Bathrooms

Above and Beyond the ADA Standards

Tuesday, March 4th, 2025

The 2010 ADA Standards for Accessible Design are only minimum requirements to ensure that the facility will be, to the maximum extent feasible, be readily accessible to and usable by individuals with disabilities.

What that means is that the requirements are a base line for how to make buildings accessible, and if something better or more accessible can be provided, that would be ideal.

As an inspector, I cannot tell my architects and owners to do more than the minimum, but this newsletter will give guidance on elements that may not be required, but would be a good practice to provide.

Wheel Stops

Wheel stops are not required by the ADA standards. The minimum requirement is that the sidewalks and parking should be desiged as to prevent the parked cars from reducing the clear width of the accessible route:

ADA Section 502.7 Relationship to Accessible Routes. Parking spaces and access aisles shall be designed so that cars and vans, when parked, cannot obstruct the required clear width of adjacent accessible routes

Wheel stops are a good way to prevent the cars and vans from obstructing the clear width of the accessible route.

The photo above shows an accessible route located in front of the parking spaces, and because there are no wheelstops the front of the parked car is partially obstructing the route.

The photo above shows parked cars that are obstructing not only the walking surface but also the curb ramps that are part of the accessible route. Wheel stops would prevent it.

Benches at Shower rooms

The ADA Standards section 803 requires that dressing, fitting and locker rooms provide a bench.

ADA Section 803.4 Benches. A bench complying with 903 shall be provided within the room.

As an inspector I find that design professionals think they need to have a bench at shower rooms. Technically the shower rooms would be a place to undress in order to take a shower, but it is not considered a “dressing room”. Therefore a shower room is not required to have a bench as stated in section 803.

Even though it is not required, a bench in the shower room would be a good practice to provide, since the likelyhood of a person with disabilities to need to undress in order to use the shower would be high, the bench would be helpful.

For information: A bench is different than a shower seat

The drawing above shows a locker room with showers. Because this is a locker room, a bench is required in this room.

The drawing above shows a shower room. Even though there is a bench shown in the shower room, it is not required.

The photo above shows a bathing room without a bench.

Power Assisted doors

Exterior doors are not required to have an opening force more than 5 lbs. That requirement is only for interior swing doors. But exterior swing doors might be difficult to open due to the wind pressure or other factors that are not within out control. One way to provide assistance with difficult doors is to install power assisted doors. They are not required, but if used they must comply.

Even though a power assisted door is not required by the ADA Standards, it would be a good practice to provide one in order to assist persons with disabilities to open exterior doors.

The photo above shows a power assisted mechanism on the exterior entrance in order to provide assistance for persons with disabilities to open the door.

34″ a.f.f. Counter Heights

There are two different requirements at fixed counters depending on what they are used for.

Section 902 requires that a fixed dining or non-employee work surface be mounted at 34″ a.f.f.

Section 904 on the other hand has a requirement that the fixed sales or service counters be mounted at 36″ a.f.f.

As an inspector I find violations when the fixed dining counters are mounted higher than 34″ a.f.f. or the fixed sales or service counters are mounted higher than 36″ a.f.f.

In order to avoid this it would be recommended to mount all counters at 33″ a.f.f. therefore they will be meet both requirements.

The fixed dining counter shown in the photo above is required to be mounted a maximum of 34″ a.f.f.

The fixed ticket counter shown in the figure above is considered a “sales and service counter” and will be required to be mounted a maximum of 36″ a.f.f.

The movable reception counter is not required to provide an accessible portion since it is considered furniture, but it would be good practice to provide one so that a person with disabilities will be able to approach it and utilize it.

Private Bathrooms

Monday, February 3rd, 2025

There is a misconception that a private bathroom is exempted from having to comply with the 2010 ADA Guidelines and the 2012 TAS. In reality, even private bathrooms must comply, although there are some exceptions they can take. In order to take the exceptions, a bathroom is deemed “private” if the bathroom is accessed from a private office and not for public or common use. This newsletter will discuss what items are required to be provided at private bathrooms, and which one’s can be left out. There is a summary from TDLR on TM 2013-19  which we will discuss in detail.

Toilets

At a private bathroom that is accessed through a private office and not for common use, the toilets must comply with all the requirements except for:

  1. The height of the toilet does not have to be 17″-19″ a.f.f. It can be higher or lower than the minimum required heights.
  2. Grab bars are not required to be installed, but blocking must be provided within the wall for future installation
  3. In the Toilet and Bathing rooms the door can swing into the clear floor space of the fixtures in a private office

So a private toilet must still have the clearances required at the floor area distance from the side wall, flush control and toilet paper dispenser must comply with 604.

The photo above shows a toilet in a private bathroom. As you can see, no grab bars are provided. They are not required. Blocking for future grab bars should be provided.

But notice that it is located in a toilet compartment without a toe clearance and the width was not increased to accommodate the maneuvering to exit

The photo above shows the 60″ width inside the hard walls. ADA requires 6″ more when toe clearance is not provided….so 66″ min. would work.

 

The photo above shows another private bathrom toilet. This one did not provide the clearance arount the toilet required.

Sinks

At a private bathroom accessed from a private office and not for public use must have a sink that complies with everything in section 606 except:

  1. The sink does not have to have a knee space complying with 306 for forward approach. A parallel approach is allowed to be provided.
  2. The height of the sink does not have to be a 34″ a.f.f. maximum. It can be higher or lower than what the Standards require.

The sink is required to have the proper faucet mechanism, the mirror at the correct height, and floor area for parallel approach.

The photo above shows a lavatory in the private office. Although the lav itself can be taller than 34″ a.f.f. and does not need a knee clearance, the mirror will have to be mounted no higher than 40″ a.f.f. (this one is higher)
The photo above shows a lavatory in the private office. Although the lav itself can be taller than 34″ a.f.f. and does not need a knee clearance, the mirror will have to be mounted no higher than 40″ a.f.f. (this one is higher)

Showers and Tubs

At a private bathroom accessed by a private office and not for public or common use, the showers and tubs have to comply with all the requirements of section 607 and 608 except for:

  1.  Grab bars do not have to be installed, but blocking within the walls for future installation must be provided.

Otherwise, a shower must have the controls installed at the proper reach range, a hand held shower unit must be provided, the threshold at the entry must not be higher than 1/2″, the size of the shower must comply, and at a transfer shower a seat must also be provided.

The shower in the private office was not required to provide grab bars, but there should have blocking for future grab bars. The shape of the shower is not required to be rectangular, therefore this shower should comply. The door to enter would have complied, but there was no maneuvering clearance to open. If the hinge would have been located opposite of this one, that would have corrected the issue.

The shower in the private office had controls mounted higher than 48″ a.f.f. and did not have a hand held shower unit


I was honored to be part of my colleague’s podcast Michelle Grace Hottel,AIA called “I’ve never met a woman architect before…” podcast with Michele Grace Hottel, Architect

Enjoy!!!

Need Barrier Free CEUs?

On Demand Online courses:

Free Online CEU Gannett Flemming AIA Library: Designing for All: A conversation around the Principles of inclusive architcture and accessibiilty

Green CE On Demand webinar Understanding the 2010 Accessibility Standards

Green CE On Demand webinar “ADA and Residential Facilities”

Green CE on Demand webinar: How Accessible is your work place

AIA U online course: “Applying the ADA on Existing and Altered Buildings”

We offer live online courses as well. If you are interested, please contact our office.

Visit our Resource Page that we are building to give you guidance on products and services

If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide”  “Applying the ADA” published by Wiley.

 

If you have any questions about these or any other topics, please feel free to contact me anytime.

Drinking Fountain Cane Detachable Apron

Thursday, January 2nd, 2025

Protruding Objects: An overview

The accessibility Standards are not only for mobility, but also for people who are visually impaired.

People with visual impairments (blindness, low vision etc.) will not be able to see their environment, but rather they feel their way around. They are taught to use a cane to feel their way. That cane can detect elements on the ground as well as any element mounted so that their leading edge (bottom usually) is lower than 27″ a.f.f.

Any element that is mounted on a vertical surface higher than 27″ above the finished floor and projecting more than 4″ from the mounting surface will be considered a hazard to persons who are visually impaired. That hazard is described in the ADA Standards as a “protruding object”

307.2 Protrusion Limits. Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the floor shall protrude 4 inches (100 mm) maximum horizontally into the circulation path.

The figure above shows the limits to what would be considered a protruding object.

Keep in mind that the definition of a protruding object in the standards state that objects which are located in a circulation path are the ones of which we need to be careful.

What might be confusing for us architects and designers is the definition of a “circulation path”. In architectural terms, the word “circulation” implies corridors, stairs, elevators. Because of that, we may not always think of “circulation” in terms of how people who are visually impaired define it. To them, any place they walk will be their “circulation path”.

Here is the definition found in the ADA:

Circulation Path. An exterior or interior way of passage provided for pedestrian travel, including but not limited to, walks, hallways, courtyards, elevators, platform lifts, ramps, stairways, and landings.

Which means that any “passage for pedestrian travel” will be a circulation path, exterior or interior.

Below are some examples of Protruding objects:

The photo above was taken inside a restroom. The paper towel dispenser is located in the circulation path to the lavatory

 

The photo above was taken at a restaurant. The dining counter had an open side that was higher than 27″ a.f.f. and projected more than 4″
The photo above was taken inside a restroom. The open diaper counter was mounted higher than 27″ a.f.f. and projected more than 4″ onto the circulation path around the restroom.
The photo above was taken inside an exit stairwell. The cross bracing is located along the circulation path to the door which leads you back into the building. Since it is leaning at a certain point, the leading edge is lower than 80″ a.f.f. and it is a protruding object.
The hi-lo drinking fountain shown above has the leading edge of the “high” fountain (for standing persons) mounted higher than 27″ a.f.f. and projects onto the circulation path more than 4″.


This drinking fountain is located in a recessed alcove, but it is still protruding onto the circulation path because the recess is not deep enough

Solutions for Correcting Protruding Objects

One of the ways that elements that are protruding objects can be corrected would be to create “cane detection”.

Remember that the reason why the element would be considered a protruding object is because it cannot be detected by a person who is visually impaired and uses a cane to find their way. If the element can be detected by using the cane, then it will NOT be a protruding object.

An example would be a hi-lo drinking fountain. The low drinking fountain IF mounted so that there is knee clearance (27″ a.f.f.) it will also be cane detectable (no higher than 27″ a.f.f.). But because the “high” drinking fountain is for standing persons and requires that it be higher than 27″ a.f.f. it will not be cane detectable. Most drinking fountain manufacturers have additional accessories that one can specify called “cane detectable apron” which can be installed at the higher drinking fountain (IF IT IS A PROTRUDING OBJECT) and it will therefore be able to be detected by a person who uses a cane.


The high drinking fountain shown above has a cane detectable apron installed which reaches exactly at 27″ a.f.f. making it cane detectable

Misunderstanding about cane detectable aprons

I have been noticing at new construction, that the cane detectable aprons are installed even when the drinking fountain is not a protruding object. And also they have been installed at every drinking fountain, even the low one for wheelchairs.


The photo above shows a drinking fountain located in an alcove. It is not technically protruding onto a circulation path and the walls on either side of the drinking fountains act as cane detection. So the cane detectable apron installed under the “high” drinking fountain was not required.

Not only is the drinking fountain shown above in an alcove and not protruding, and did not need a cane detectable apron, but the low drinking fountain would never need a cane detectable apron because if mounted for knee clearance it will be cane detectable without the apron, but when the cane detectable apron is installed it reduces the knee clearance to less than 27″ a.f.f.

This photo is another example of drinking fountain in recessed alcove, not protruding and each drinking fountain had the cane detectable apron installed.

Examples of elements that are NOT Protruding objects

Here are some wall-mounted elements that do not meet the criteria for protruding objects. Remember that for an object to be protruding it must meet the following criteria:

  • It must be located along a circulation path
  • It must be mounted so that the bottom of the object is higher than 27″ a.f.f.
  • It must be more than 4″ deep measured from the mounting surface to the front edge of the object
The paper towel dispenser is mounted higher than 27″ a.f.f. and projects more than 4″ from the vertical surface it is mounted on BUT it is not located in a circulation path. The fact that it is mounted between two lavatories in the top photo and between the toilet and lavatory in the second photo takes it away from a circulation path where a pedestrian would bump into it.
The photo above is a diaper counter that is mounted higher than 27″ a.f.f. and projects more than 4″ from the wall, but because it is located between a wall and a lavatory it is not in a circulation path.
Need Barrier Free CEUs?

On Demand Online courses:

Free Online CEU Gannett Flemming AIA Library: Designing for All: A conversation around the Principles of inclusive architcture and accessibiilty

Green CE On Demand webinar Understanding the 2010 Accessibility Standards

Green CE On Demand webinar “ADA and Residential Facilities”

Green CE on Demand webinar: How Accessible is your work place

AIA U online course: “Applying the ADA on Existing and Altered Buildings”

We offer live online courses as well. If you are interested, please contact our office.

Visit our Resource Page that we are building to give you guidance on products and services

If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide”  “Applying the ADA” published by Wiley.

 

If you have any questions about these or any other topics, please feel free to contact me anytime.

Obscure Requirements for Accessibility

Monday, December 2nd, 2024

ADA Requirements on Grab bars

The 2010 ADA Standards has requirements for grab bars position gives a range on section 609.

  • For adults the top of the gripping surface of the grab bar should be between 33″ to 36″ a.f.f.
  • For children, the top of the gripping surface is required to be installed between 18″ and 27″ a.f.f.

609.4 Position of Grab Bars. Grab bars shall be installed in a horizontal position, 33 inches (840 mm) minimum and 36 inches (915 mm) maximum above the finish floor measured to the top of the gripping surface, except that at water closets for children’s use complying with 604.9, grab bars shall be installed in a horizontal position 18 inches (455 mm) minimum and 27 inches (685 mm) maximum above the finish floor measured to the top of the gripping surface. The height of the lower grab bar on the back wall of a bathtub shall comply with 607.4.1.1 or 607.4.2.1

But what it doesn’t state or require is that the grab bars must be at the same height. Below is a photo of an inspection where the grab bars were both installed at the children’s height, but one was at the 18″ range and the rear on was at the 27″ range. According to TDLR and The US Access Board, this is not a violation of the Standards.

 

The situation pictured above is not idea, but if both grab bars are between 18″ and 27″ a.f.f. it is compliant with the ADA and TAS.

Fair Housing Showers

The Fair Housing Design Guidelines has a requirement that states that if a unit only has a shower as the only bathing facility, then it must be a minimum of 36″x36″.

For the shower as the only bathing fixture: In both Specification A and B bathrooms, when a stall shower is the only bathing fixture in the covered dwelling unit it must be at least 36 inches x 36 inches in size.

This requirement would not allow a 30″x60″ shower as the ADA allows. But the requirements are not so clear. HUD (Fair Housing First) clarified that requirement and allow a shower that is less than 36″ wide as long as the total square inches meets or exceeds 36″x 36″ shower.

The photo above is the shower in a one bedroom unit and it is the only bathing fixture in the unit

The shower was 33″ x 60″ which has a square inches that exceeds 36″x36″ and therefore compliant.

Need Barrier Free CEUs?

We are currently scheduling our 1 HR HSW in person seminars for 2025

On Demand Online courses:

We offer live online courses as well. If you are interested, please contact our office.

Visit our Resource Page that we are building to give you guidance on products and services

If you want to learn more about these standards, be sure to check out my books:

The ADA Companion Guide” and “Applying the ADA” published by Wiley.

If you have any questions about these or any other topics, please feel free to contact me anytime.

September 2024:ADA Signage Location

Tuesday, September 3rd, 2024

The ADA regulations for singage location cover three things:

  1. Location relative to the door of the room it designates
  2. Installation Height of characters
  3. Clear floor space

This newsletter will explain each one and will give some examples of ambigous locations.

Scope of Coverage

The ADA has requirements on when a sign must comply with the Standards. These requirements are found in the scoping section 216. Not all signs must comply. Below are some of the signs that are required to meet certain minimum standards:

216.2 Designations. Interior and exterior signs identifying permanent rooms and spaces shall comply with 703.1, 703.2, and 703.5. Where pictograms are provided as designations of permanent interior rooms and spaces, the pictograms shall comply with 703.6 and shall have text descriptors complying with 703.2 and 703.5.

The picture above shows a sign for an office suite. Since these may not always be office (could be storage, conference rooms etc) This sign is not designating “permanent” rooms and do not have to comply

216.4 Means of Egress. Signs for means of egress shall comply with 216.4.

216.4.1 Exit Doors. Doors at exit passageways, exit discharge, and exit stairways shall be identified by tactile signs complying with 703.1, 703.2, and 703.5.

216.4.2 Areas of Refuge. Signs required by section 1003.2.13.5.4 of the International Building Code (2000 edition) or section 1007.6.4 of the International Building Code (2003 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1) to provide instructions in areas of refuge shall comply with 703.5.

216.4.3 Directional Signs. Signs required by section 1003.2.13.6 of the International Building Code (2000 edition) or section 1007.7 of the International Building Code (2003 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1) to provide directions to accessible means of egress shall comply with 703.5

216.6 Entrances. Where not all entrances comply with 404, entrances complying with 404 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1. Directional signs complying with 703.5 that indicate the location of the nearest entrance complying with 404 shall be provided at entrances that do not comply with 404.

 

The sign is a directional sign which provides information to the accessible entrance

Here are the sections referenced above and what they are about:

703.1- gives guidance for raised and tactile characters and braille

703.2- Gives the requirements for raised characters

703.3- Gives the requirements for Braille

703.4- Gives the requirements for Installation Height and Location of signage

Location of ADA Signage

The ADA requires that accessible signs be located alongside the door at the latch side:

703.4.2 Location.

  • Where a tactile sign is provided at a door, the sign shall be located alongside the door at the latch side.

The picture above shows the Accessible sign designating the permanent restroom was located next to the latch side of the door

The picture above shows the Accessible sign designating the permanent room was located next to the latch side of the door and it is either mounted on the side light or on the wall away from the glass. Either of those locations are acceptable.

The picture above shows the Accessible sign designating the permanent restroom was located next to the hinge side of the door

  • Where a tactile sign is provided at double doors with one active leaf, the sign shall be located on the inactive leaf.

The picture above shows the Accessible sign designating the permanent restroom was located next to the hinge side of the door

  • Where a tactile sign is provided at double doors with two active leafs, the sign shall be located to the right of the right hand door.

The picture above shows the Accessible sign at double doors with two active leaves designating the permanent room can be located at either side of the doors

  • Where there is no wall space at the latch side of a single door or at the right side of double doors, signs shall be located on the nearest adjacent wall.

The picture above shows the Accessible sign at walls outside the restrooms. The doors did not have enough room for a sign at the latch side so they can be located at the wall closest to the strike

The picture above shows the Accessible sign at the hinge side of the restroom door

The picture above shows the Accessible sign at walls outside the restrooms without doors. A cased opening will be similar to a door. The sign can be located anywhere along the wall.

Clear Floor Space to read the signs

ADA reqires that signage have a clear floor space of 18″x18″ beyond the swing of the door and centered below the sign.

  • Signs containing tactile characters shall be located so that a clear floor space of 18 inches (455 mm) minimum by 18 inches (455 mm) minimum, centered on the tactile characters, is provided beyond the arc of any door swing between the closed position and 45 degree open position.

The image above shows the reason why the 18″x18″ must be located beyond the swing of the door. This prevents a person from getting hit by the door as they read the sign.

The photo above shows the restroom sign next to the strike side of the door

The photo above shows the restroom sign 8″ from the door which is less than the 9″ min. required from the door the centerline of the sign.

The photo above shows the restroom sign between the wall and the drinking fountain.

The photo above shows the clear floor space less than 18″x18″. The drinking fountain is located inside the clear floor space

The p18″x18″ clear floor space must be located away from the swing of the door

The photo above shows the clear floor space less than 18″x18″. The drinking fountain is located inside the clear floor space

Can the sign be located on the door?

An accessible sign is required to be located on a wall alongside the latch side of the door. But there is one exception that allows the sign to be located on a door. If the door has a closer a sign can be located on the push side of the door.

EXCEPTION: Signs with tactile characters shall be permitted on the push side of doors with closers and without hold-open devices.

The photo above shows the sign located on the pull side of the door

Height of ADA Signage

The height of the sign is required to be mounted between 48″ to 60″ a.f.f. to the bottom of the raised characters

703.4.1 Height Above Finish Floor or Ground. Tactile characters on signs shall be located 48 inches (1220 mm) minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches (1525 mm) maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character

The photo above shows the sign mounted higher than 60″ a.f.f to the bottom of the raised characters

The photo above shows a sign with raised characters

The photo above shows a sign with raised characters mounted at 61 1/2″ a.f.f.

Summary

1) The location of the sign must be located on the wall closest to the strike side of the door of the room it designates

2) If there is no room adjacent the strike side, it is allowed to be located on a wall adjacent the door’s strike side

3) An 18″x18″ clear floor space and centered below the sign and located beyond the swing of the door must be provided.

4) At a double leaf door , the sign can be located adjacent eigher active leaf

5) At a double leaf with one active leaf, the sign can be located on the inactive leaf.

6) The sign may be located on a door provided that it is a push side approach and the door have a closer.

August 2024:Fixed and Built in Elements

Monday, August 5th, 2024

The ADA regulations for building access only apply to built-in or fixed elements. Movable furniture and movable equipment (unless scoped in the standards specifically) are not covered by the Standards and do not have any requirements.

Scope of coverage. The 1991 Standards and the 2010 Standards apply to fixed or built-in elements of buildings, structures, site improvements, and pedestrian routes or vehicular ways located on a site.

My colleagues get confused about these requirements, so I am sharing some examples of when these rule can be ambigous and how we can clarify the requirements.

When elements that are not built in or fixed are not required to comply

Movable furniture is not required to comply with the ADA. Even if the furniture is a reception desk, a dining surfaces, or benches. That means that they don’t have any regulations, but they cannot be used as an accessible element that is required.

The image above shows movable tables in a cafeteria at a school. Even though a school is required to provide areas for kids and faculty with disabilities to eat lunch just like everyone else, the fact that these are movable will exempt them from any requirements found in the standards.

The image shown above shows a dining area that is not only movable but raised higher than the ground. But because it is not built in it does not have to be on an accessible route and the table does not have to have a knee space

The image shown above shows movable classroom tables. Since they are not built in, they will not have to be at a certain height or have knee clearance.

The image shown above shows a system’s furniture reception desk with a service counter. Because it is movable, the counter will not be required to comply with the sales and service counter requirements.

Even though the banquette itself is not scoped in the Standards, and even though the tables at this dining area is movable and also not scoped, what is scoped because it is a built in element is the charging outlet that is provided at the banquette. Because that charging outlet is fixed or built in, it will be required to be within reach (15″ min. a.f.f.)

When elements that are not built in or fixed are used to provide cane detection to protruding objects

Movable furniture and elements cannot be used to create cane detection for persons who are visually impaired. Cane detection is required to be permanently available because if the movable element is moved the cane detection will not be there. Below are some examples.

The image shown above shows a movable table below a pendant light. The pendant light is technically located along a circulation path because the table is not considered permanently in the location shown. It could potentially move and therefore the pendant light would be located in the open circulation path.

The pendant light was mounted at 63″ a.f.f. and therefore considered a protruding object.

The image shown above shows movable planters that are being used as cane detection to the open stairs beyond

The image shown above shows movable trash can that is being used as a cane detection for the paper towel dispenser that is protruding onto the circulation path. since the trash can is movable, it cannot be used as cane detection.

Movable elements being used to provide accessibility when a buiilt in or fixed element is not compliant.

Becuse only fixed or built in elements are scoped and have requirements, movable elements cannot be counted as the accessible element instead of the built in element. Below are some examples

In this kitchen, there are two built in microwaves that are mounted higher than the allowable reach range. The owner decided to provide a movable microwave as the accessible element, but as we have explained, this microwave can be moved and not returned, therefore it cannot be used as the “accessible” element.

But in this kitchen there is only a movable microwave and it will not be required to be within reach.because it is not technically there.

The image shown above shows a movable shower seat. If a shower seat is required, it must be built in and not mvable.

The bench shown above is not bolted down and therefore not considered a substitute for the built in enches at the lockers

Which movable elements are scoped and required to comply?

Even though ADA only applies to built in or fixed elements, there are a few elements that are movable but also scoped. Below are some examples:

The image shown above are of washer and dryers. Even thought they are movable, they are also technically built in because it is connected to the wall via venting. But even if they were not, there is scoping for the equipment on section 611.

Even though a beverage dispenser could be considered movable, most of the time it is part of the plumbing and built in by way of the connection of the water line. But even if it wasn’t built in, beverage dispensers are scoped by the standards and requirements are found in section 904.

Exercise equipment are also “movable” but are scoped and have requirements in the standards. The requirmements for Exercise equipment is found in section 1004

June 2024: Location of Signage

Monday, June 3rd, 2024

Accessible Signage Location

The 2010 ADA (and other States standards like Texas) section 216 requires that signage that designates interior rooms that are permanent (which means that their function will not change in the future due to the fixtures within). Those signs must have raised characters and braille. Although pictograms and symbols are not required, if they are provided, they must also comply with the standards.

Some of the requirements are for height and location of signs. This newsletter will focus on that requirement and will provide examples of some problematic rules.

Height of the sign

The 2010 ADA states that the signs required to comply must have raised characters and there should be brailled that matches the words of the raised characters and located directly below the corresponding words.

703.2 Raised Characters. Raised characters shall comply with 703.2 and shall be duplicated in braille complying with 703.3.

The height of the sign is in relationship to the raised characters. In other words, the Standards require that the bottom of the raised characters be located between 48″-60″ a.f.f.

703.4.1 Height Above Finish Floor or Ground. Tactile characters on signs shall be located 48 inches (1220 mm) minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches (1525 mm) maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character.

Door Signage that has both name of room and room numbers must also meet the requirements. The bottom most baseline of the raised characters should not be mounted lower than 48″ a.f.f. and the top most baseline should not be mounted higher than 60″ a.f.f.

The sign is mounted higher than 60″ a.f.f. to the baseline of the raised characters

Where should the sign be located?

Signs have requirements on where they need to be located.

1. If it is provided at a door, they must be mounted alongside the door at the latch side. Although they are allowed to be located on the push side of doors with closers.

The sign must be located adjacent the latch side of the door. If there is a sign on the door, it can stay there as long as there is also a second sign where it is required

The sign should not be located on the door on the pull side of the door because if a person is reading it, the door could open and hit them

2. Where a tactile sign is provided at double doors with one active leaf, the sign shall be located on the inactive leaf.

3.. Where a tactile sign is provided at double doors with two active leafs, the sign shall be located to the right of the right hand door.

4..Where there is no wall space at the latch side of a single door or at the right side of double doors, signs shall be located on the nearest adjacent wall.

Sign located at the wall adjacent the latch/handle of the door

The wall beyond the swing of the door is less than 18″ and therefore the sign did not have the centerline at 9″ at the floor space beyond the arc.

The sign can be mounted to a glass wall if it is adjacent the latch side of the door

5..Signs containing tactile characters shall be located so that a clear floor space of 18 inches (455 mm) minimum by 18 inches (455 mm) minimum, centered on the tactile characters, is provided beyond the arc of any door swing between the closed position and 45 degree open position.

The ADA figure shows the 18″x18′ clear floor space at the sign. It must be centered at the sign and also located beyond the arc of the door.

The clear floor space of 18″x18″ was obstructed by a drinking fountain

The clear floor space at the sign was obstructed by a drinking fountain.

May 2024: Fair Housing Bathrooms

Monday, May 13th, 2024

Usable Bathrooms

In the Fair Housing Design Manual, Requirement 7 states that a covered dwelling unit must have usable bathrooms. The definition of usable bathrooms is not fully accessible, like the ADA or the ICC ANSI A117.1, but rather required to:

Bathrooms must be designed and constructed so a person in a wheelchair can maneuver about the space and use fixtures and appliances. The guidelines provide specifications for baths which, when applied, provide a minimum level of accessibility.

To create Fair Housing “usable bathrooms” there are just a few requirements that we must incorporate into our designs. But some can be a bit confusing. This newsletter will explain those requirements and give you examples of when the confusion occcurs. This newsletter will only cover the bathroom for the dwelling units and not the common and public spaces.

Definition of bathroom

In The fair housing defines bathrooms as a room:

“which includes a water closet (toilet), lavatory (sink), and bathtub or shower. It does not include single-fixture facilities or those with only a water closet and lavatory”

Therefore powder rooms will not be required to be “usable” as outlined in the Guidelines, except for a few requirements that will be listed below.

Examples of powder rooms

Usable Bathrooms Usable bathroom specifications include:

1. An accessible route to and into the bathroom with a nominal 32- inch clear door opening (Requirements 3 and 4).

“The Guidelines specify that kitchens and all bathrooms, including powder rooms, must be on an accessible route; therefore, no part of kitchens or bathrooms may be located in a raised or sunken area unless an accessible route can be provided to that area.”

This requirement applies to all bathrooms, and also to powder rooms when the powder room is the only toilet facility on the entry level of a multistory dwelling unit in an elevator building.

2. Switches, outlets, and controls in accessible locations (Requirement 5).

3. Reinforced walls to allow for the later installation of grab bars around the toilet, tub, and shower stall; under certain conditions provisions for reinforcing must be made in shower stalls to permit the installation of a wall-hung bench seat (Requirement 6).

Hotel Ballroom for conferences or events

These are the minimums sizes for blocking, but keep in mind that to install future grab bars for mobility, it is recommended that longer ones be installed for longer grab bars in the future.

4. Maneuvering space within the bathroom to permit a person using a mobility aid to enter the room, close and reopen the door, and exit (Requirement 7).

5. Maneuvering and clear floor space within the bathroom to permit a person using a mobility aid to approach and use fixtures; fixture dimensions and placement are specified under certain conditions (Requirement 7).

clearances at the different fixtures in the usable bathrooms

clearance at the toilet can have an obstruction, but only 24″ deep

showers can only have a parallel approach

In dwelling units containing more than one bathroom

Some dwelling units have more than one bathroom. So the question is, how many of the bathrooms have to be “usable”? The answer is it depends (gotta love that answer)

The fair housing gives us two choices: Spec A or Spec B

(This is not to be confused with Type A and Type B units that are described in the ICC ANSI A117.1. Those are different standards and requirements.)

If you choose Spec A bathroom layout then ALL the bathrooms have to meet the “usable” requirements.

If you choose Spec B then only one must be usable

If Specification A is selected as the basis for designing a bathroom, all bathrooms in the dwelling unit also must comply with the A Specifications.

Spec A Batrhoom

(plumbing fixtures all in the same wet wall. perpendicular approach at bathing allowed and facility and clear floor space beyond the door)

If Specification B is selected, only one bathroom in the dwelling unit must meet those requirements;

Spec B Batrhoom

(fixtures are in different wet walls. parallel approach at bathing facility and clear floor space beyond the door)

all other bathrooms in the dwelling unit must be

1) on an accessible route (Requirement 4),

2) have doors with a nominal 32-inch clear opening (Requirement 3),

3) have switches, outlets, and controls in accessible locations

(Requirement 5),

4) and have reinforced walls around toilets, tubs, and shower stalls (Requirement 6).

Spec B Batrhoom only one of the bathrooms required to be “usable”

but the others must be on an accessible route

February 2024: Inspector’s Corner

Friday, February 2nd, 2024

Edge protection at ramps

There is a standard that requires that the side edges of a ramp be protected from wheelchair casters from falling off the edge if the ramp edges are open and located 10″ above the ground. Edge protection along ramp runs and landings keep wheelchair casters and crutch tips on the surface and can be provided by curbs, barriers, or extended surfaces.

At one of my inspections yesterday, there was a ramp that had handrails alongside of low planter wall (so the edges were not open). But it also had a low bar that was mounted 4″ above the surface of the ramp. The additional edge protection was not required, since there was no drop off on either side of the ramp edges.

 

The ramp shown above had a low wall that acted as edge protection AND a low rail that was also intended to be edge protection.“

The photo above shows the low rail that was intended as edge protection. The ramp did not require it since the edges were not exposed.

Cane detection

When an object is located along a circulation path and mounted higher than 27″ a.f.f. , said object is not “cane detectable” (read last month’s newsletter which discussed Protruding Objects)

At one of my inspections yesterday, there were two examples of cane detection: one was not necessary and one was a good example of a prevention from becoming a protruding object.

Below are the two examples:

The photo above shows a diaper counter located along a circulation path in a restroom. It is a recessed type diaper counter with handles that project out onto the path. (the diaper counter was a Koala product)

 

But the handles are only 3 1/2″ from the mounting surface which does not make it a protruding object.

Once the diaper counter is down, and if it is left down, It could be a protruding object….but the handles are now below the counter and will act as cane detection.

The photo above shows the handles below the counter that are mounted lower than 27″ a.f.f. and act as cane detection.

The photo above shows a drinking fountain located in an alcove. It is not technically protruding onto a circulation path and the walls on either side of the drinking fountains act as cane detection. So the cane detectable apron installed under the “high” drinking fountain was not required.

January 2024: Protruding Objects

Wednesday, January 3rd, 2024

BECAUSE IT WAS A PROTRUDING OBJECT

What is a protruding object?

Most of the rules in the 2010 ADA Standards for Accessible design seems to be relating to people who use wheelchairs. But the guidelines apply to other disabilities besides mobility. There are guidelines to assist person who are hearing impaired, congnitively impaired as well as visually impaired.

People who are visually impaired use the built environment to find the way. They might use a cane to “feel” objects which will guide them and will assist them to avoid any hazards. People who use a cane can only detect objects that are located along their circulation path and mounted BELOW 27″ a.f.f.

A circulation path is not the same as an accessible route.

When you see the words “accessible route” in the ADA Standards it is describing the path a person in a wheelchair would use to get around. When you see the words “circulation path” in the ADA Standards it describes any path that a pedestrian would take regardless of disability. Most of the time, the circulation path applies to persons that are visually impaired.

People who are visually impaired use the built environment to find the way. They might use a cane to “feel” objects which will guide them and will assist them to avoid any hazards. People who use a cane can only detect objects that are located along their circulation path and mounted BELOW 27″ a.f.f.

Anything that is mounted ABOVE 27″ a.f.f. or below 80″ a.f.f. could be considered a protruding object IF it is more than 4″ from the mounting surface.

 

But are any object that extends more than 4″ from its mounting surface a “protruding object”?

No….only if they are also located in a circulation path.

A circulation path in the ADA is not the same as what we design professionals think of a circulation path. We think of it ONLY as corridors, walkway, elevators, stairs….

A circulation path in the ADA describes ANY place that a able bodied pedestrian will be going. This would include the path you would take to go from the doorway to the toilet inside a restroom, the path from the toilet to the sink inside a restroom, the path from a doorway to your seat in a conference room or classroom, the path from one room to a different room etc.

The photo above is showing a drinking fountain in a circulation path from one room to another

Some people ask me, but there is plenty of room in the middle of the corridor where the drinking fountain does not protrude…..Yes, but a person who is visually impaired who uses a cane to find their way is trained to walk close to the walls in order that they can tap the cane on a surface which will gude them to where they are going. So the middle of the corridor would not be THEIR circulation path.

The photo above is showing a diaper counter located in the circulation path to the toilet compartments as well as the exit door. It also projects more than 4″ onto that circulation path making it a protruding object.

The photo above is showing a pendant light fixture mounted lower than 80″ a.f.f. and in a circulation path from one side of the room to the other. But you might say that there is a seat located right below it. Unless that seat is FIXED or BUILT IN it does not constitute a cane detectable element because it could be moved from that location. Only permanent elements will be able to be used as cane detection.

 

The drawing above is showing a plan of a lavatory located on the way to the urinals and showers at this lavatory might be a protruding object if the leading edge is mounted higher than 27″ a.f.f. which is possible since the knee space for a lavatory is required to be a minimum of 27″ a.f.f.

The floor plan above is showing a set of drinking fountains in an alcove. It appears as though the alcove puts them away from the circulation path, but because the alcove is wide a person who is visually impaired could accidentally walk into the drinking fountain if one of the leading edges are higher than 27″ a.f.f.

The photo above is showing a clock mounted on a wall in a corridor of a school and lower than 80″ a.f.f.. The clock is a hazard to people who are visually impaired because it protrudes more than 4″ onto the circulation path.

 

The photo above is showing stair with exposed risers and treads. There is no cane detection and a person who is visually impaired could bump their head on the edges.

There are some requirements that sometimes get mistaken for protruding objects. For example, there is a rule that forbids certain objects to overlap the clearance of the toilet in a restroom. Designers might think that the rule pertains to protruding objects and as long as the object within the clearance of the toilet is less than 4″ it is allowed to overlap.

That is not correct.. The protuding object rule, remember, has to do with persons who are visually impaired. The requirement at the toilet has to do with persons in wheelchairs where such objects would prevent them from easily transfer onto the water closet.

The photo above is showing a paper towel dispenser that is overlapping the clearance around the toilet. This is NOT a protruding object because it is not lcoated in a circulation path. The paper towel dispenser is located between the toilet and the lavatory which both act as cane detection away from the paper towel dispenser. This however is a violation of the overlap rule for toilets (ADA section 604.3.2)

Some Solutions

Below are some solutions to resolve the protruding objects.

The figure above shows a way to provide cane detection by using a rail below an open stair

The photo above shows a rail below an open stair that acts as cane detection

 

The figure above shows a way to provide cane detection by using a rail below an open stair

The photo above trash receptable mounted below the paper towel dispensers that are protruding more than 4″ onto a circulation path inside the restroom. This trash receptible reaches below 27″ a.f.f. which makes it cane detectable.

 

The photo above shows a cane detectable apron that is an accessory you can specify to be installed below the leading edge of the high drinking fountain. The cane detectable apron should be mounted exactly at 27″ a.f.f. so that it acts as cane detection and allows the wheelchair drinking fountain to have the required knee clearance.

The photo above shows panels on either side of a wall mounted counter which acts as cane detection

 

The photo above shows a furred out wall that acts as cane detection to the wall mounted TV located in a circulation path.