Bathrooms
Thursday, June 1st, 2023
I have had several projects latetly where my clients have asked me to write them a letter that explains that their project was excempted from having to be reviewed or inspected because they were not “alterations”. One of them said that all they were doing was MEP upgrades and “finishes”. That made me question their request….
- What finishes?
- Where are the MEP upgrades occurring?
- Were they just doing mechanical and electrical upgrades?
- or werer there also plumbing changes involved?
- Were they installing new lighting or light switches as part of the upgrades?
- What finishes? painting, flooring, new cabinetry?
The concept of “alterations” is a confusing concept for most of us. The basic confusion is what is an alteration? The answers to my questions above would have given me some clarity. In the ADA and TAS an “alteration” has a specific (not so specific) definition. And in the definition it also tells you what is NOT an alteration. I will put the definition below and then I will explain why the request was not able to be fulfilled.
Alteration: A change to a building or facility that affects or could affect the usability of the building or facility or portion thereof. Alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, resurfacing of circulation paths or vehicular ways,
changes or rearrangement of the structural parts or elements, and changes or rearrangement in the plan configuration of walls and full-height partitions.
Below are some examples:
Reconstruction….even if it is demolishing something and re-building it EXACTLY IN THE SAME PLACE….or as my clients like to explain…BUILDING IT IN KIND….it is still an alteration.
Reconstruction of a cabinet even it is going to be put back exactly where it was, will be considered an alteration.
Reconfiguration of a floor plan, by either removing walls, adding or re-building walls, adding or re-building millwork (even if it was there before) is an alteration.
Historic Restoration, depending on what is being restored might be considered an alteration. If it happens in the vertical plane or the ceiling it may not because it may not affect the usabilitity.
“
The definition of alteration, includes “re-surfacing of circulation paths”. This would include flooring. Even if the flooring is being replaced “IN KIND” with the same material that was there before….it is an alteration.
Removing toilet partitions and replacing them is an alteration. Be careful when re-installing them. If they were not compliant before, they will need to be compliant at the time of installantion.
Rebuidling toilet compartments will require that they comply. Even if they were put back exactly where they were, it is an alteration. The wheelchair accessible toilet compartment will have to comply with the standards even if it did not originally. DON’T ASSUME THEY WERE COMPLIANT BEFORE
In an alteration, the standards only requires that the element that you are altering be compliant. In this project, they were only replacing the lavatory, therefore the lavatory is the only thing in the restroom that will need to comply at the end of the project.
In this restroom, all the elements were removed and will be re-built. Even if they are all going back exactly where they were before, each new element will have to comply with the standards.
Therefore when alterations ocur based on the definition, it will trigger ADA and TAS to be applied. Everything that is newly installed will have to comply.
The definition continues with this clarification:
Normal maintenance, reroofing, painting or wallpapering, or changes to mechanical and electrical systems are not alterations unless they affect
the usability of the building or facility.
Replacing one or two damaged carpet tile would be considered maintenance. Replacing an entire carpet would an alteration.
painting is not an alteration because it does not affect the usability of the building for persons with disabilities
changing ceilings is NOT an alteation becuase it does not affect the usability
adding pendant light fixtures could affect the usability, therefore adding them to an existing space will be an alteration.
replacing a broken toilet, may be considered “maintenance” if it does not require a permit and other elements are being altered. This will need to be evaluated on a case by case basis.
Alterations in Areas that contain a Primary Function:
Once you determine that your project is an alteration, then we have to explore where it happens? Is it located inside an area of your facility that is considered to have a function that is a major activity to the facility? This area would be considered a “primary function” according to the ADA and TAS
Definition of: Primary Function. A major activity for which the facility is intended. Areas that contain a primary function include, but are not limited to, the customer services lobby of a bank, the dining area of a cafeteria, the meeting rooms in a conference center, as well as offices and other work areas in which the activities of the public accommodation or other private entity using the facility are carried out.
If the area you are altering is considered a primary function, then Section 202.4 will apply:
202.4 Alterations Affecting Primary Function Areas. In addition to the requirements of 202.3, an alteration that affects or could affect the usability of or access to an area containing a primary function shall be made so as to ensure that, to the maximum extent feasible, the path of travel to the altered
area, including the parking areas, rest rooms, telephones, and drinking fountains (and in Texas they added parking) serving the altered area, are readily accessible to and usable by individuals with disabilities, unless such alterations are disproportionate to the overall alterations in terms of cost and scope.
Mechanical rooms, boiler rooms, supply storage rooms, employee lounges or locker rooms, janitorial closets, entrances, corridors, and restrooms are not areas containing a primary function.
break rooms are not considered a “primary function”. If any renovation occurs inside the break room, it will not trigger the “path of travel” elements to be in compliance
restrooms are not considered a “primary function” except in rest stops. If any renovation occurs inside the restrooms (other than at rest stops), it will not trigger the “path of travel” elements to be in compliance
parking is not the “primary function” of a facilty and therefore will not trigger compliance with the path of travel elements.
Alterations that affect the usability of or access to an area containing a primary function include, but are not limited to:
(i) Remodeling merchandise display areas or employee work areas in a department store;
(ii) Replacing an inaccessible floor surface in the customer service or employee work areas of a
(iii) Redesigning the assembly line area of a factory; or
(iv) Installing a computer center in an accounting firm.
For the purposes of this section, alterations to windows, hardware, controls, electrical outlets, and signage shall not be deemed to be alterations that affect the usability of or access to an area containing a primary function.
Then the existing elements located within the path of travel will have to comply. This requirement comes from the alteration section 202.4
The figure above shows a visual of the “path of travel” elements. The existing path of travel to the altered area will have to comply in this project (EVEN IF IT IS NOT PART OF THE ORIGINAL SCOPE OF WORK) because it serves the altered area which occurs in an area that contains a primary function. The ADA and TAS requires that at least 20% of the construction budget is used for barrier removal and ADA upgrades.
I hope this newsletter made some of these items a bit more clear. This topic is very confusing and frustrating…if you have more questions, feel free to reach out.
Monday, April 3rd, 2023
Accessible signage can be a very confusing topic. Even after all these years of practicing my accessibility consulting, I am still learning a thing or two. Sadly they can even be confusing to signage manufacturers and installers.
Accessible signs require the following things:
- Raised and Brailled Characters
- Contrasting background
- San Serif Fonts
- Height and location
- If using Pictogram, there are requirements
- If depicting accessible spaces the use of the ISA (International Symbol of Access)
This newsletter will focus on a few common errors I encounter during my inspections mainly about Raised and Braille characters, contrasting background and location
Raised Characters
The accessible signage will require that the characters describing the space whether it be a number or letters, must be raised. They should be at least 1/32″ above the surface of the sign.
This graphic shows the minimum requirement for the raised characters of a sign.
There should also be Braille below the words that states the same words that are provided. So all words and numbers should be duplicated by Braille
The restroom had a painted sign on the door but the characters were not raised and it did not have brailled as a duplicate. This is not compliant
This restroom has more than six toilets and urinals combined, therefore one compartment should be for wheelchairs and one compartment should be for other mobility devices (ambulatory)
Contrasting Background
At one of my inspections I encountered some signs that were all white. The raised characters were white as well as the background. The raised characters and the background were too similar in color and therefore there was no adequate contrast.
The requirement for contrasting color is intended for people with low vision. The sign would be too difficult to read without contrast.
The sign shown above did not have the required contrast between the raised characters and the background
Location
Signage that identify permanent rooms must be located on the latch side of the door or as close as possible on the latch side of the door. It must be located between 48″-60″ to the bottom of the raised characters and there must be a floor space of 18″x18″
The sign shown above did had a drinking fountain at the floor area and did not have a clear 18″x18″ at the floor in front of the sign
In addition to permanent rooms, signage with Braille and raised characters must also be located at Exit Stair, Exit Passage Way and Door
ADA Section 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.
In addition to permanent rooms, signage with Braille and raised characters must also be located at Exit Stair, Exit Passage Way and Door
ADA Section 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.
When are accessible signs NOT required?
Not all signs have to meet the accessibility guidelines. Here are the ones that do not required raised characters, brailled etc.
1. Building directories, menus, seat and row designations in assembly areas, occupant names, building addresses, and company names and logos shall not be required to comply with 216.2.
2. In parking facilities, signs shall not be required to comply with 216.2, 216.3, and 216.6 through 216.12.3.
3. Temporary, 7 days or less, signs shall not be required to comply with 216.4. In detention and correctional facilities, signs not located in public use areas shall not be required to comply with 216
Wednesday, March 1st, 2023
One of my clients inspired me to write this newsletter. She asked me how many toilets needed to be accessible by the 2010 ADA/2012 TAS. This newsletter will cover multi-user restrooms, single user restrooms and restrooms that could be used for both adults and children.
Multi-User Restrooms
In a multi-user (Gang restroom) one of the toilet compartments must have an accessible toilet used for wheelchairs. The size depends on whether the toilet is wall hung or floor mounted. Also if you are designing for children and they will be the primary user, then the size will be similar to having a floor mounted toilet even if you use a wall mounted. See the figure below
The ADA and TAS has an advisory describing what is a toilet compartment:
Advisory 213.3.1 Toilet Compartments. A toilet compartment is a partitioned space that is located within a toilet room, and that normally contains no more than one water closet. A toilet compartment may also contain a lavatory. A lavatory is a sink provided for hand washing. Full-height partitions and door assemblies can comprise toilet compartments where the minimum required spaces are provided within the compartment.
This is the figure found in the 2010 ADA and the 2012 TAS that shows the size of the wheelchair toiilet compartment.
This photo shows mulitple toilet compartments. Only one compartment will have to be provided for wheelchair users. And there are more than six toilet compartments which also requires an ambulatory compartment.
What is an Ambulatory compartment?
If the restroom has six or more waterclosets/toilets and urinals then the ADA and TAS requires that an ambulatory toilet compartment be provided IN ADDITION TO the wheelchair toilet compartment. These are for people who use other mobility devices such as walkers, crutches, etc.
2010 ADA 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.
This figure shows the requirements for ambulatory toilet compartments. Notice the depth. Even though the wheelchair toilet compartment allows a 56″ depth, the ambulatory requries a minimum of 60″.
This figure shows a person that uses a cane using the ambulatory toilet compartment.
This restroom has more than six toilets and urinals combined, therefore one compartment should be for wheelchairs and one compartment should be for other mobility devices (ambulatory)
Single User Toilet Rooms
The ADA and TAs both require that EVERY toilet room provided be accessible.
213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603.
There are several exceptions to this:
EXCEPTIONS:
1. In alterations where it is technically infeasible to comply with 603, altering existing toilet or bathing rooms shall not be required where a single unisex toilet room or bathing room complying with 213.2.1 is provided and located in the same area and on the same floor as existing inaccessible toilet or bathing rooms.
2. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, no fewer than one toilet room for each sex complying with 603 or one unisex toilet room complying with 213.2.1 shall be provided.
3. Where multiple single user portable toilet or bathing units are clustered at a single location, no more than 5 percent of the toilet units and bathing units at each cluster shall be required to comply with 603. Portable toilet units and bathing units complying with 603 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
4. Where multiple single user toilet rooms are clustered at a single location, no more than 50 percent of the single user toilet rooms for each use at each cluster shall be required to comply with 603.
Based on exception 4, when you have single user restrooms in a cluster, then only 50% are required to be accessible. Make sure you round up to the nearest whole number (so if you have three restrooms in a cluster, you would need two accessible ones)
This image shows two single user restrooms in a cluster and only one would have to comply. They opted not to take the exception, but they could have.
In a single user restrooms is provided with one toilet, then that one toilet must be accessible. If the single user restroom has two toilets, again only one of the toilets is required to be accessible.
213.3.2 Water Closets. Where water closets are provided, at least one shall comply with 604.213.3.3
This restroom shows two toilets. Even though one is for adults and one is for children, the ADA only requires that one be accessible. Of course this is a minimum requirement and would be a good idea to have both be accessible since they will be used by different people.
Tuesday, January 3rd, 2023
There is a lot of confusion in the ADA on what clearances and elements are allowed to overlap each other. The main idea for restrictions to having elements overlap is the inability for a person in a wheelchair to use the element or the space efficiently. The amount of clearance that we design by translates to the amount of space that should be provided for one wheelchair. Floor clearances are not fixed elements and if they overlap each other it does not impede the usage of the clearance. But if a fixed element overlaps the clearance, that might reduce the clearance and prevents a person from using the element.
In addition, there is a confusion about protruding objects and elements that are overlapping the clearances of plumbing fixtures.
This newsletter will explain which elements can overlap since they don’t impede the usage of the space or element, and which ones may not overlap. All the rulings are taken from the 2010 ADA Standards.
Fixture clearances and turning space
In a toilet room, the floor space and other clearances including the turning space can overlap each other.
603.2.2 Overlap . Required clear floor spaces, clearance at fixtures, and turning space shall be permitted to overlap.
As was explained in the introduction, the clear floor space of the plumbing fixtures are not fixed elements. When we show them in plan it is a depiction of where a wheelchair can be in order to utilitize the fixtures. Therefore those clearances can overlap without preventing a wheelchair to utilize or manuever around the fixtures.
The drawing above shows the turning space overlaping the clerances of fixtures and the door clearance can also overlap the turning space. This turning space is essentially a representation of where a person in a wheelchair could use to turn, but it is not a permanent element. The drawing is also showing the lavatory and water closet clearances that can also overlap.
Clearance around a water closet
Toilets require a minimum of 60″ wide x 56″ depth clearance in order for a person in a wheelchair to transfer onto the water closet. The clearance must not be obstructed. There are only certain elements that are allowed to overalp the clearance:
- the water closet
- associated grab bars
- dispensers*
- sanitary napkin disposal units,
- coat hooks
- shelves
- accessible routes
- clear floor space and clearances required at other fixtures
- the turning space
Per the 2010 ADA Standards for Accessible Design:
604.3.2 Overlap. The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space. No other fixtures or obstructions shall be located within the required water closet clearance.
*Clearance around a water closet
*The part of the section that is not clear is the “dispensers”. We think of dispensers in a restroom as soap dispesers, paper towel dispensers, femenine napkin dispensers for example. So if the list includes “dispensers” we may be inclined to provide those within the clearance of the toilet. You might want to check with the AHJ at your State, but in Texas the AHJ (TDLR) came on record as stating in their
Technical Memo 2013-17 that the word “dispenser” is describing those associated with the toilet and therefore any other dispenser is not allowed to be inside the clearance of the toilet.
This toilet in the picture above had a soap dispenser that overlaps the clearance which it is not allowed
This toilet in the picture above had a paper towel dispenser and waste receptable that overlaps the clearance which it is not allowed. Note that the paper towel dispenser was recessed in the wall and did not overlap the clearance. if the element is completely recessed it is not considered overlapping.
The picture above had a lavatory overlapping the clearance of the toilet. Remember that the clearance includes the overhang of the counter.
The picture above had a urinal overlapping the clearance of the toilet.
“But it is less than 4 inches”
Some of my clients conflate the “overlap” rule and the “protruding object” rule. They think that as long as the element projects less than 4″ from the wall then it is allowed to overlap the clearance. Those are two different requirements:
The protruding object rule is for people who are visually impaired that cannot detect objects mounted in their circulation path and could get hurt. So the standards suggests that if there are any objects located on a pedestrian circulation path that it should not project more than 4″ onto that path.
The clearance around the toilet rule is for people in wheelchairs to provide a clear space for them to transfer on. the US Access Board did their research and determined that any object (no matter how big or small) inside the toilet clearance makes it difficult to transfer onto the toilet.
Thursday, December 1st, 2022
Have you noticed that there are many instances in the ADA that uses 60″ as a requirement?
- Turning spaces
- Passing spaces
- Manuevering clearances at some doors
- Landings at ramps
- Clearance around the toilet
- access aisle as parking spaces
I am not sure exactly why they like that dimension….but one thing is clear is that it confuses many of my architects. This newsletter will clarify (hopefully) that even though these are the same numbers, they are meant to be for two SEPARATE instances.
Turning spaces
Toile rooms are required to be large enough in order to provide a turning space. It can either be a circle or a “T” turn. This turning space can overlap door clearances. It can overlap fixture CLEARANCES but it cannot overlap the fixture itself.
304.3.1 Circular Space. The turning space shall be a space of 60 inches (1525 mm) diameter minimum. The space shall be permitted to include knee and toe clearance complying with 306.
304.3.2 T-Shaped Space. The turning space shall be a T-shaped space within a 60 inch (1525 mm) square minimum with arms and base 36 inches (915 mm) wide minimum. Each arm of the T shall be clear of obstructions 12 inches (305 mm) minimum in each direction and the base shall be clear of obstructions 24 inches (610 mm) minimum. The space shall be permitted to include knee and toe clearance complying with 306 only at the end of either the base or one arm.
The drawing above shows the turning space overlaping the clerances of fixtures and the door clearance can also overlap the turning space. This turning space is essentially a representation of where a person in a wheelchair could use to turn, but it is not a permanent element.
Clearance around a water closet
Toilet rooms require a minimum of 60″ x 56″ in order for a person in a wheelchair to transfer onto the toilet room. This is different and separate than the 60″ turning space. It is only related to the toilet even though they have the same dimension.
604.3 Clearance. Clearances around water closets and in toilet compartments shall comply with 604.3.
604.3.1 Size. Clearance around a water closet shall be 60 inches (1525 mm) minimum measured perpendicular from the side wall and 56 inches (1420 mm) minimum measured perpendicular from the rear wall.
This image shows the clearance required for a wheelchair to transfer onto the toilet
This toilet in the picture above did not have the 60″ min. clearance around the toilet- it does have the 60″ turning space, but that is a different requirement.
Upcoming Classes
December 13th- Understanding the ADA: Case Studies
I will be giving a zoom to the Mother’s In Architecture Facebook Group, but I am opening it up to others.
Here is the Zoom Link. Email me for the password.
Friday, July 1st, 2022
July 2022: Inspector’s Corner
I do ADA inspections every Wednesday and I always find some interesting things that I wanted to share. Here are some interesting solutions and products that are good for accessibility, and I will show them in this newsletter.
Diaper Changing Counters and Cane Detection
A diaper changing counter will sometimes be located in a circulation path around the restroom and when it is left open it can be a protruding object. TDLR issued a technical memo on the topic. Here is the link. At some of my inspections I have seen some interesting ways of handling this:
The figure above shows the requirements for objects mounted in a circulation path so they will not be hazards for people with visual impairments.
The photo above shows a diaper changing counter in the open position and located on the circulation path to the toilet compartments and exit door and is a protruding object.
Recently I have seen this Koala diaper counter installed. What is unique and interesting about it is that they are taking into consideration the “protruding object” concern and they have designed it so that the handle you use to open it, once it is in the down position, acts as cane detection.
This diaper counter’s handles will reach below 27″ a.f.f. if installed correctly and it acts as cane detection.
Reflective Surface at Mirrors
Most of us understand the rule about mirrors over lavatories or sinks. They must be located so that the reflective surface is not higher than 40″ a.f.f. I was recently at an inspection where the mirror had a frame as part of the mirror where the outer edge was the reflective surface, then frosted glass and back to the reflective surface. Obviously, the intent was for a person in a wheelchair to be able to see themselves in the mirror, so although technically there is a reflective surface at 40″ a.f.f., the real “mirror” was above that.
The mirror in the picture above has a frosted glass frame that has an outer edge made of the reflective surface of the mirror.
The “reflective” surface of the mirror (as the Standards intended) will be the one above the frosted glass, even though there is a reflective surface below the frosted glass.
Call for Entries: Click here for more information
Need Barrier-Free CEUs? 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 would like a private class for your office, contact us and we can schedule one in person or virtual.
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.
Subscribe to our YouTube Channel
Follow us on LinkedIn
Join our group on LinkedIn
Like our Page on Facebook
Monday, August 3rd, 2020
Introduction
The ADA Standards (and the Texas Accessibility Standards) states:
106.5.5 Alteration. A change to a building or facility that affects or could affect the usability of the building or facility or portion thereof. Alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, resurfacing of circulation paths or vehicular ways, changes or rearrangement of the structural parts or elements, and changes or rearrangement in the plan configuration of walls and full-height partitions.
Normal maintenance, reroofing, painting or wallpapering, or changes to mechanical and electrical systems are not alterations unless they affect the usability of the building or facility.
|
|
When doing “alterations” in buildings you have two sets of requirements: Requirements for alterations ( ADA Section 202.3) and requirements for alterations that occur in an area that contains a primary function ( ADA Section 202.4) If your alteration is in an area that is not a primary function, only the new things will have to comply. Some examples are doing renovation in bathrooms, break rooms, closets etc.
If your alterations are in an area that is considered primary function then all the new things must comply, but also the path of travel elements that serve the altered area including: accessible route, entrance, restrooms, drinking fountains and telephones that serve the altered area. In Texas they included parking that serves the altered area.
|
|
The yellow line in the figure above depicts the path of travel elements that must be compliant when an alteration occurs in an area that contains a primary function
|
|
Case studies
With the above information, let’s take a look at a few examples and what it would trigger:
Case Study #1: What if we do an alteration in an existing school of an entire bathroom?
|
|
This is an existing school building where they were going to renovate the existing toilet room.
- Restrooms are not a primary function
- They are demo-ing the entire restroom
- They are installing new fixtures and new partitions.
|
|
Because the toilet rooms are not a “primary function” in the school, only the new elements installed would have to comply
|
|
Case Study #2: What if we only renovate one element in the restroom?
|
|
This is an existing restroom, but only the lavatory will be altered. Because the ADA allows element by element alteration, only the lavatory will have to comply. The rest of the restroom that was not altered will remain as is and will not be required to be brought up to compliance.
|
|
Case Study #3: What if only the toilet is altered?
|
|
This one is a little more complicated. Just like with the lavatory, only the toilet would have to comply. But does that mean that it would also require compliant grab bars? What about compliant toilet paper dispenser? The answer is yes. Those are also elements that are part of the water closet.
One gray area question is whether the clearance around the water closet part of the toilet? Would the clearance need to be 60″ wide? If the toilet room was built prior to 2012, then it is allowed to remain at 36″ clearance.
|
|
The image on the left is the 1991 ADAAG clearance at the toilet. The image on the right is the 2010 ADA Standards clearance at the toilet. If the toilet was built prior to 2012 (the year that the new standard became mandatory) then it is compliant.
|
|
Case Study #4: What if new bleachers are installed in an existing gymnasium in the school?
- The gymnasium is a primary function
- The bleachers will have to comply
- The path of travel elements that serve the altered area must also comply
|
|
Case Study #5: What if we alter the floor at the gymnasium only?
- The gymnasium is a primary function
- The flooring must comply
- The path of travel elements that serve the altered area must also comply
|
|
Case Study #6
What if we paint the walls in the gymnasium only
- The gymnasium is a primary function
- Painting doesn’t affect the usability and therefore it is not an alteration
|
|
-
In Summary:
•Existing buildings are not “grandfathered”. They must comply
•Texas requires compliance at the time of construction
•ADA requires compliance when it is readily achievable
•Existing buildings that comply with 1991 ADAAG/1994 TAS are a safe harbor
•Altered elements must comply
•Altered elements in an area of primary function must comply, plus:
•Accessible entrance
•Accessible route
•Accessible restrooms
•Drinking fountains
•Telephones
•Parking
Here is a presentation I did about the subject
|
|
Tuesday, June 2nd, 2020
Vertical Diaper Changing Counters
Diaper changing counters have been discussed in several of my past newsletters, from the rules about where to locate them, to general rules about height and knee clearance. So we are all mostly aware that they must comply with the ADA under “work surfaces” (and why “work” you may ask…well have you ever tried to change a diaper?)…Some of the items that must comply is the reach range of the opening mechanism of the diaper changing counter. Most of them have handles that you grab and pull down.
The handle should be no higher than 48″ a.f.f.
Once open, the second thing that must comply is that the counter be no higher than 34″ a.f.f. and have a knee space no lower than 27″ a.f.f.
the counter in the open position should have the top no higher than 34″ a.f.f. and the bottom no lower than 27″ a.f.f.
These work nicely when you are using a horizontal diaper counter. But what happens when you want to use a vertical diaper changing counter?
Vertical Diaper changing counter
The handle on a vertical counter is shown higher than 48″ a.f.f. in the unit above. But if they lower it, then the bottom of the counter (when open) will be lower than 27″ a.f.f.
the handle is mounted at 53″ a.f.f.
the top of this counter when open is 37″ a.f.f. and the bottom knee space is 33″ a.f.f.
So unless the manufacturer has a model with a handle mounted lower so that it is able to be mounted within reach and with the proper clearances, it is not recommended to use a vertical diaper changing counter for the accessible counter.
here is a good chart to follow:
Automatic Flush Controls
One of the requirements in the ADA is to have the flush control located on the transfer side of the water closet
Sometimes the water closet has an automatic flush control which does not have the person flush on their own, therefore the location is not dictated. But what happens when the automatic mechanism breaks and the unit has a manual option located in the middle of the water closet? We found this exact condition on one of our inspections.
water closet with automatic flush control located behind the toilet
sign that is broken and to push the button located behind the toilet
There are many issues with this, one being that now the flush control is not located on the transfer side, but also, the fact that to reach for the control you have an obstruction that is likely more than 25″ long which is not within reach range.
If at all possible, when installing automatic flush controls, try to also install the override button on the transfer side.
Funnies
not sure this ATM meets the reach range required by ADA
Friday, May 1st, 2020
Transient Lodging: Common Mistakes
Being all cooped up at home due to the Covid19, made me nostalgic for traveling and staying at hotels. So I thought I would dedicate this newsletter to that topic! After the ADA became a law, people with disabilities were able to also enjoy staying in hotels with friends and family.
As an accessibility specialist, I review and inspect many hotels for ADA compliance. One of the most common mistakes that I see is that the corporation that owns the hotels has a “standard” that they want to adhere to. This may be for the type of fixtures they install, or the aesthetic or certain amenities they provide. Sometimes the “corporation” may not understand the ADA standards and they will select fixtures that are not compliant with the ADA.
|
|
| as I will explain in the next entry, the showers are not always designed correctly for ADA |
Today I will focus on some of those “corporate standards” that I find during my inspections that are not compliant with the ADA or other accessibility standards.
|
Minimun number of guest rooms with communication features
One of the common mistakes I see is the lack of understanding about guest rooms that must have communication features. These are rooms for people who are hearing impaired or sometimes for guest who are visually impaired.
The table below shows the amount of rooms that are required to be available with communication features:
#ADAFact: At least one guest room (but no more than 10%) is required to provide both mobility features and communication features as described in the 2010 ADA
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 the 1991 ADAAG this was not required 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.
|
|
| The drawing above shows 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.
|
Hand Held Shower Units and Adjustable Rods
In guest rooms that are required to have mobility features, the bathrooms within the room must comply. One of the common mistakes I see are hand held shower units. The ADA requires that all accessible showers and tubs have hand held shower units. The units must be located where a person in a wheelchair or other mobility devices can reach it and use it.
|
|
| this is a roll in shower and the hand held unit and control are within 27_ from the seat wall |
In a roll in shower it must be no farther than 27″ from the seat wall. In a transfer shower it is located right in front of the seat and in a tub it is located at the control wall.
|
|
| in the tub the hand held shower unit is at the control wall |
|
|
| this is a transfer shower and the hand held device is also at the control wall |
One thing that gets missed is the fact that the hand held shower unit MUST have an on/off control with a non-positive shut off directly on the unit. Most of the ones I see installed, have different spray settings, but no on/off control.
|
|
| this hand held unit only controls the spray but it does not turn off the shower unit when being held |
|
|
| This unit has the on/off controls on the unit |
A non-positive shut off is also required. What that means is that if a person who is using the shower unit needs to turn it off, the water will not be completely off but will trickle a bit. This will prevent the pressure to be built up and will not over spray once it gets turned back on.
|
Wish you were here…..
Pools, fitness rooms, guest laundry, saunas, golf or any other sports, lobby, restaurants, bars, reception desks all must be accessible. I will devote another newsletter for those specifically….but for now, enjoy the nice images and imagine you are all there! Stay safe!
|
Some Resources I used for this Newsletter:
|
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.
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.
Abadi 
