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

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

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)

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.

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.

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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 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 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.

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

Signage clearance

The ADA and TAS requires that an 18″x18″ centered clear floor space be provided at the permanent room signage

Many times, I have seen shower seats that are too short to meet the requirements. Most of the time they don’t take into consideration the depth of the shower and the seat is typically farther than 3″ fron the entry

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The shower seat in the photo above was located 7″ from the entrance

What are the cane detectable apron at drinking fountains for?

There is an accessory that is available to specify for drinking fountains called “cane detectable apron”. And they are not cheap….

This accessory is for Halsey Taylor but other drinking fountains also carry it.

The apron is used when the high drinking fountain (for standing persons) is located along a circulation path and possibly a protruding object. The apron is installed under the high drinking fountain bringing the leading edge to 27″ a.f.f. making it detectable to canes used by people with visual impairments..

This drinking fountain is located where pedetrians would circulate and mounted where a person that is visually impaired would not be able to detect it.

This depicts a drinking fountain that is not cane detectable.

This photo shows the cane detectable apron installed at the high drinking fountain making it cane detectable.

TheBut not everyone understands how to install it and how it works. At some of my inspections I have found the apron mounted to the low drinking fountain which is not needed and removes the knee clearance. I have also seen them installed where built cane detection was provided.

This photo shows the cane detectable apron installed at the low drinking fountain instead of the high one

This photo shows the cane detectable apron installed at all drinking fountains (high and low), but because the drinking fountains were recessed in an alcove, they weren’t even required. The walls that make the alcove acts as cane detection. None of these drinking fountains were protruding objects.

Rear wall grab bar

In the ADA Standards, Texas Accessibility Standards A117.1 the rear wall grab bar is required to be a minimum 36″. It should be mounted in relation to the CENTERLINE OF THE TOILET as shown in the figure below:

This is rear wall grab bar was allowed to be shifted

ADA classes

October 19th Gannet Flemming is hosting a course called: Designing for All: A Conversation Around the Principles of Inclusive Architecture and Accessibility.

Here is the link to register

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.

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.

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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.

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:

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;

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:

1. Raised and Brailled Characters
2. Contrasting background
3. San Serif Fonts
4. Height and location
5. If using Pictogram, there are requirements
6. 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

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

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 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.

1. the water closet
2. associated grab bars
3. dispensers*
4. sanitary napkin disposal units,
5. coat hooks
6. shelves
7. accessible routes
8. clear floor space and clearances required at other fixtures
9. the turning space