What doors are required to comply with ADA?

There seems to be a confusion about which doors are required to comply with the Americans with Disabilities Act. Most people understand that doors that lead you to accessible public spaces and rooms have to comply. But many don’t realize that ALL doors that allows “user passage” must comply with the standards. There is just one exception: a door that allows user passage but it is leading into a room that is exempted from accessibiltiy (i.e. a machinery space).

Knowing that information, let’s delve into what doors are required to comply and what are the requirements.

Doors that allow user passage like the one shown above must comply.

Which Doors must comply?

In section 206.4 of the ADA it gives us the requirements for which type of doors must be accessible.

206.4 Entrances. Entrances shall be provided in accordance with 206.4. Entrance doors, doorways and gates shall comply with 404 and shall be on an accessible route complying with 402

206.5 Doors, Doorways, and Gates. Doors, doorways, and gates providing user passage shall be provided in accordance with 206.5.206.5.1

This paragraphs lets us know that only entrance doors are going to have requirements. Exit doors are not fully exempted. The door to “exit” a space is technically an “entrance” to the exit. Therefore the side of the door which allows user passage must also comply.

Even though this is a means of egress door and has limited requirements in the ADA Standards, it is considered a door that allows user passage and must comply.

206.5 continues to tell us which spaces must have doors that comply:

• Each entrance to a building or facility (there are some restrictions, so be sure to understand them)
• Within a building at least one door serving each room (even work areas)
• In transient lodging facilities all entrances providing user passage into and within guest rooms that ARE NOT required to provide mobility features (but only the clear width)

This floor plan shows a hotel room that is not required to have mobility features. All doors (except the shower door) which allows “user passage” into and within the room must comply. A 32″ clear width should be provided. All other requirements are not mandated.

A common misunderstanding is the term “user passage”. A user that they are describing is not only people who use wheelchairs, but also ambulatory and able bodied users. Therefore even if the room where the door is located is not large enought for a wheelchair, the door clear width into the room must still comply. Note the water closet room. That door must also comply with providing at least a 32″ clear width, even if the room is not large enough for a wheelchair to enter.

This storage closet appears to be the type that allows user passage, and therefore the door must comply with the techical requirements.

What are the technical requirements?

To find the technical requirements we look in section 404 which explains how to make the required doors accessible.

Doors, doorways and gates must meet the following standards:

• Must have a clear width of 32″
• Must have proper maneuvering clearances to allow for a person to open the door and go through
• The floor and ground surface at the maneuvering clearance must be stable, firm, slip resistant and must have a slope no steeper than 1:48
• A threshold that is not higher than 1/2″ must be provided
• The hardware must be the type that does not require tight grasping and twisting of the wrist, plus must be mounted between 34″-48″ a.f.f.
• The door should not close too fast (no faster than 5 seconds)
• The opening force should not be too heavy (no more than 5 lbs on an interior door)
• The bottom surface at the push side should be smooth
• If it has a vision light it should be mounted no higher than 43″ a.f.f. (a peep hole is not a vision light)
• And if there is an automatic door, there are some additional requirements (under 404.3)

This door had a clear width of 28 1/2″. The minimum requirement is 32″ clear

This picture shows the proper maneuvering clearance to reach the door handle and to go through the door

Even sliding doors are required to have maneuvering clearance. The only ones that will not is for shallow closets that do not provide user passage

This video shows you the requirements for door maneuvering clearances

The door shown above has a slope steeper than 1:48 at the maneuvering clearance, and a threshold higher than 1/2″

The door shown above has hardware that requires tight grasping and twisting of the wrist to operate

A dining counter has a forward approach knee clearance and it is 34″ a.f.f.

The door hardware in this door was mounted at 61″ a.f.f. (higher than the allowed 48″ a.f.f.)

Because the push side of the door must have a smooth surface, a foot opener cannot be used on the push side

In addition, the door hardware on the push side of the door must not be lower than 10″ a.f.f.

The vision light shown above was mounted higher than 43″ a.f.f. to the glazing.

Section 810.2 Bus Loading Zones

This newsletter will speak about Bus Loading Zones both in the Public Right of Way and inside a property (like a school or other facility).

The bus stop in the above picture does not show the proper requirements for loading and unloading. This newsletter will explain why

The bus stop in the above picture is at a school and appears to have the correct area for loading children with disabilities

Technical Requirements

Bus loading zones must have an area that 96″ long measured perpendicular to the curb or vehicle roadway edge, and a clear width of 60 inches (1525 mm) minimum, measured parallel to the vehicle roadway.

The video above shows why the 96″ long area parallel to the curb is required. The lift mechanism for a wheelchair user to enter and exit the bus requires that amount of space.

If there is a bus shelter there should be a path of travel from the bus shelter to the loading area. The path needs to be a minimum of 36″ wide. There should be an area inside the shelter that is 30″x48″ with a slope of no greater than 1:48

Accessible Work Areas

Thank you to Marsha Godeaux from TDLR for taking the time to explain about employee work areas. Click here to watch the video.

This newsletter will cover Employee work areas. There is a misunderstanding that work areas are not required to comply with the ADA or TAS Standards. We will explain what is required to comply within work areas and what is exempted. Keep in mind that the requirements we are covering are only the 2010 ADA Standards and the 2012 Texas Accessibility Standards. The ABA which covers Federal Facilities do not have the same requirements.

What is a Work Area?

Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.

Work Area Equipment. Any machine, instrument, engine, motor, pump, conveyor, or other apparatus used to perform work. As used in this document, this term shall apply only to equipment that is permanently installed or built-in in employee work areas. Work area equipment does not include passenger elevators and other accessible means of vertical transportation.

Work cubicles are part of a work area

a Point of Sale counter is considerd a work area as long as the public is not required to approach it.

What are the requirements?

203.9 Employee Work Areas. Spaces and elements within employee work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area.

The image above summarizes the approach, enter and exist requriement

An example of a work area that only requires an approach, enter and exit would be a janitor’s closet. Elements within the janitor’s closet such as the faucet for the mop sink will not be required to comply.

An exam room is partially a “work” area and partially a “patient” area. The area that is only used by the doctor (the sink) will be exempted from having to comply.

What are some exceptions?

Employee work areas, or portions of employee work areas, other than raised courtroom stations, that are less than 300 square feet and elevated 7 inches or more above the finish floor or ground where the elevation is essential to the function of the space shall not be required to comply with these requirements or to be on an accessible route.

This toll booth is less than 300 s.f. and elevated more than 7″ a.f.f. and therefore do not require an accessible route to it or the ability to approach it and enter it.

Common Circulation Path

In addition to approach, enter and exit, if the employee work area is larger than 1,000 s.f.. then a common path within the work area to common use spaces shall be provided

206.2.8 Employee Work Areas. Common use circulation paths within employee work areas shall comply with 402.

A “common” circulation path is one that is used by more than one person and not intendend for work

Section 402 states that a minimum 36″ width shall be provided along the circulation path.

EXCEPTIONS:

1. Common use circulation paths located within employee work areas that are less than 1000 square feet (93 m2) and defined by permanently installed partitions, counters, casework, or furnishings shall not be required to comply with 402.2.

This raised work area is allowed since the work area is less than 1,000 s.f.

If the path is around work area equipment, then it will not have to comply with the 36″ clear width.

This commercial kitchen has equipment that is an integral part of the work area. The 36″ min. circulation path in this space is not required to comply due to the location of the work area equipment.

Protruding Objects

Even though the only requirement for a work area is “approach, enter and exit”, it also requires that circulation path be provided. Part of the circulation path has to make sure there are no protruding objects projecting onto the circulation path more than 4″. This requirement are for any employee or visitor to the employee area that might be visually impaired.

the filing system is located along the common circulation path inside the office space and projects more than 4″ onto the circulation path.

What about other employee areas that are not work related?

The requirements thus far have been for areas that are considered part of the “work” areas in a space. But there are other areas that are also part of an employee area, but are not related to the work they perform. Those areas that are NOT related to their job description will not be exempted and must comply. Below are a few examples of areas that might be for employees only, but must be fully compliant with the Standards:

Break Rooms

even though a break room is not a public area, it is still required to comply with the ADA and TAS because it is not considered a “work” area, but rather a space where they take a break from work.

LEED employee shower and employee restrooms

an employee shower or even an employee restroom are also not considered “work” areas and must comply.

Employee Locker Room

The lockers as well as the bench in this locker/dressing room must comply with the Standards

What happens when an employee is disabled?

The Standards sometimes provide additional guidance through “advisories”. These are NOT requirements, but they are suggestions that might make your design a better one. Below are some of the advisories on work areas:

Advisory 203.9 Employee Work Areas. Although areas used exclusively by employees for work are not required to be fully accessible, consider designing such areas to include non-required turning spaces, and provide accessible elements whenever possible.

Under the Title I of the ADA, employees with disabilities are entitled to reasonable accommodations in the workplace; accommodations can include alterations to spaces within the facility. Designing employee work areas to be more accessible at the outset will avoid more costly retrofits when current employees become temporarily or permanently disabled, or when new employees with disabilities are hired.

Abadi Accessibility is proud to support the Americans with Disabilities Act (ADA) 31st Anniversary. On July 26th we celebrate this important civil rights law that works to ensure all people with disabilities have the same rights and opportunities as everyone else. Celebrate with us by visiting: www.adaanniversary.org/ #ADA31 #ThanksToTheADA

How are you planning to celebrate Americans with Disabilities Act (ADA) 31st Anniversary? This July 26th the ADA National Network and individuals, communities, and organizations across the country will be participating. Learn how you can be involved by visiting www.adaanniversary.org/ #ADA31 #ThanksToTheADA

Introduction to our newsletter:

After I wrote my first newsletter about counters, my clients are still not clear on all the different requirements for the different types of counters and fixed or built-in surfaces that the ADA requires to be accessible. First of all let me review that there are five type of counters scoped in the ADA Standards: Work surfaces, dining counters, service counters, sales counters and check out counters. Then there are two type of counters that are not scoped: work area counters and non-work area common use counters that do not fall under the other listed. There are also Food service lines, as well as other portions public side service areas. For those please check out my newsletter I wrote I 2014.

This newsletter will explain the different requirements for dining surfaces, non-employee work surfaces and sales and service counters.

Inspector’s Corner

Post-mounted protruding objects

(this is not exactly examples of violations, but rather why it is not a violation)

The rules for protruding objects allows post or pylon mounted obects to project 12″ from its mounting surface. The figure below is from the ADA and TAS section 307.3 which shows the parameters of the protrusion limits.

My example is from an interior play area where there was a statue of one of their characters mounted on a pylon or tall base. The statue had a little hand and pigtail that projected beyond the edge of the base. But because the ADA and TAS allows a 12″ protrusion limit along the circulation path, the statue was not a protruding object.

The little hand of the statue projected 6″ beyond the base, which was compliant.

Another example of a post mounted protruding object is a stand pipe located at a means of egress stair landing. Because the means of egress is essentially a circulation path it will require that the protrusion limits that the ADA and TAS describe in section 307 be adhered to.

The stand pipe in the photo below does have an extension where the valve is projecting more 12″ beyond the pipe and mounted higher than 27″ a.f.f.

The stand pipe is a protruding object because the valve projects more than 12″ from the post onto the circulation path

Pendant lights as protruding objects

The 2010 ADA Standards for Accessible Design (The ADA for short) is sometimes used as a catch-all term for all requirements for designing for persons with dissabilities. What is sometimes misunderstood is that the ADA is a Civil Rights law with design guidelines for public accommodations and commercial facilities. But there are other laws and standards that govern how to design for persons with disabilities that are different from the ADA and still have to be followed. One of the standards are found in the building code. If a municipality has adopted Chapter 11 of the IBC that chapter references another Standards call the ANSI A117.1. The ADA and ANSI are very similar, but there are some differences. In this newsletter I will give you a few examples.

For the sake of this newsletter I wilil be discussing the 2017 ANSI A117.1 Standards. This may or may not be the Standared that has been adopted by the municipality you are designing under and you will need to verify which version you need to follow. Not all the versions have the same requirements.

304 Turning Space

604.5.2 Rear Wall Grab Bar

Both in the ADA and the ANSI the section that discusses the rear wall grab bars is 604.5.2 But the location of the grab bar is measured differently in the ANSI than in the ADA. this confuses most installers and we typically find ADA violations based on the assumption that they are both the same.

Note the figure below. It is from the 2017 ANSI A117.1 604.5.2

It shows that the rear wall grab bar is located in relation to the side wall. It should measure 6″ from the side wall to the inner edge of the grab bar and it should have an overall dimension of 42″ min. from the side wall to the outer edge.

This is figure ANSI A117.1 604.5.2 from the 2017 version

Note the figure below. It is from the 2010 ADA section 604.5.2

It shows that the rear wall grab bar is located in relation to toilet. It should also be 36″ long min. just like the ANSI, but we locate it from the center of the toilet so that there is 12″ min. from the center to the inner edge and 24″ min. from the center to the outer edge.
The ADA rear wall grab bar location has no relation to the side wall.

This is figure 604.5.2 from the 2010 ADA Standards. It shows the rear wall grab bar and its lcoation in relation to the toilet.

502 Parking

502.9 Parallel Parking

The 2017 ANSI Standards has guidelines for parallel parking for on-street parking. It requires a vehicle space plus an access aisle parallel to the curb and a curb ramp or accessible route close to the spaces.

The figure 502.9.1 above shows on-street parallel parking

502.11 Electrical Vehicle Charging Stations

The 2017 ANSI Standards provide requirements for Electrical Vehicle charging stations. Some of them are

• Operable parts should be within reach
• There should be an access aisl adjacent to the parking space with clear floor sapce next to the unit
• Any protection bollards, curbs and wheel stops should not be located so it obstructs the route or the reaching.

It’s been a while since I have done an “Inspector’s Corner”….It was actually last April…must be an April Fools thing…but it is not. I go to many inspections and see some really interesting violations (amid all the common ones). I even learn from them. Here are three that I saw that are good to learn from:

Ambulatory Toilet compartments

The ambulatory compartment was located next to the wheelchair compartment which was only 58″ long

Cane detectable aprons at Electric Water Closets

The drinking fountain shown above if mounted along a circulation path the high one will not be detectable and will be considered a protruding object

A good solution for drinking fountains that are protruding onto the circulation path is to create “cane detection” by using a cane detectable apron which most manufactures have as an accessory that can be added after market. The apron should be located under the “protruding object” which is typically the high drinking fountain. If mounted correctly it will reach the 27″ a.f.f. which provides cane detection and will resolve the violation.

The issue becomes when the use of the cane detectable apron is misunderstood. Some contractors do not understand why they are being installed and will mount them to the wrong drinking fountain.

The drinking fountain shown above has a cane detectable apron mounted under the wheelchair accessible drinking fountain. That drinking fountain was not the protruding object but in addition not the wheelchair drinking fountain does not have a knee clearance due to the apron.

the cane detectable apron was mounted under all the drinking fountains. In addition, the cane detectable apron was not required since the wing walls that were installed would have been used as cane detection as well.

Changes in Level

The ADA Standards has a chapter called “Changes in Level” which states that along the accessible route you may not have any changes in level greater than 1/4″ or 1/2″ with a bevel.

The drawing is showing the location of the turning space which overlaps inside the roll in shower.

This was a photo of the collapsable curb at the roll in shower.

Based on the advisory of section 304 which discusses turning spaces, this is acceptable:

Advisory Advisory 304.2 Floor or Ground Surface Exception.

As used in this section, the phrase “changes in level” refers to surfaces with slopes and to surfaces with abrupt rise exceeding that permitted in Section 303.3. Such changes in level are prohibited in required clear floor and ground spaces, turning spaces, and in similar spaces where people using wheelchairs and other mobility devices must park their mobility aids such as in wheelchair spaces, or maneuver to use elements such as at doors, fixtures, and telephones.

Click her to watch the video to introduce our newsletter

ADA Section 213 Toilet Facilities and Bathing Facilities

Section 213.2 of the ADA explains that where toilet room and bathing rooms are provided, each one must comply with the Standards.

There are a few exceptions that allow some toilet rooms and bathing rooms not to have to comply. This newsletter will explain those exceptions and when they can be taken.

ADA Section 213.2 Exceptions

Exception #1 explains that not all restrooms would be required to comply in an alteration when it is technically infeasible to comply and cannot be made compliant due to existing conditions, they do not all have to comply and a the owner must apply for a variance with the AHJ. In such cases, a single user restroom can be used instead.

Exception #2 In a Historic facility (a facility regsitered with the National Register or Landmark Commission) is not required to have all toilet rooms accessible. One unisex restroom will be allowed to be used.

Exception #3 if there are multiple single user portable toilet or bathing rooms that are clustered at a single location, no more than 5% of each must comply.

This is a single user portable toilet room

Exception #4 Where multiple single user toilet rooms are clustered at a single location, no more than 50% of the single user toilet rooms for each use at each cluster shall be required to comply. This section only gives the exception to toilet rooms (even though it is part of the same section that also discusses bathing rooms)

The above image is of two single user restrooms clustered together. Only one must comply

The above image is of two single user restrooms that are not in a cluster because the doors open to separate areas. In the Advisory it explains that a cluster are “within sight of or adjacent to one another”. Both of these toilet rooms must comply

The above image is of multiple single user toilet rooms and multiple single user bathing rooms in a cluseter. In this plan only restroom 117 and 119 can take the exception because they are toilet rooms in a cluster and they are of the same kind.

All the other toilet rooms have showers and therefore are considered bathing rooms. Even though they are in a cluster, there is no exception for bathing rooms that are in a cluster, so all of the bathing rooms must comply.

Section 213.2.1 Unisex or single user restroom or Family restroom and unisex bathing rooms is defined as containing no more than one lavatory,and two water closets without urinals or one water closet, one urinal and one urinal. In addition, a unisex bathing room is considered unisex when it has one shower or one shower/tub, one lavatory and one water closet.

Even though these individual toilet compartments have a lavatory and a water closet, they are located inside a multi-user toilet room and therefore only one compartment is required to comply. These are not single user toilet rooms. These are toilet compartments inside one multi-user toilet room.

Even though these individual shower compartments, they are located inside a multi-user toilet room and therefore only one compartment is required to comply.

Click her to watch the video to introduce our newsletter

Before we start designing…..

Before starting to design operable parts by looking in section 309, we should begin in section 106.5 Defined Terms. This section will give us guidance on what is defined as an operable part:

Operable Part. A component of an element used to insert or withdraw objects, or to activate, deactivate, or adjust an element.

Now that we know what is defined as an “operable part” we can then go to Section 205 which gives us information on how many and which type are required to comply with the technical standards found in 309.

Section 205 begins with some exceptions. According to this section, operable parts on an accessible element, accessible route and in accessible rooms must comply. In the same section we also have a few exceptions.

1.Operable parts that are intended for the use only by service or maintenance personnel do not have to comply:

The medical equipment in this patient room is only for the use of the medical service personnel and does not have to be mounted within reach range

2 . Dedicated use electrical receptacles do not have to comply

The outlets that are used for appliances or specific electrical uses above the counter will not have to comply

3 . Where two or more outlets are provided in a kitchen above the length of counter top that is uninterrupted by a sink or appliance, one outlet shall not be required to comply

There are two outlets above the counter. Because they are not interrupted by a sink or appliance only one outlet will have to comply

The exercise equipment controls do not have to comply.

Section 309 Operable parts

Once we have determined which operable parts are required to comply, we read the requirements on those operable parts in section 309: There are several requirements but in this newsletter we will focus on reach ranges which are found in section 308.

The rules about reach ranges are to locate the maximum and minimum heights to the operable parts.. In essense the height to the parts of the element that will need to be operated so that the element can work.

309.3 Height. Operable parts whsll be placed within one or more of the reach ranges in section 308

Section 308 requires that the operable part be within reach. Either unobstructed forward or side.

This light switch was mounted so that its operable part is at 48 1/2″ a.f.f. rather than the required BELOW 48″ a.f.f. to the top of the switch (which is what make it operate)

The rocker light switch was mounted so that it was 48″ a.f.f. to the middle of the switch. The problem with this is that the switch is operable by pushing the top or the bottom of the switch, not the middle.

The low reach (forward or side) can be no lower than 15″ a.f.f The charging outlet at these booths are mounted 8″ a.f.f.

Operable parts could also be located so that they are reached over an obstruction, either forward or side approach.

the outlet at the wall behind the counter is a type of operable part that will need to be within reach range. Most of the times the outlets are located at the gyp board, which in this case it is located more than 25″ away from the edge

operable parts over the obstruction can only be located a maximum of 25″ from the edge of the obstruction. The soap dispenser is located 26″ away

operable parts at classroom lab tables must be within reach also

the operable part is more than 25″ from the edge of the obstruction

Operable parts have many requirements, including the ability to reach it in order to operate if. The reach range requirements are to the part of the element to operate it, rather than the middle of the element, or the top of bottom. In addition, the location should never be exactly at the “maximum” or “minimum” . Construction is not a perfect science and tolerances are built in to the requirements. So when we are designing the elements keep in mind how it is operated and always design within the reach range, not higher or lower.