. Stairs are never classified as an accessible route component because they don't provide an unbroken, continuous path for someone using a mobility device.

2. The Path of Travel (The Alteration Trigger)

"Path of travel" is a scoping term that kicks in when you are remodeling an existing building. Under CBC 11B-202.4 and ADA 36.403, if you alter an area containing a "primary function" (like a retail sales floor or a restaurant dining area), you are legally required to upgrade the path of travel leading to that altered area.

This means you don't just fix the room you're remodeling. You must also ensure the route from the parking lot or sidewalk to that room is accessible. Furthermore, the "path of travel" legally includes the restrooms, drinking fountains, and public telephones serving that altered area.

The Multi-Story Alteration Trap

This is where California code really diverges from federal law during a remodel.

If you are altering a primary function area on a second floor or a mezzanine, you have to upgrade the path of travel to that area. The ADA has a "multi-story elevator exception" (Section 206.2.3) that lets certain small private buildings—those under three stories or with less than 3,000 square feet per floor—skip the elevator or ramp requirement. If this federal exception applied, you wouldn't have to build a ramp or elevator to that second floor just because you remodeled it.

But here is the catch: California doesn't care about that federal exception.

The 2025 CBC specifically omits that broad ADA exception for commercial facilities (CBC 11B-206.2.3). Because the CBC governs local building enforcement, your path of travel upgrade must include an accessible route (via a ramp or elevator) between floors, even if the ADA would legally let you off the hook. The only way out of this in California is if the cost of the path of travel upgrades exceeds 20% of your total project cost (known as disproportionality), but you still have to spend that 20% making the path as accessible as possible.

Quick Reference: CA Code vs. ADA During Alterations

What We're Looking At	2025 CBC 11B Says...	2010 ADA Says...	What You Actually Do in CA
Accessible Route Components	Ramps, lifts, elevators; NO STAIRS	Ramps, lifts, elevators; NO STAIRS	You cannot use stairs to connect accessible spaces .
Path of Travel Trigger	Kicks in during alterations to primary function areas	Kicks in during alterations to primary function areas	Upgrade the route, restrooms, and fountains serving the area .
When a Ramp is Required	Over ½ inch change in level	Over ½ inch change in level	Build a ramp!
Small Building Elevator Exception	Strictly limited	Broadly allowed	Follow the stricter CBC and provide a ramp or elevator .

The Bottom Line: An accessible route is the physical ramp or walkway, while the path of travel is the legal requirement to upgrade that route when you remodel. If your path of travel goes up more than ½ inch, you need a ramp, elevator, or lift. Period. Don't rely on stairs, and if you're building in California, don't rely on federal ADA exceptions that the state has thrown out.

DISCLAIMER: The information provided in this post is for informational purposes only and does not constitute legal advice. Please consult a qualified attorney or consultant for advice tailored to your situation.