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.


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.

Accessible operable parts and mechanisms

Tuesday, July 3rd, 2018
One of the guidelines that seem to be misunderstood is for operable parts.  This guideline requires that an accessible operable part have a mechanism that allows for operating or use without tight grasping or pinching, twisting of the wrist, with less than 5 lbs of force and to operate using only one hand.
ADA section 309.4 Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.
Why this is required?
There are persons that don’t have proper use of their hands.  People with rheumatoid arthritis for example, or cerebral palsy, have a hard time grasping elements.  Also, there are people, like amputees, or people that were born without hands or fingers that cannot operate elements which require tight pinching.  In addition, some people with disabilities or older people may not have the amount of strength required to operate an element or activate an operable part if the force required is more than 5 lbs.  Therefore, the ADA design guidelines provides rules to assist those people to navigate their environment in an equal manner.


Operable parts on accessible elements, accessible routes, and in accessible rooms
and spaces shall comply with with the standards.  There are some exceptions which explain that certain operable parts do not have to comply:
1. Operable parts that are intended for use only by service or maintenance personnel
2. Electrical or communication receptacles serving a dedicated use (like a refrigerator)
3. Where two or more outlets are provided in a kitchen above a length of counter top that is uninterrupted by a sink or appliance, one  outlet shall not be required to comply
4. Floor electrical receptacles
5. HVAC diffusers
6. Except for light switches, where redundant controls are provided for a single element, one control in each space  shall not be required to comply 
7. Cleats and other boat securement devices
8. Exercise machines and exercise equipment
9. Operable windows that are only operated by staff and not occupants
There is an advisory  that gives us more guidance and explanation;
205.1 General. Controls covered by 205.1 include, but are not limited to, light switches, circuit breakers, duplexes and other convenience receptacles, environmental and appliance controls, plumbing fixture controls, and security and intercom systems.
Section 309 
Operable parts have three requirements:
1) They must be within reach ranges as spelled out in the Section 308
the operable part of the coffee maker must be no higher than 48″ a.f.f.
2) They must have a 30″x 48″ clear floor space to reach the operable part as specified on 305.  The clear floor space should have a slope no steeper than 1:48 (2%) in all directions.
the slope at the push button door opener was steeper
than 2%
3) and the operable part should be the type that will not require tight grasping and twisting of the wrist and no more than 5 lbs, like explained before.
this feminine napkin dispenser operable part requires tight grasping and pulling to operate
this faucet has an operable part that requires graping and twisting to activate
Below are some more examples.

Fire Extinguisher cabinet

I get this question a lot about fire extinguisher cabinets:
“Do we mount the cabinet so that the top of the fire extinguisher is between 15″-48″ a.f.f.?”
The answer is no.  The reach range is for “operable parts” of fixed elements.  So a fire extinguisher would not be the operable part, but the handle to open the cabinet would be.  So one should locate the fire extinguisher cabinet door handle between 15″-48″ a.f.f.
the operable part is the handle to open the cabinet door

Emergency Nurse calling

Another operating mechanism that is confusing is the emergency call button located in medical care facilities and long term care facilities. They are used when a patient or resident needs a nurse.  They are typically located next to the toilet and in the shower and they are required to have a string that reaches the floor.  The string is used if a patient or resident falls and they need to pull the string if they can’t get up.
this call button has a red lever that can be pushed down with a closed fist which has a compliant operable part
this call button also has a lever that can be pushed down with a closed fist which is a compliant operable part
this call button is only able to be activated by grasping and pulling the string. This would not meet the requirements for accessible operable parts
In order for the call button to be compliant, it must not only have the string, but it should have a second way of calling the nurse which will not require tight grasping and pulling.

Adjustable mechanism at the hand held shower

One of the operating mechanism that is forgotten is the one required to adjust a hand held shower unit.
the hand held unit height can be adjusted using the wheel next to the vertical bar.  The wheel requires tight grasping and twisting to
operate it and therefore not a compliant operating mechanism.
Once the height is adjusted, the mechanism to loosen or tighten the adjustable part is not always used again.  But the initial action to adjust must meet the requirements.  So the adjustable mechanism must also comply.
this mechanism does not require tight grasping to loosen or tighten
this adjustable mechanism requires pinching to loosen

Need Barrier Free CEUs?

We are giving classes in the following locations:
Metrocon18-Dallas Texas
Online courses:
Green CE On Demand webinar “How Accessible is Your work place?”
Green CE On Demand webinar “ADA and Residential Facilities”
If you want to learn more about these standards, be sure to check out my books:

Revisiting Shower Seats

Thursday, March 1st, 2018

Shower seat installation, location and the effects of shower controls and other elements

Seats are not always required at bathing facilities, but there are some situations that will require showers seats to be added.  For instance, a transfer shower always requires a seat. Also, in transient lodging facilities (hotels, halfway houses, dorms), a seat is required not only in transfer showers but also in roll-in showers.

The shower must be permanently attached to the shower and not be movable.  The one exception will be at residential facilities which require blocking for future seats.

This article will explain how the seat should be installed and how it affects the location of controls and other elements.

Shower Seat: Scoping

There are two types of showers: Transfer showers and roll in showers.  Transfer showers are one’s people with mobility impairment will “transfer” onto.  Roll-in showers are the ones that a person in a wheelchair will roll their wheelchair into.

ADA Section 608.4 requires permanent shower seats in transfer showers.

  1. These must be either folding or not folding seat.
  2. The only exception is for residential dwelling units required to comply with ADA (not Fair Housing). Reinforcement in the wall for the future installation shall be provided instead.

Roll-in showers are not required to provide a shower seat per section 608.4.  There are two exceptions where seats are required to be provided in roll-in showers:

  1. In social service establishments (i.e. homeless shelters) with more than 50 beds. (per DOJ’s Subpart D of 28 CFR Part 36) AND
  2. In transient lodging guest rooms with mobility features
  3. If a seat is provided in a roll in shower, either by choice or because it is required as stated above, the seat must be permanent and folding.  This allows a person to either use the shower as a transfer type with the seat or as a true roll-in-shower without the seat in the way.
  4. The same technical requirements must be provided as in a transfer shower with a seat (see next entry)

This photo shows a folding seat mounted on a roll in shower.  The controls are located in the correct location, but there is a grab bar above it.  A grab bar should not be provided where the seat is located.

This shower was intended as a roll in shower, but the seat provided is not “folding”, therefore a person in a wheelchair could not roll in and use it easily.

Shower Seats: Technical

Sections  610.3 describes the types of seats allowed at showers.  There can be a rectangular seat or an “L-shape” seat:

1) Where a seat is provided, the seat shall extend from the back wall to a point within 3″ of the compartment entry.

This seat did not extend from the back wall to 3″ of the entry

The seat is 9″ away from the entry

Sometimes, the seat is located around a gyp wall and the shower sits back a few inches.  So do we consider the wing wall part of the shower when measuring the location of the seat?  According to the Texas Department of Licensing, the shower begins at the shower pan and therefore the wing wall is not counted as part of the shower.

This shower seat is located 3″ away from the shower pan which is technically where the shower entry begins.  The gyp wall extension is not technically part of the shower.  We recommend that if at all possible, you make the shower pan flush with the wall.

2) The top of the seat shall be 17″-19″ above the bathroom finish floor.

3)They can be rectangular meeting figure 610.3.1

This seat is 4″ away from the end wall rather than 1 1/2″ max

4) Or they can be “L-shape” meeting figure 610.3.2

5) The structural strength should be able to sustain 250 lbs of applied force on the seat, fastener, mounting device or support structure.


Roll-in Showers

 There are two types of roll in shower configurations allowed by the ADA.  The shower seat location in these showers will dictate where the controls and grab bars will be located.

The Standard Roll-in shower with seat:

The alternate shower with a seat.  An alternate shower is a combination of a transfer shower and roll in shower, so it is larger in depth than a standard roll-in shower.

The photo above shows an alternate roll-in shower


Depending on where the seat is located, the controls must be located no farther than 27″ away from the seat.


Clear Floor Space

In order to transfer onto the seat, there should be a clear floor space that meets the requirements at 305 parallel to the shower seat.  The requirements include the size to be 30″x48″ and that the slope is not steeper than 1:48.

This shower has a ramp transition up to the entry which creates a slope steeper than 1:48 at the clear floor space of the seat
This shower entry into a transfer shower has a sloped entry which would have been acceptable if the clear floor space would have been 30″ deep. The slope begins with that 30″ making the slope steeper than 1:48.

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Fair Housing

Monday, February 1st, 2016

Which projects have to comply?

The Federal Fair Housing Act covers newly constructed multi-family housing projects that are first time occupancy residential.  The projects must also have more than four dwelling units.  In an a building with elevators, ALL dwelling units must comply with the guidelines.  In a building without an elevator, only the first floor units must comply.  If the building is only two story units, then none of them must comply.
In addition to the Fair Housing Act, some municipalities have also adopted the ANSI A117.1 for their residential dwelling units.  These dictate that a certain percentage must be built as with mobility features (for the mobility impaired) and a percentage with communication features (for the hearing and visually impaired)

Seven Requirements

The Fair Housing Act Guidelines have seven requirements for the covered residential dwelling units.  Here is the definitions.  This newsletter will just give an overview and will not describe all the details for each requirement.  We will plan to explain in more detail in future newsletters:
Accessible Building Entrance on an Accessible Route:
Covered multifamily dwellings must have at least one building entrance on an accessible route, unless it is impractical to do so because of terrain or unusual characteristics of the site. For all such dwellings with a building entrance on an accessible route the following six requirements apply.
Accessible and Usable Public and Common Use Areas:
Usable Doors:
All doors designed to allow passage into and within all premises must be sufficiently
wide to allow passage by persons in wheelchairs.
Accessible Route Into and Through the Covered Dwelling Unit:
Light Switches, Electrical Outlets, Thermostats and Other Environmental
Controls in Accessible Locations:
All premises within the dwelling units must contain light switches, electrical outlets, thermostats and other environmental controls in accessible locations.
Reinforced Walls for Grab Bars:
All premises within dwelling units must contain reinforcements in bathroom walls to allow later installation of grab bars around toilet, tub, shower stall and shower seat, where such facilities are provided.
Usable Kitchens and Bathrooms:
Dwelling units must contain usable kitchens and bathrooms such that an individual who uses a wheelchair can maneuver about the space.

Inspector’s Corner

Requirement 1 of the Fair Housing Act states that an accessible entrance is required to the dwelling units.  This photo shows three steps up to the stoop which leads to the entrance, and no ramp or lift to get them to the stoop.  This unit does not meet the requirement.


Need CEUs

February 24th: “How Accessible is Your Work Space” at Herman Miller Showroom in Dallas, Texas
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:

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

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Private Bathrooms

Wednesday, July 1st, 2015

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.


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 shall 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 the proper floor clearance, but the flush control and the toilet paper dispenser were not correctly located 


The toilet in this photo does not have the proper floor clearance per 604 nor is the toilet paper dispenser mounted at the proper location


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.


Because a private bathroom does not require a knee space at the sink, a pedestal sink can be used.  The mirror on the other hand must be mounted at 40″ a.f.f. to the bottom of the reflective surface.

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.


This shower doesn’t have a seat or a handheld shower unit.  In addition there is a door which doesn’t have clearance on the interior of the shower 

Upcoming Continuing Education Opportunities


Tuesday July 21st from 3:00-4:00 CST “Understanding the 2010 ADA Standards” Provided by Green CE

Thursday July 23rd

Sit in a wheelchair for a Day!  Join several of your fellow architects in Dallas and experience what a person who uses a wheelchair experiences.  For more information contact Marcela Rhoads at

Friday July 24th ALL DAY!  Join Us!!!

Marking the 25th anniversary of the ADA, July 24th will be ADA Awareness day in Dallas Texas.  The AIA Dallas’s Codes and Standards committee is planning a day full of great programs.  Stay tuned.  If you want to be a sponsor, let me know.


Thank you to our Sponsors: Andres Construction, Access by Design and

Abadi Accessibility

If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes

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. 


 They are available for sale now. (also available as an e-book)
If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714
Useful Links



Accessible Residences

Sunday, March 24th, 2013

In the new ADA there are residential scoping and technical guidelines.  But these guidelines only deal with Federally funded housing, residences in places of education or social service establishments that have dwelling within.  Other residential facilities, do not fall under the ADA, but Fair Housing or Model Codes.  There are four types of residential projects, but only two are required to follow the ADA Standards.

  1. Single Family Housing
  2. Multi-Family Housing
  3. Federally funded multi-family housing
  4. Residential facilities as defined by ADA

This newsletter will explain single and multi-family housing that are not required to meet ADA Standards.

Privately funded Multi-Family Housing

The Fair Housing Act requires that any multi-family project be made accessible to the disabled community. Therefore the owner of a multi-famly property cannot discriminate against a family or individual who is disabled on the grounds that the property is not accessible.

ALL multi-family housing projects are required to be accessible per the Fair Housing Act.  This includes apartment complexes, and even condominiums as long as there are four or more units in the property.


Here are the requirements from the fair housing act guidelines:

– At walk-ups (no elevator) ALL ground level units must meet the requirements

–  in an elevator building ALL units must meet the requirements

Building code and ADA does have percentages for how many units are required to be fully compliant vs. adaptable, but fair housing does not.  Therefore all units must be designed using the minimum guidelines listed below.

There are seven requirements:

1) Accessible building entrance on an accessible route: At least one entrance into the building or unit


2) Accessible and Usable public and common use areas: Places such as parking lots, mail boxes, recreational area, lobbies, laundry areas, community building must be accessible and usable.


3) Usable doors: all doors that allow passage must be wide enough (32″ nominal) and the main entrance must have proper hardware


4) Accessible route into and through the covered dwelling unit


5)  Light switches, Electrical outlets, thermostat and other environmental controls in accessible locations


6) Reinforced walls in bathrooms for future installation of grab bars


7) Usable kitchens and bathrooms: Should be designed and constructed so an individual in a wheelchair can maneuver in the space provided.  No knee clearances are required




To understand more in detail the requirements, visit the Fair Housing Act website or click here for the Design Manual

Single Family Housing

Single family homes, duplexes, triplexes and multi-story townhouses  are not required to be accessible by any accessibility standards. Therefore any single family home development are essentially exempted from having to be accessible to the disabled.

A new movement called “Aging in Place” are advocating for remodeling or retro-fitting homes in order to make them more usable to the disabled and more universally designed so that families can stay together as they age. Below are some of the enhancements we did in a kitchen of a family with a disabled mother and son.  It is also good for their able body husband.

Before the upgrades:



After the upgrades:




Inspector’s Corner

This was a remodel of a single family home.  We installed a pull down shelving which made the shelves within reach range


Click here to watch the video of pull down shelving

For more information

If you want to learn more about the new Standards, The ADA Companion Guide explains the 2004 ADAAG Guidelines  with commentary and explanations throughout.  The 2004 Guidelines were adopted by the DOJ to create the 2010 Standards and by Texas to create the 2012 TAS.  This book explains the technical requirements for both.

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

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Technical Memos

Monday, December 24th, 2012

The Texas Department of Licensing and Regulation regulates the Architectural Barrier Act and the Texas Accessibility Standards in Texas.  They also issue memos that explain certain ambiguous terms and concepts in the Standards.  They have issued four so far to explain the 2012 TAS.  This newsletter explain them.

TM 2012-01 Electrical Vehical Charging Station

The Technical Memorandum TM 2012-01 has requirements for Electrical Vehicle Charging Station.

Because the US Department of Justice have not issued guidelines for Electric Vehicle Charging station, TDLR decided to create one.  So in Texas this is the requirements:

Twenty percent (20%) but not less than one, of each type of charging station in each cluster on a site shall meet the following criteria:

  1. Controls and operating mechanisms for the accessible charging station shall comply with TAS 309 (no twisting of the wrist and less than 5 lbs to operate) and shall be within the forward reach ranges specified in TAS 308.2;
  2. The vehicle space(s) with the accessible charging station shall be at least 96 inches wide and shall provide a 36 inch wide (minimum) accessible route complying with TAS  402 on both sides of the vehicle space to allow the user adequate space to exit their vehicle and access both sides of the vehicle. Striping of the accessible routes is recommended but not required.
  3. Directional and informational signage complying with TAS 216.3 shall designate the location of the accessible charging stations.  The symbol of accessibility is recommended but not required.


This figure is just one example.  There might be other ways to meet the requirements

TM 2012-02 Emergency Response Building and Facilities

The Technical Memorandum TM 2012-02 explains what to do with facilities for emergency response personnel.  This was taken from the US Access Board and DOJ Commentary.  There are basically Three type of areas within emergency response facilities:

  1. Crew quarters that are used exclusively as a residence by emergency response personnel and the kitchens and bathrooms exclusively serving those quarters shall comply with the requirements of 233 (including 233.3.1) and 809 for residential facilities and residential dwelling units.
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  3. All other common use areas, elements, and spaces, including, but not limited to, parking, drinking fountains, public restrooms, meeting and training rooms, and conference rooms, shall comply with the 2012 TAS.  Multi-story buildings and facilities shall comply with the accessible route requirements found in 206.2.3 unless exempted by 206.2.3, Exception 2, which states that in a public building that is less than three stories with less than 5 occupants on the upper or lower story, an accessible route is not required.
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  5. Truck bays, workshops, and other employee work areas, elements, and spaces used exclusively by emergency personnel for work shall comply with 203.9 and other provisions of the 2012 TAS applicable to employee work areas which state only approach, enter and exit is required.
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TM 2012-03 Shopping Centers and Shopping Malls

The Technical Memorandum TM 2012-03 explains what defines a shopping center or shopping mall and how this affects the elevator/accessible route exception.

The definition of a shopping center is:

a) A building housing five or more sales or rental establishments; or

b) A series of buildings on a common site, either under common ownership or common control or developed either as one project or as a series of related projects, housing five or more sales or rental establishments

If a private building is a shopping center and has more than one story, an accessible route is required, no matter what is going on on the second story.

But there is an exception if it is a retail space in a one story building with a mezzanine.

A free standing store, like Walmart is not a shopping center and therefore a mezzanine may not require an accessible route if it meets all the criteria on 206.2.3 Exception 1 or 206.2.4 Exception 3.


This photo is of a retail story with a second story and it does require an accessible route to the second story.

TM 2012-04 Multi-Story Buildings and Facilities

The Technical Memorandum TM 2012-04 explains what is meant by “square feet” and “per story” in 206.2.3, Exception 1:

  1. Square Feet. The reference to “square feet” shall mean gross square feet.
  2. Per Story. The term “story” is defined  in 106.5.64  as that portion of a building or facility designed for human occupancy included between the upper surface of a floor or the upper surface of the floor or roof next above.  A story containing one or more mezzanines has more than one floor level.
  3. Therefore, based on 106.1 and the indicated meaning of “story”, the reference to “per story” shall also apply to the first story when calculating square footage.

    These clarifications have been confirmed by the Department with the U. S. Access Board and do not constitute a substantive change to the compliance requirements of 206.2.3, Exception 1.


    Continuing Education Opportunities

    New Orleans

    4 hr HSW: 2010 ADA and IBC

    Please use this link below for registration and details

    Little Rock

    4 hr HSW 2010 ADA and IBC

    Please  use this link below for registration and details

    If you want to learn more about the new Standards, The ADA Companion Guide explains the 2004 ADAAG Guidelines  with commentary and explanations throughout.  The 2004 Guidelines were adopted by the DOJ to create the 2010 Standards and by Texas to create the 2012 TAS.  This book explains the technical requirements for both.

     If you have any questions about these or any other topics, please feel free to contact me anytime.
    Marcela Abadi Rhoads, RAS #240
    Abadi Accessibility
    214. 403.8714