Are the parking provisions of OSSC 1104 retroactive?
No. You must still comply with Federal ADA requirements. These requirements were retroactive in OSSC till October 1, 1996 as can be seen from the language in Section 3101(e) of the 1993 OSSC which, states “Except as required in Section 3104 for accessible parking, this code is not retroactive…”. When the 1996 OSSC was adopted effective October 1, 1996, the retroactive code requirement for accessible parking were dropped from the OSSC.
