Accessibility Experts and Architects Consider 30 Years of the ADA

Monday, August 3rd, 2020

The following is an excerpt from Marcela Abadi Rhoads, owner of Abadi Accessibility is quoted in the article:

This month marks 30 years since President George H.W. Bush signed into law the Americans with Disabilities Act (ADA) on July 26, 1990. One of the most sweeping pieces of civil rights legislation in the country’s history, its guidelines and protections have changed the way we work, learn, and move through space. For architects and planners, it has meant a complete shift in thinking about accessibility and inclusive design. Now, on this landmark anniversary, experts weigh in on how far we have come and what a more equitable future might look like with the help of ADA.

Read the article in its entirety here.

Circulation Paths

Monday, February 3rd, 2020

There are a few of requirements in the 2010 ADA Standards that speak about  ways that people get around.  Some are described as either  “circulation path”,  “path of travel”,  “accessible route” or “vehicular path”.  Those all speak about either a car, wheelchair or pedestrian means of getting different places.  In my experience, there is a misunderstanding about the difference between “circulation path” and “path of travel” and “accessible route”.

Path of Travel and Accessible route are mainly describing the “unobstructed” path that a wheelchair user would take.

But a circulation path is speaking about a path where any pedestrian would use to get around.  As it pertains to Americans with disabilities, this term is used for persons who are visually impaired, but are still able to walk.

The idea is that a person who cannot see very well cannot detect certain hazards along the path that he will take to find his way around (i.e. the circulation path).  This newsletter will discuss this concept and will give examples of some “circulation paths”

Protruding Objects

When a person who is visually impaired is walking to find their way, that is a description of his or her “circulation path”.  Since they cannot see, we are required to make sure there are no hazards along their path.  Those hazards are any objects located along the circulation path that are mounted higher than 27″ a.f.f. or lower than 80″ a.f.f. and projects more than 4″ onto the path.

….because the bar is a protruding object

A protruding object, cannot be detected by a cane which is one of the ways that a person who is visually impaired finds their way. Here is a video by the US Access Board that explains this topic.

Circulation Path

What becomes confusing for people is the other terms in the standard.  What is a circulation path?  What is an accessible route?  What is a path of travel?  A circulation path is different than an accessible route.  An accessible route is solely for people in wheelchairs.  It must be a certain width and should be located so that people in wheelchairs can use it without much effort.

A circulation path, on the other hand,  can be used by anyone.  It describes the path that a person who can walk will be taking.  And that can really be anywhere that leads you from one place to another.  Below are some examples:

The obvious circulation path is a corridor.  That is what most people think of when they see the words “circulation path”.  Along a corridor, make sure the sconces are not mounted lower than 80″ a.f.f. if they are deeper than 4″.

A corridor is a circulation path.

A circulation path can be anywhere where people are walking.  So from one side of the bar shown below to the other side is a circulation path and the counter should not project more than 4″ onto it.

The bar top projects more than 4″ onto the circulation path between one side of the bar to the other.

The path to the restroom door is a circulation path.  The paper towel dispenser is mounted along that path and it is deeper than 4″, therefore it is a protruding object.

The paper towel dispenser in the restroom is located along the circulation path.

The circulation path to the desk has a display cabinet that projects more than 4″ onto it.

The display case is located in the circulation path to the desk.

The path to the restroom door is considered the circulation path. The drinking fountain is located on the circulation path of that door and it is a protruding object.

The drinking fountain projects more than 4″ onto the circulation path to the restroom door.

The drinking fountain in the photo below is also located along the circulation path too the restroom door.  It is partially recessed, but since the bottle filler is not the same depth as the drinking fountain it does not provide cane detection.

The drinking fountain is located along the circulation path to get to the door beyond.

The circulation path to the lavatory has a hand dryer projecting onto it.

The path to the lavatory is the circulation path.

Any place in a plaza where people walk is part of a circulation path.  The sculpture is located within the circulation path and the angled parts come down to less than 80″ a.f.f. and are considered protruding objects.

The planters were added at each angle as cane detection.

When discussing circulation paths, keep in mind that although an accessible route is a circulation path because that is where wheelchairs will go, a circulation path is not an accessible route.  A circulation path is where ANYONE can go.  There may be many more examples of circulation paths, so let’s keep them free from hazards and protruding objects.

Clear Widths Along an Accessible Route

Friday, January 3rd, 2020
As most of us know, the minimum clear widths along an accessible route that the ADA requires are 36″ minimum clear.  But there are times when are allowed to be narrower or required to be wider.  This newsletter will explain those instances.

Clear Width Reduction


In the 2010 ADA guidelines, section 403 gives us a figure to follow which explains that the 36″ wide clear width can be reduced to 32″ clear as long as the distance that you travel through the narrower width is no more than 24″ deep.
403.5.1 Clear Width. Except as provided in 403.5.2 and 403.5.3, the clear width of walking surfaces shall be 36 inches (915 mm) minimum.
EXCEPTION: The clear width shall be permitted to be reduced to 32 inches (815 mm) minimum for  a length of 24 inches (610 mm) maximum provided that reduced width segments are separated by  segments that are 48 inches (1220 mm) long minimum and 36 inches (915 mm) wide minimum.

But do both sides of the path need to be 24″ long the way it is shown in the figure above?  Could one side be a wall or even a longer cabinet or obstruction?  I was inspecting a restroom and found that condition.  There was a cased opening to enter the toilet compartment area.  One side of the cased opening was 8″ deep and the other side was the restroom wall which was longer than 24″.

This is the photo of the cased opening along the route to the sinks
This is the plan of the cased opening (where it says “Align”) which part of it is 8″ on one side and longer than 24″ on the other side. The opening was less than 36″ wide.
The guidelines allow this.  As long as one side of the path is no more than 24″ long and it goes back to 36″ wide, it will be an acceptable condition.

Clear width at the approach to a toilet compartment


A clear path to a toilet compartment (both wheelchair and ambulatory) should  also have a  36″ minimum clear width.  Except that at the approach to the door it must increase to 42″ in width
604.8.1.2 Doors. Toilet compartment doors, including door hardware, shall comply with 404 except that if the approach is to the latch side of the compartment door, clearance between the door side of the compartment and any obstruction shall be 42 inches (1065 mm) minimum

The standard is giving us requirements for the door clearance only.  The path to the toilet compartment is still required to have a 36″ minimum clear width.  But the space to open the toilet compartment door and the  maneuvering clearance (if the approach is on the latch side) must have a  42″ minimum clear width between the door and the obstruction

This photo shows the plan view of a path to the ambulatory toilet compartment.

In the plan view above you can see a furred out column in front of the toilet compartments.  That fur out is located within the door maneuvering clearance of the ambulatory toilet compartment and it reduces the 42″ required width to 36″

This figure above shows the door maneuvering clearance at the latch side approach.  A toilet compartment door will only require 42″ of clear width not 48″ like a standard door.

Passing space


Along an accessible route you are required to have 36″ clear width.  This width is required to be widened to 60″ every 200 feet.  This is to allow people in wheelchairs and pedestrians to pass each other.
403.5.3 Passing Spaces. An accessible route with a clear width less than 60 inches (1525 mm) shall provide passing spaces at intervals of 200 feet (61 m) maximum. Passing spaces shall be either: a space 60 inches (1525 mm) minimum by 60 inches (1525 mm) minimum; or, an intersection of two walking surfaces providing a T-shaped space complying with 304.3.2 where the base and arms of the T-shaped space extend 48 inches (1220 mm) minimum beyond the intersection
Here is a video from the Access Board that explains it

Clear width at turns


When a wheelchair makes a ninety degree turn, a 36″ minimum clear width is allowed.

But when a wheelchair is required to make a 180 degree turn, like in a narrow corridor, or maybe in a queue line or library stacks, then the width will have to increase from 36″ to 42″ depending on what size the element they are turning around is.

403.5.2 Clear Width at Turn. Where the accessible route makes a 180 degree turn around an  element which is less than 48 inches (1220 mm) wide, clear width shall be 42 inches (1065 mm)  minimum approaching the turn, 48 inches (1220 mm) minimum at the turn and 42 inches (1065 mm) minimum leaving the turn.
EXCEPTION: Where the clear width at the turn is 60 inches (1525 mm) minimum compliance with  403.5.2 shall not be required.
For instance if the space that they are turning around is 60″ in depth, then the clear width can be 36″ min.  If the space is 48″, then the clear width will have to increase to 42″
This video will give you some guidance on turning and wheelchair clearances


About the ADA and TAS. What you might not know?

Monday, December 2nd, 2019
After almost 20 years in my business I am still learning things about the ADA and TAS.  I want to share with you some things that might not be so apparent when you read the standards.

Location of Work Surface in a Residential Kitchen

When designing a residential kitchen that will be used by the public (e.g. a an assisted living resident room, a kitchen in an emergency personnel facility, an apartment for a resident hall director or RA etc.) the appliances that you choose will have to be compliant with the ADA and TAS.   One of the requirements is typically missed or overlooked.  It is the one pertaining to a work surface in a “residential kitchen”.
804.3 Kitchen Work Surface. In residential dwelling units required to comply with 809, at least one 30 inches (760 mm) wide minimum section of counter shall provide a kitchen work surface that complies with 804.3
804.6.5.1 Side-Hinged Door Ovens. Side-hinged door ovens shall have the work surface required by 804.3 positioned adjacent to the latch side of the oven door.
804.6.5.2 Bottom-Hinged Door Ovens. Bottom-hinged door ovens shall have the work surface required by 804.3 positioned adjacent to one side of the door.
Where a work surface is required and the kitchen has an oven, the work surface needs to be located adjacent the oven.


Keep in mind, this only applies to “residential” kitchens….not all kitchens.  So a break room or common use kitchen not located in a residential dwelling unit (as defined by the ADA) does not require a work surface.

Clearance vs. Clear Floor Space

There are two concepts that are sometimes thought to be interchangeable in the ADA and TAS:  “Clearance” and “Clear Floor Space”.  Section 305 lists the requirements for “Clear floor space” .  Clear floor space is required adjacent beds, under counters, lavatories, sinks, at operable parts for reaching, inside platform lifts, at drinking fountains, at toilet room fixtures, at washer and dryers, at saunas and steam rooms, at ATM, at signage, at work surfaces, at jury boxes and adjacent exercise equipment.

Some of the requirements are listed below from Section 305:

305.2 Floor or Ground Surfaces. Floor or ground surfaces of a clear floor or ground space shall comply with 302. Changes in level are not permitted.

EXCEPTION: Slopes not steeper than 1:48 shall be permitted.

305.3 Size. The clear floor or ground space shall be 30 inches (760 mm) minimum by 48 inches (1220 mm) minimum.


Any time that the words “clear floor space” is found in the Standards these are the requirements that must be followed.  Some of those instances will be at the clear floor space to reach objects, a clear floor space at wheelchair seating in assembly areas or clear floor space at toilet rooms.

A clear floor space is required at the push button. The clear floor space needs to have a slope no steeper than 1:48 . This clear floor space is steeper.


What sometimes gets conflated are the “clearance” at plumbing fixtures like toilets, showers and tubs. “Clear floor space” is defined, but “clearance” is not….except to describe its size and location.

608.2.2.1 Clearance [at roll in showers]. A 30 inch (760 mm) wide minimum by 60 inch (1525 mm) long minimum clearance shall be provided adjacent to the open face of the shower compartment.

The clearance is mentioned to let us know what size we need to provide and where it should be located…but it does not mention slope.

Unlike the clear floor space where a slope cannot exceed 1:48, a clearance at the shower for example is not defined.  So the clearance at the roll in shower can have a slope that exceeds 1:48
This roll in shower has a slope up to the shower pan which is acceptable (although may not be recommended)

Showers in Transient Lodging

Friday, November 1st, 2019

Showers are not all the same.  There are three types that are described in the ADA standards for showers: transfer showers, roll in showers and alternate roll in showers (which is like a hybrid between the transfer and the roll in shower). Their requirements also vary depending on where they are located.

Below are the requirements in showers, and specifically in a transient lodging facility.

Minimum number of roll in showers required

In the ADA Standards under 224 Transient Lodging there is a chart that we use to calculate how many rooms must be accessible.

Chart of minimum number of required ADA accessible showers per hotel guest room

There are requirements for rooms with mobility features (for persons with mobility disabilities) and there are requirements for how many rooms with communication features (rooms for persons that are either hearing impaired or visually impaired).  When designing rooms with mobility features one of the requirements is to provide a minimum number of rooms with roll in showers and without roll in showers.

If you notice the chart above, note that if you have less than fifty rooms in a transient lodging facility, then you MUST provide rooms WITHOUT a roll in shower.  So that would mean either a tub or a transfer shower must be provided in a certain number of rooms.  All your bathing facilities cannot be roll- in-showers.

The photos below show you two bathing facilities that are not roll-in-showers:

Transfer Shower

Tub with a fixed and folding seat

If you would like to also provide roll in showers for persons with disabilities you could, but you must first provide the rooms without the roll in showers as stated in the chart. Any additional rooms provided with mobility features beyond the amount on the chart can have a roll in shower.

Transfer shower

Fixed Shower Seats

There are also requirements for seats in showers.  In a typical installation that is not located in a transient lodging, the only shower that requires seats are the transfer showers.  If you provide a roll in shower or an alternate roll in shower, having a seat is optional.  If you do provide them then you must locate the shower controls close to the shower seat.

But in a transient lodging you MUST install a shower seat no matter what type of shower you are providing.

Part of the requirement is that the seat be fixed and either folding or non-folding, EXCEPT in a transient lodging room with a roll in shower.

608.4 Seats. A folding or non-folding seat shall be provided in transfer type shower compartments. A folding seat shall be provided in roll-in type showers required in transient lodging guest rooms with mobility features complying with 806.2. Seats shall comply with 610.

So what that means is that if you have a roll in shower that is not located in a transient lodging facility you can provide a seat that is fixed but not folding.

Safe Harbors in Restrooms

Wednesday, October 2nd, 2019

Safe Harbors in Restrooms

Safe Harbor is a provision that was adopted by the Department of Justice as well as the Texas Department of Licensing and Regulation where it allows an existing element that meets the original Standard to remain as it is even if it does not meet the new standards.  It can only remain a safe harbor as long as it is not touched.  Once it is remodeled, removed or relocated then it must comply with the new standards.
Our newsletter gives a couple of examples of safe harbor provisions in restrooms.

Toe clearance at toilet compartments

The 2010 ADA Standards for Accessible design (and the 2012 TAS) requires that a 9″ high toe clearance be provided on two sides of the toilet compartments so that a person in a wheelchair can maneuver inside the stall and be able to exit.
But the 1991 ADAAG (and the 1994 TAS) only required a toe clearance if the “stall” was less than 60″ deep.
4.17.4 Toe Clearances. In standard stalls, the front partition and at least one side partition shall provide a toe clearance of at least 9 in (230 mm) above the floor. If the depth of the stall is greater than 60 in (1525 mm), then the toe clearance is not required.
If you have a hard wall toilet compartment built prior to 2012 that is more than 60″ deep and 60″ wide, but no toe clearance, it is allowed to remain narrow.  It does not require the additional 6″ of width as the 2010 ADA does.
This toilet compartment is 60″ wide but because it is longer than 60″ it does not require toe clearance

“Alternate” Toilet Compartments

There was a term in the original ADA standards that is no longer used: “Alternate stall”.  This was what we now call an ambulatory compartment but it was allowed to be used instead of a standard wheelchair accessible compartment if there was not room and only in alterations.
4.17.3 EXCEPTION: In instances of alteration work where provision of a standard stall (Fig. 30(a)) is technically infeasible or where plumbing code requirements prevent combining existing stalls to provide space, either alternate stall (Fig. 30(b)) may be provided in lieu of the standard stall.

These are the “alternate” stalls allowed in alterations

The word “technically infeasible” is meant to imply that a variance would be required where a AHJ like The Texas Department of Licensing and Regulation is involved.  So in order to determine if the compartment is a “Safe Harbor” the variance that allowed it to be used would need to exist.

“Ambulatory” Toilet Compartments

In the 1991 ADAAG the “ambulatory” stall is described as a stall required when six or more stalls are provided.
4.22.4 Water Closets. If toilet stalls are provided, then at least one shall be a standard toilet stall complying with 4.17; where 6 or more stalls are provided, in addition to the stall complying with 4.17.3, at least one stall 36 in (915 mm) wide with an outward swinging, self closing door and parallel grab bars complying with Fig. 30(d) and 4.26 shall be provided. Water closets in such stalls shall comply with 4.16. If water closets are not in stalls, then at
least one shall comply with 4.16.
So only restrooms with toilet compartments are required to also provide “ambulatory stalls”.  So if a mens’ restroom has three urinals and three toilet compartments, that would not add up to six “stalls” therefore an ambulatory stall would not be required.

But in the 2010 ADA changed the wording to say:

213.3.1 Toilet Compartments. Where toilet compartments are provided, at least one toilet compartment shall comply with 604.8.1. In addition to the compartment required to comply with 604.8.1, at least one compartment shall comply with 604.8.2 where six or more toilet compartments are provided, or where the combination of urinals and water closets totals six or more fixtures.
So now, when a restroom has three urinals and three compartments, then one of the compartments would have to be an ambulatory compartment.

So an existing pre-2010 ADA restroom with three urinals and three compartments and no ambulatory stall, is a safe harbor and can remain this way until it is remodeled.


The ADA at 29 – Safe Harbors

Tuesday, July 2nd, 2019


Thanks to my friend Mike Griffin from Dallas Texas who suggested this great topic.  Hope you enjoy
July 26, 2019 will be 29 years since the ADA was passed into law.  Since its first publishing there was one revision that happened in 2010.  When it was revised there were certain changes from the original.  But they added a provision that stated that when doing a renovation, the original requirements are still valid for existing conditions.  In other words if the elements are existing and compliant with the previous version of the ADA Standards, they may remain as they are and they will be considered compliant.  This is called a “Safe Harbor”.  This newsletter will explain the concept of a safe harbor and when you can apply it.
Examples of a Safe Harbor
The ADA defines a safe harbor as:
(d) Relationship to Alterations Requirements of Subpart D 
(2) (i) Safe harbor. Elements that have not been altered in existing facilities on or after March 15, 2012, and that comply with the corresponding technical and scoping specifications for those elements in the 1991 Standards are not required to be modified in order to comply with the requirements set forth in the 2010 Standards…
Some examples of the things that changed that if left the way during a renovation will be considered compliant are:
Side approach reach
In the 1991 ADAAG, the unobstructed reach range to an operable part that is approached on the side was between 9″ to the lowest operable part to 54″ to the tallest operable part
old side

The 2010 ADA Standards raised the bottom reach to 15″ and lowered the top reach to 48″ a.f.f.

So in an existing restroom, for example, if the paper towel dispenser operable part (the part you operate to dispense the paper towels) was mounted at 54″ a.f.f. , it would still be counted as compliant today.  It would even be counted as compliant when you remodel said restroom but do not touch the paper towel dispenser.

Water Closet Clearance
In the 1991 ADAAG, there were several ways that you could approach and transfer onto the water closet.  The figure below showed you the choices you had:
As shown above, the lavatory was allowed to be inside the floor clearance of the water closet as long as it was 36″ from the side wall and it had a knee space at the sink.
The new standard you are required a 60″ clear at the water closet floor space.  A lavatory or any other fixture is not allowed to overlap.
So if an existing toilet room has the 1991 layout it will be acceptable and will be considered a safe harbor.  If the restroom is remodeled, then part of the new standards takes each element into consideration for requirements, and a change in one element will not trigger that the entire restroom be upgraded.  If all the fixtures are removed, then you would have to make it comply with the 2010 Standards, or file a variance if it is not technically feasible.
This toilet room was built prior to 2012 and it has a 46″ clear floor space at the water closet.  This is an example of a safe harbor.

Drinking Fountains

In the 2010 Standards it is required to have a forward approach knee clearance for drinking fountains designed for people who use wheelchairs.  In the 1991 ADAAG it was allowed to have a parallel approach for the drinking fountains.
So if there are any drinking fountains without a knee space, but the spout is no higher than 36″ a.f.f. then it is a “safe harbor” and compliant with the 2010 ADA Standards
These drinking fountains don’t meet the requirements for the 2010 ADA Standards, but because they meet the 1991 ADAAG they are a safe harbor and are deemed compliant.
What is NOT a Safe Harbor
When the ADA Standards were revised, they included requirements that were not covered in the original document.  Those new requirements will not be part of the Safe Harbor provision.  In other words, if you have an existing element that was not covered in the original standard it is not “grandfathered” and it must be brought up to the new standards.
Some of the examples are listed below:
Playground equipment
Existing playground equipment at parks or schools were never covered in the 1991 ADAAG.  Therefore existing playground equipment must be brought up to compliance “as it is readily achievable” according the the DOJ.

Swimming Pools

Another new element that was added in 2010 was swimming pools.  Again, existing pools are not “grandfathered” and will be required to be brought up to compliance.

Accessible Hotel Rooms

Wednesday, April 10th, 2019

Transient Lodging

The minimum number of guest rooms required to be accessible in transient lodging facilities is covered by section 224 of the 2010 ADA Standards. Scoping requirements for guest rooms with mobility features and guest rooms with communication features are addressed at section 224.2 and section 224.4, respectively.

Accessible guest rooms are used not only by individuals using mobility devices such as wheelchairs and scooters, but also by individuals with other mobility disabilities including persons who use walkers, crutches, or canes.

Guest rooms with communication features are used by persons that are visually and hearing impaired.
Even knowing where to look does not always make it simple to understand the requirements.  This newsletter will give you some examples of the not so well known rules about Transient lodging.

Roll in Showers

#ADAFact: If there are less than 51 guest rooms in a hotel or dorm, you are required to have mobility rooms without roll in showers.
This rule is very easy to miss because most of hotels have more than 50 guest rooms.  If you have less than 50, there are zero roll-in showers required.  But there are still required accessible bathing fixtures.  In a recent hotel review, I performed there were exactly fifty guest rooms.  I looked at the chart to see how many rooms with mobility features were required and saw that it was two.  But what I also noticed was that both of them could not have a roll in shower.  As a matter of fact, there is always a minimum number that is required without roll in showers.  So they could provide tubs or transfer showers instead.  See the chart below.

If they are interested in providing a roll in shower as an option, they would have to add a third guest room with mobility features.

Shower seats

#ADAFact:  All showers in a “transient lodging” facility are required to have a wall or floor mounted folding seat.
Generally, in the ADA Standards, the only showers that are required to have a seat are transfer showers.  There is one exception: “Transient lodging”
608.4 Seats. A folding or non-folding seat shall be provided in transfer type shower compartments. A folding seat shall be provided in roll-in type showers required in transient lodging guest rooms with mobility features complying with 806.2. Seats shall comply with 610.

When a roll-in shower has a seat , the controls will have to be located no more than 27″ from the seat wall

controls in the roll in shower were located no farther than 27″ from the seat wall


#ADAFact:  At least one guest room (but no more than 10%) required to provide mobility features as described in the 2010 ADA shall also provide communication features.
That means that you can’t have all your guest rooms with communication features in the mobility rooms.  But you are required to provide at least one of the rooms with both communication and mobility features.
In addition, they have to be dispersed as described below:
224.5 Dispersion. Guest rooms required to provide mobility features complying with 806.2 and guest rooms required to provide communication features complying with 806.3 shall be dispersed among the various classes of guest rooms, and shall provide choices of types of guest rooms, number of beds, and other amenities comparable to the choices provided to other guests. 
Where the minimum number of guest rooms required to comply with 806 is not sufficient to allow for complete dispersion, guest rooms shall be dispersed in the following priority: guest room type, number of beds, and amenities. 
At least one guest room required to provide mobility features complying with 806.2 shall also provide communication features complying with 806.3. 
Not more than 10 percent of guest rooms required to provide mobility features complying with 806.2 shall be used to satisfy the minimum number of guest rooms required to provide communication features complying with 806.3.
In the 1991 ADAAG this was not the case and some establishments made all the rooms with communication features the same as the rooms with mobility features.  Communication features must be available as soon as the guest arrives.  It is no longer allowed to have a device at the front desk for the guest’s to request.

Here are some examples of communication features
this is a hard-wired notification device for the hearing impaired.
There typically is more communication rooms required than mobility rooms, and therefore some would be exclusively rooms with communication features.  Designers must be careful to make sure that they are providing 90% of the rooms with communication features without mobility features.

Location of Diaper Changing Stations

Friday, March 1st, 2019

Diaper Changing Stations

#ADAFact: Diaper changing stations must be compliant with the 2010 ADA section 902, and be able to be used by persons with disabilities.
 In this blog, we will explore the proper locations of a diaper changing station within the restroom, which will allow the technical requirements to be met without creating any other accessibility issues.

The Location could affect Clear Floor Space

One of the requirements is for the diaper changing station to have a forward approach knee space. The location of the table or counter must not have anything in front of it which will impede the forward approach
This baby changing station does not have a clear forward approach because the toilet is in the way
Can the diaper changing station be inside a toilet compartment?  Yes, as long as there is enough room for a forward approach. Even though it is not a violation to have the only diaper changing station in the accessible stall, it would be recommended that it be located so that most of the public can use it without having to wait for the stall to be freed up.
The diaper changing station in the photo above is located in the toilet compartment_ but it has plenty of room after entering to have a forward approach

The Location could affect Door Clearance

When locating the diaper changing station on a wall within a single user restroom, it is important to locate it so that it is not in the way of the door maneuvering clearance.  The door should be able to swing clear of the diaper changing station like it is shown on the drawing below 
Not only do we have to be concerned about the diaper changing station when it is closed, but also when it is open.  If the diaper changing station is left open and a person in a wheelchair wants to come into the restroom, they would have a hard time maneuvering through the door since there is not a clear 60 of floor space.

the open diaper changing station is in the way of the
60 inches of required clearance to enter the restroom
this diaper changing counter is in the way of the 18 inches minimum required at the pull side of the door


Possible Protruding Objects

Depending on where the diaper changing counter is located it might be considered a protruding object when open (or closed).  If the person who might have been using it forgets to close it and a person who is visually impaired enters the restroom, if the counter is mounted so that the bottom edge is higher than 27″ a.f.f. then the counter will be an undetectable hazard and a protruding object. This was explained by TDLR in a  Technical MemoTM 2013-15 published in June 2013.
This open counter is higher than 27″ a.f.f. and is located in the way to the toilet. Therefore, it is considered a protruding object


The solution would be to either mount the counter so that the bottom edge is EXACTLY 27″ a.f.f. which provides the required knee clearance, but also allows it to be cane-detectable.  Or it can be relocated away from the circulation path.

What are Detectable Warnings?

Monday, February 4th, 2019
Detectable warnings are only required at curb ramps located in the public right of way and platform boarding edges.
Detectable warnings are used to assist persons that are visually impaired in detecting hazards along their wayfinding.  A person who is visually impaired uses a sense of touch to find their way.  Detectable warnings is one of those methods.  In the 1991 ADAAG, detectable warnings were described as having contrasting color and texture.  Contrasting color meant that it should have a different color than its surroundings (either light to dark or dark to light) and texture was achieved by using truncated domes. They were required at curb ramps and the edges between pedestrian and vehicular ways.
  But in the 2010 ADA Standards they were limited to only platform boarding edges.  The Public Right of Way Accessible Guidelines (PROWAG) and the 2012 Texas Accessibility Standards (TAS) also requires detectable warnings at curb ramps located within the public right of way.
detectable warnings at the platform edge of a train stop
This blog will give you the required regulations governing detectable warnings

Platform Boarding Edges

The ADA standards requires that detectable warnings be located along the boarding edges of trains or bus platforms.
ADA 705.2 (train) Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches (610 mm) wide and shall extend the full length of the public use areas of the platform. 
ADA 810.5.2 (Bus) Detectable Warnings. Platform boarding edges not protected by platform screens or guards shall have detectable warnings complying with 705 along the full length of the public use area of the platform.
light rail boarding platform edge has a lightly colored detectable warning

Public Rights of Way

There are also requirements for public rights of way (located outside the property line). The federal standards are called the “Public Right of Way Accessibility Guidelines” (PROWAG).  These are still a draft and have not been adopted, although they are recommended.  In Texas, TDLR wrote in their administrative rules a set of guidelines for public rights of way.  Below is a brief summary of each.

PROWAG state:

R208 Detectable Warning Surfaces
R208.1 Where Required. Detectable warning surfaces complying with R305 shall be provided at the
following locations on pedestrian access routes and at transit stops:
1. Curb ramps and blended transitions at pedestrian street crossings;
2. Pedestrian refuge islands;
3. Pedestrian at-grade rail crossings not located within a street or highway;
4. Boarding platforms at transit stops for buses and rail vehicles where the edges of the boarding platform are not protected by screens or guards; and
5. Boarding and alighting areas at sidewalk or street level transit stops for rail vehicles where the side of the boarding and alighting areas facing the rail vehicles is not protected by screens or guards.
R305.1.4 Size. 
– Detectable warning surfaces shall extend 610 mm (2.0 ft) minimum in the direction of
pedestrian travel. 
– At curb ramps and blended transitions, detectable warning surfaces shall extend
the full width of the ramp run (excluding any flared sides), blended transition or turning space.
– At pedestrian at-grade rail crossings not located within a street or highway, detectable warnings shall extend the full width of the crossing. 
– At boarding platforms for buses and rail vehicles, detectable warning surfaces shall extend the full length of the public use areas of the platform.
–  At boarding and alighting areas at sidewalk or street level transit stops for rail vehicles, detectable warning surfaces shall extend the full length of the transit stop.
R305.2 Placement. The placement of detectable warning surfaces shall comply with R305.2.


R305.2.3 Blended Transitions. On blended transitions, detectable warning surfaces shall be
placed at the back of curb. Where raised pedestrian street crossings, depressed corners, or other
level pedestrian street crossings are provided, detectable warning surfaces shall be placed at the
flush transition between the street and the sidewalk.


R305.2.4 Pedestrian Refuge Islands. At cut-through pedestrian refuge islands, detectable warning
surfaces shall be placed at the edges of the pedestrian island and shall be separated by a 610 mm
(2.0 ft) minimum length of the surface without detectable warnings


TDLR AB Rules requires:

These requirements are not located in the Texas Accessibility Standards, but rather in the TDLR Administrative Rules Chapter 68
68.102. Public Right-of-Ways Projects
(2) Curb Ramps-
(A) At perpendicular curb ramps constructed within the public right of way, detectable warnings complying with TAS 705 at a minimum of 24″ in depth (in the direction of pedestrian travel) and extending the full width of the curb ramp shall be provided where the pedestrian access route enters a crosswalk or other hazardous vehicular area.

(B) At parallel curb ramps constructed within the public right-of-way, detectable warnings complying with TAS 705 at a minimum of 24″ in depth (in the direction of pedestrian travel) and extending the full width of the landing shall be provided where the pedestrian access route enters a crosswalk or other hazardous vehicular area.


(C) At diagonal curb ramps constructed within the public right-of-way, detectable warnings complying with TAS 705 at a minimum of 24″ in depth (in the direction of pedestrian travel) and extending the full width of the curb ramp or landing, shall be provided where the pedestrian access route enters a crosswalk or other hazardous vehicular area. Additionally, the department will allow the detectable warning to be curved with the radius of the corner.

The detectable warning shall be located so that the edge nearest the curb line is 6″ minimum and 10″ maximum from the curb line.

For more information about PROWAG and its requirements click on this link

TABS (Texas Architectural Barriers online System)

If you do work in Texas you should be aware that there is a new system for online registration and keeping track of the projects.  The  Texas Department of Licensing and Regulation has now created a system that eliminates most paper forms and makes many things cloud-based.
The main differences are as follows:
1) In order to register a project, you will have to create an account with TDLR here
2) The TDLR registration occurs in the pull-down menu shown below.  You can also fill out the registration form and send it to your RAS for her to do it for you.

3) If you register the project yourself, you must also upload the Proof of Submission FormOwner agent form (if there is an owner agent) and a digital copy of the drawings

4) when you register the project (or fill out the registration form), you will also be required to submit the square footage of the building.  If it is not a building, make your best faith effort to estimate it.
5) Once you register the project you will be able to view results and other saved items in the online “file cabinet”
In this new system you will be able to update information to the project, upload revised drawings, and check the status of the project.
If you have any questions about this new system you can reach our office or TDLR directly.