Bathrooms
Monday, June 2nd, 2025
Lavatories at Fair Housing
When designing dwelling units for multi-family projects, we follow the Fair Housing Design Guidelines. Requirement 7 gives us the requirements for “usable bathrooms” and tells us how many must comply. One of the first things we have to determine when applying the Fair Housing requirements, is whether the dwelling unit is subject or covered by the Fair Housing Act or not. These are the dwelling units that must meet the requirements:
- Dwelling units in a multi-family project where the building has four or more dwelling units.
- All the dwelling units in a building that has an elevator that connects all the stories
- Only the ground floor units in a building that does not have an elevator
- Only multi-story town homes with elevators
- Only the first level of a multi-story unit.
The requirement for “Usable Bathrooms” are found in Requirement 7 of the Fair Housing Design Manual. To be a usable bathroom there are five requirements:
Usable bathroom specifications include:
- an accessible route to and into the bathroom with a nominal 32-inch clear door opening (Requirements 3 and 4),
- switches, outlets, and controls in accessible locations (Requirement 5),
- 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),
- 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), and
- 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 only under certain conditions (Requirement 7).
In addition to those five requirements, there are guidelines for how many bathrooms are required to be “usable” . Thoese are based on the type of bathroom they are: Spec “A” or Spec “B”
Spec A bathroom
Spec B bathroom
If the dwelling unit has a spec A bathroom, then ALL bathrooms must be “usuable”. If the dwelling unit has a Spec B bathroom, then only ONE of them must be usable.
As far as each fixture is concerned, there are other requirements for how many must be provided. This newsletter will explain about lavatories only.
Usable bathrooms:
1) section 100.205©(3)(iv)(b)(v) state that vanities and lavatories are installed with the centerline of the fixture a minimum of 1’3” horizontally from an adjoining wall or fixture.
2) In Spec B Bathrooms: The top of the fixture rim is a maximum height of 2’10” above the finished floor. If knee space is provided below the vanity, the bottom of the apron is at least 2’3” above the floor. If provided, full knee space (for front approach) is at least 1’5” deep. (See Figure 7c.)
Figure 7c
3) While there is not a specific height requirement for lavatories in Spec A bathrooms, the manual recommends that the 34in height should be used in Spec A bathrooms.
The photo above shows a lavatory in a spec A bathroom
The height is 35 1/2″ a.f.f. which is acceptable because Type A bathroom lavatories are not required to be 2′-10″ a.f.f.
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June 24th – “How Accessible is Your Workplace” at Ann Sacks, 1616 Oak Lawn Avenue in the Design District. CEU begins at noon.
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September 9th – “The ADA and Residential Facilities” at Kimball’s Downtown Showrrom, 1699 Cedar Springs Road, Dallas 75201
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Thursday, May 1st, 2025
| The minimum numbers of elements that are required to comply with the Guidelines of the ADA are mentioned throughout the scoping sections (Chapter 2). Sometimes they are a specific number or sometimes they are listed as a percentage. If there is not a specific number or percentage listed, it is understood that 100% of the elements or spaces must comply. In some cases there are exceptions that allow less of some elements to comply.
This newsletter will discuss showers specifically and where in the Standards states how many and if there are any exceptions to when they need to comply.
Bathing Facilities
In the ADA, showers are mentioned in scoping section 213. if a bathing facility has multiple showers or bathtubs located in the same room, you will see the minimum requirements in section 213.3.6:
213.3.6 Bathing Facilities. Where bathtubs or showers are provided, at least one bathtub complying with 607 or at least one shower complying with 608 shall be provided.
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The drawings shown above is a multi-user shower room in a school. Only one of the shower compartments are required to comply.
If multiple shower compartments or bathtubs are provided in a multi-user shower or bathing room, then at least one shower compartment or bathtub must comply (§213.3.6), including where showers or tubs are enclosed by full-height partitions for privacy. |
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The photo shown above is a shower compartment located in a shower room. The compartment is created by full height walls and a door. In a multi-user bathing room, at least one must comply with the shower section (608) as well as the door section (404)
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| “What If a bathing facility has multiple showers or bathtubs located in separate rooms for privacy, how does scoping apply? “
If single-user bathing rooms are provided in a cluster and accessed directly from a common use corridor or hallway, then each is required to comply as a separate bathing room.
This is based on this section:
213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603. Where bathing rooms are provided, each bathing room shall comply with 603.
There are some exceptions pertaining to this requirement. I will list a few pertaining to showers and toilet rooms below. But keep in mind that since the requirement above lists toilet rooms and bathing rooms separately, the exceptions will be either for toilet rooms OR bathing rooms, and not for both.
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.
This exception is allowed to be taken for either a toilet room or bathing room as listed above.
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 complyingwith 213.2.1 shall be provided.
This exception is only for toilet rooms.
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 theInternational Symbol of Accessibility complying with 703.7.2.1.
This exception is for PORTABLE toilet or bathing units in a cluster.
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.
This exception is ONLY for toilet rooms in a cluster.
Please note, that there is only one exception that reduces the BATHING ROOM requirements. Exception #3 gives exception when “portable” bathing units are clustered…then only 5% will be required to comply. These are the type that you find in an event, or construction site, and not permanent ones.
Exception #4 ONLY gives the exception to toilet rooms in a cluster, NOT bathing rooms. Therefore, if you have multiple bathing rooms located in a cluster, ALL shower rooms must comply |
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| The drawing above shows a cluster of bathing rooms. Each one must comply. |
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Tuesday, March 4th, 2025
The 2010 ADA Standards for Accessible Design are only minimum requirements to ensure that the facility will be, to the maximum extent feasible, be readily accessible to and usable by individuals with disabilities.
What that means is that the requirements are a base line for how to make buildings accessible, and if something better or more accessible can be provided, that would be ideal.
As an inspector, I cannot tell my architects and owners to do more than the minimum, but this newsletter will give guidance on elements that may not be required, but would be a good practice to provide.
Wheel Stops
Wheel stops are not required by the ADA standards. The minimum requirement is that the sidewalks and parking should be desiged as to prevent the parked cars from reducing the clear width of the accessible route:
ADA Section 502.7 Relationship to Accessible Routes. Parking spaces and access aisles shall be designed so that cars and vans, when parked, cannot obstruct the required clear width of adjacent accessible routes
Wheel stops are a good way to prevent the cars and vans from obstructing the clear width of the accessible route.
The photo above shows an accessible route located in front of the parking spaces, and because there are no wheelstops the front of the parked car is partially obstructing the route.
The photo above shows parked cars that are obstructing not only the walking surface but also the curb ramps that are part of the accessible route. Wheel stops would prevent it.
Benches at Shower rooms
The ADA Standards section 803 requires that dressing, fitting and locker rooms provide a bench.
ADA Section 803.4 Benches. A bench complying with 903 shall be provided within the room.
As an inspector I find that design professionals think they need to have a bench at shower rooms. Technically the shower rooms would be a place to undress in order to take a shower, but it is not considered a “dressing room”. Therefore a shower room is not required to have a bench as stated in section 803.
Even though it is not required, a bench in the shower room would be a good practice to provide, since the likelyhood of a person with disabilities to need to undress in order to use the shower would be high, the bench would be helpful.
For information: A bench is different than a shower seat
The drawing above shows a locker room with showers. Because this is a locker room, a bench is required in this room.
The drawing above shows a shower room. Even though there is a bench shown in the shower room, it is not required.
The photo above shows a bathing room without a bench.
Power Assisted doors
Exterior doors are not required to have an opening force more than 5 lbs. That requirement is only for interior swing doors. But exterior swing doors might be difficult to open due to the wind pressure or other factors that are not within out control. One way to provide assistance with difficult doors is to install power assisted doors. They are not required, but if used they must comply.
Even though a power assisted door is not required by the ADA Standards, it would be a good practice to provide one in order to assist persons with disabilities to open exterior doors.
The photo above shows a power assisted mechanism on the exterior entrance in order to provide assistance for persons with disabilities to open the door.
34″ a.f.f. Counter Heights
There are two different requirements at fixed counters depending on what they are used for.
Section 902 requires that a fixed dining or non-employee work surface be mounted at 34″ a.f.f.
Section 904 on the other hand has a requirement that the fixed sales or service counters be mounted at 36″ a.f.f.
As an inspector I find violations when the fixed dining counters are mounted higher than 34″ a.f.f. or the fixed sales or service counters are mounted higher than 36″ a.f.f.
In order to avoid this it would be recommended to mount all counters at 33″ a.f.f. therefore they will be meet both requirements.
The fixed dining counter shown in the photo above is required to be mounted a maximum of 34″ a.f.f.
The fixed ticket counter shown in the figure above is considered a “sales and service counter” and will be required to be mounted a maximum of 36″ a.f.f.
The movable reception counter is not required to provide an accessible portion since it is considered furniture, but it would be good practice to provide one so that a person with disabilities will be able to approach it and utilize it.
Monday, February 3rd, 2025
There is a misconception that a private bathroom is exempted from having to comply with the 2010 ADA Guidelines and the 2012 TAS. In reality, even private bathrooms must comply, although there are some exceptions they can take. In order to take the exceptions, a bathroom is deemed “private” if the bathroom is accessed from a private office and not for public or common use. This newsletter will discuss what items are required to be provided at private bathrooms, and which one’s can be left out. There is a summary from TDLR on TM 2013-19 which we will discuss in detail.
Toilets
At a private bathroom that is accessed through a private office and not for common use, the toilets must comply with all the requirements except for:
- 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.
- Grab bars are not required to be installed, but blocking must be provided within the wall for future installation
- In the Toilet and Bathing rooms the door can swing into the clear floor space of the fixtures in a private office
So a private toilet must still have the clearances required at the floor area distance from the side wall, flush control and toilet paper dispenser must comply with 604.
The photo above shows a toilet in a private bathroom. As you can see, no grab bars are provided. They are not required. Blocking for future grab bars should be provided.
But notice that it is located in a toilet compartment without a toe clearance and the width was not increased to accommodate the maneuvering to exit
The photo above shows the 60″ width inside the hard walls. ADA requires 6″ more when toe clearance is not provided….so 66″ min. would work.
The photo above shows another private bathrom toilet. This one did not provide the clearance arount the toilet required.
Sinks
At a private bathroom accessed from a private office and not for public use must have a sink that complies with everything in section 606 except:
- The sink does not have to have a knee space complying with 306 for forward approach. A parallel approach is allowed to be provided.
- The height of the sink does not have to be a 34″ a.f.f. maximum. It can be higher or lower than what the Standards require.
The sink is required to have the proper faucet mechanism, the mirror at the correct height, and floor area for parallel approach.
The photo above shows a lavatory in the private office. Although the lav itself can be taller than 34″ a.f.f. and does not need a knee clearance, the mirror will have to be mounted no higher than 40″ a.f.f. (this one is higher)
The photo above shows a lavatory in the private office. Although the lav itself can be taller than 34″ a.f.f. and does not need a knee clearance, the mirror will have to be mounted no higher than 40″ a.f.f. (this one is higher)
Showers and Tubs
At a private bathroom accessed by a private office and not for public or common use, the showers and tubs have to comply with all the requirements of section 607 and 608 except for:
- Grab bars do not have to be installed, but blocking within the walls for future installation must be provided.
Otherwise, a shower must have the controls installed at the proper reach range, a hand held shower unit must be provided, the threshold at the entry must not be higher than 1/2″, the size of the shower must comply, and at a transfer shower a seat must also be provided.
The shower in the private office was not required to provide grab bars, but there should have blocking for future grab bars. The shape of the shower is not required to be rectangular, therefore this shower should comply. The door to enter would have complied, but there was no maneuvering clearance to open. If the hinge would have been located opposite of this one, that would have corrected the issue.
The shower in the private office had controls mounted higher than 48″ a.f.f. and did not have a hand held shower unit
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If you have any questions about these or any other topics, please feel free to contact me anytime. |
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Thursday, January 2nd, 2025
Protruding Objects: An overview
The accessibility Standards are not only for mobility, but also for people who are visually impaired.
People with visual impairments (blindness, low vision etc.) will not be able to see their environment, but rather they feel their way around. They are taught to use a cane to feel their way. That cane can detect elements on the ground as well as any element mounted so that their leading edge (bottom usually) is lower than 27″ a.f.f.
Any element that is mounted on a vertical surface higher than 27″ above the finished floor and projecting more than 4″ from the mounting surface will be considered a hazard to persons who are visually impaired. That hazard is described in the ADA Standards as a “protruding object”
307.2 Protrusion Limits. Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the floor shall protrude 4 inches (100 mm) maximum horizontally into the circulation path.
The figure above shows the limits to what would be considered a protruding object.
Keep in mind that the definition of a protruding object in the standards state that objects which are located in a circulation path are the ones of which we need to be careful.
What might be confusing for us architects and designers is the definition of a “circulation path”. In architectural terms, the word “circulation” implies corridors, stairs, elevators. Because of that, we may not always think of “circulation” in terms of how people who are visually impaired define it. To them, any place they walk will be their “circulation path”.
Here is the definition found in the ADA:
Circulation Path. An exterior or interior way of passage provided for pedestrian travel, including but not limited to, walks, hallways, courtyards, elevators, platform lifts, ramps, stairways, and landings.
Which means that any “passage for pedestrian travel” will be a circulation path, exterior or interior.
Below are some examples of Protruding objects:
The photo above was taken inside a restroom. The paper towel dispenser is located in the circulation path to the lavatory
The photo above was taken at a restaurant. The dining counter had an open side that was higher than 27″ a.f.f. and projected more than 4″
The photo above was taken inside a restroom. The open diaper counter was mounted higher than 27″ a.f.f. and projected more than 4″ onto the circulation path around the restroom.
The photo above was taken inside an exit stairwell. The cross bracing is located along the circulation path to the door which leads you back into the building. Since it is leaning at a certain point, the leading edge is lower than 80″ a.f.f. and it is a protruding object.
The hi-lo drinking fountain shown above has the leading edge of the “high” fountain (for standing persons) mounted higher than 27″ a.f.f. and projects onto the circulation path more than 4″.
This drinking fountain is located in a recessed alcove, but it is still protruding onto the circulation path because the recess is not deep enoughSolutions for Correcting Protruding Objects
One of the ways that elements that are protruding objects can be corrected would be to create “cane detection”.
Remember that the reason why the element would be considered a protruding object is because it cannot be detected by a person who is visually impaired and uses a cane to find their way. If the element can be detected by using the cane, then it will NOT be a protruding object.
An example would be a hi-lo drinking fountain. The low drinking fountain IF mounted so that there is knee clearance (27″ a.f.f.) it will also be cane detectable (no higher than 27″ a.f.f.). But because the “high” drinking fountain is for standing persons and requires that it be higher than 27″ a.f.f. it will not be cane detectable. Most drinking fountain manufacturers have additional accessories that one can specify called “cane detectable apron” which can be installed at the higher drinking fountain (IF IT IS A PROTRUDING OBJECT) and it will therefore be able to be detected by a person who uses a cane.
The high drinking fountain shown above has a cane detectable apron installed which reaches exactly at 27″ a.f.f. making it cane detectableMisunderstanding about cane detectable aprons
I have been noticing at new construction, that the cane detectable aprons are installed even when the drinking fountain is not a protruding object. And also they have been installed at every drinking fountain, even the low one for wheelchairs.
The photo above shows a drinking fountain located in an alcove. It is not technically protruding onto a circulation path and the walls on either side of the drinking fountains act as cane detection. So the cane detectable apron installed under the “high” drinking fountain was not required.
Not only is the drinking fountain shown above in an alcove and not protruding, and did not need a cane detectable apron, but the low drinking fountain would never need a cane detectable apron because if mounted for knee clearance it will be cane detectable without the apron, but when the cane detectable apron is installed it reduces the knee clearance to less than 27″ a.f.f.
This photo is another example of drinking fountain in recessed alcove, not protruding and each drinking fountain had the cane detectable apron installed.Examples of elements that are NOT Protruding objects
Here are some wall-mounted elements that do not meet the criteria for protruding objects. Remember that for an object to be protruding it must meet the following criteria:
- It must be located along a circulation path
- It must be mounted so that the bottom of the object is higher than 27″ a.f.f.
- It must be more than 4″ deep measured from the mounting surface to the front edge of the object
The paper towel dispenser is mounted higher than 27″ a.f.f. and projects more than 4″ from the vertical surface it is mounted on BUT it is not located in a circulation path. The fact that it is mounted between two lavatories in the top photo and between the toilet and lavatory in the second photo takes it away from a circulation path where a pedestrian would bump into it.
The photo above is a diaper counter that is mounted higher than 27″ a.f.f. and projects more than 4″ from the wall, but because it is located between a wall and a lavatory it is not in a circulation path.
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If you have any questions about these or any other topics, please feel free to contact me anytime. |
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Monday, December 2nd, 2024
ADA Requirements on Grab bars
The 2010 ADA Standards has requirements for grab bars position gives a range on section 609.
- For adults the top of the gripping surface of the grab bar should be between 33″ to 36″ a.f.f.
- For children, the top of the gripping surface is required to be installed between 18″ and 27″ a.f.f.
609.4 Position of Grab Bars. Grab bars shall be installed in a horizontal position, 33 inches (840 mm) minimum and 36 inches (915 mm) maximum above the finish floor measured to the top of the gripping surface, except that at water closets for children’s use complying with 604.9, grab bars shall be installed in a horizontal position 18 inches (455 mm) minimum and 27 inches (685 mm) maximum above the finish floor measured to the top of the gripping surface. The height of the lower grab bar on the back wall of a bathtub shall comply with 607.4.1.1 or 607.4.2.1
But what it doesn’t state or require is that the grab bars must be at the same height. Below is a photo of an inspection where the grab bars were both installed at the children’s height, but one was at the 18″ range and the rear on was at the 27″ range. According to TDLR and The US Access Board, this is not a violation of the Standards.
The situation pictured above is not idea, but if both grab bars are between 18″ and 27″ a.f.f. it is compliant with the ADA and TAS.
Fair Housing Showers
The Fair Housing Design Guidelines has a requirement that states that if a unit only has a shower as the only bathing facility, then it must be a minimum of 36″x36″.
For the shower as the only bathing fixture: In both Specification A and B bathrooms, when a stall shower is the only bathing fixture in the covered dwelling unit it must be at least 36 inches x 36 inches in size.
This requirement would not allow a 30″x60″ shower as the ADA allows. But the requirements are not so clear. HUD (Fair Housing First) clarified that requirement and allow a shower that is less than 36″ wide as long as the total square inches meets or exceeds 36″x 36″ shower.
The photo above is the shower in a one bedroom unit and it is the only bathing fixture in the unit
The shower was 33″ x 60″ which has a square inches that exceeds 36″x36″ and therefore compliant.
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Visit our Resource Page that we are building to give you guidance on products and services
If you want to learn more about these standards, be sure to check out my books:
“The ADA Companion Guide” and “Applying the ADA” published by Wiley. |
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If you have any questions about these or any other topics, please feel free to contact me anytime.
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Tuesday, September 3rd, 2024
The ADA regulations for singage location cover three things:
- Location relative to the door of the room it designates
- Installation Height of characters
- Clear floor space
This newsletter will explain each one and will give some examples of ambigous locations.
Scope of Coverage
The ADA has requirements on when a sign must comply with the Standards. These requirements are found in the scoping section 216. Not all signs must comply. Below are some of the signs that are required to meet certain minimum standards:
216.2 Designations. Interior and exterior signs identifying permanent rooms and spaces shall comply with 703.1, 703.2, and 703.5. Where pictograms are provided as designations of permanent interior rooms and spaces, the pictograms shall comply with 703.6 and shall have text descriptors complying with 703.2 and 703.5.
The picture above shows a sign for an office suite. Since these may not always be office (could be storage, conference rooms etc) This sign is not designating “permanent” rooms and do not have to comply
216.4 Means of Egress. Signs for means of egress shall comply with 216.4.
216.4.1 Exit Doors. Doors at exit passageways, exit discharge, and exit stairways shall be identified by tactile signs complying with 703.1, 703.2, and 703.5.
216.4.2 Areas of Refuge. Signs required by section 1003.2.13.5.4 of the International Building Code (2000 edition) or section 1007.6.4 of the International Building Code (2003 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1) to provide instructions in areas of refuge shall comply with 703.5.
216.4.3 Directional Signs. Signs required by section 1003.2.13.6 of the International Building Code (2000 edition) or section 1007.7 of the International Building Code (2003 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1) to provide directions to accessible means of egress shall comply with 703.5
216.6 Entrances. Where not all entrances comply with 404, entrances complying with 404 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1. Directional signs complying with 703.5 that indicate the location of the nearest entrance complying with 404 shall be provided at entrances that do not comply with 404.
The sign is a directional sign which provides information to the accessible entrance
Here are the sections referenced above and what they are about:
703.1- gives guidance for raised and tactile characters and braille
703.2- Gives the requirements for raised characters
703.3- Gives the requirements for Braille
703.4- Gives the requirements for Installation Height and Location of signage
Location of ADA Signage
The ADA requires that accessible signs be located alongside the door at the latch side:
703.4.2 Location.
- Where a tactile sign is provided at a door, the sign shall be located alongside the door at the latch side.
The picture above shows the Accessible sign designating the permanent restroom was located next to the latch side of the door
The picture above shows the Accessible sign designating the permanent room was located next to the latch side of the door and it is either mounted on the side light or on the wall away from the glass. Either of those locations are acceptable.
The picture above shows the Accessible sign designating the permanent restroom was located next to the hinge side of the door
- Where a tactile sign is provided at double doors with one active leaf, the sign shall be located on the inactive leaf.
The picture above shows the Accessible sign designating the permanent restroom was located next to the hinge side of the door
- Where a tactile sign is provided at double doors with two active leafs, the sign shall be located to the right of the right hand door.
The picture above shows the Accessible sign at double doors with two active leaves designating the permanent room can be located at either side of the doors
- Where there is no wall space at the latch side of a single door or at the right side of double doors, signs shall be located on the nearest adjacent wall.
The picture above shows the Accessible sign at walls outside the restrooms. The doors did not have enough room for a sign at the latch side so they can be located at the wall closest to the strike
The picture above shows the Accessible sign at the hinge side of the restroom door
The picture above shows the Accessible sign at walls outside the restrooms without doors. A cased opening will be similar to a door. The sign can be located anywhere along the wall.
Clear Floor Space to read the signs
ADA reqires that signage have a clear floor space of 18″x18″ beyond the swing of the door and centered below the sign.
- Signs containing tactile characters shall be located so that a clear floor space of 18 inches (455 mm) minimum by 18 inches (455 mm) minimum, centered on the tactile characters, is provided beyond the arc of any door swing between the closed position and 45 degree open position.
The image above shows the reason why the 18″x18″ must be located beyond the swing of the door. This prevents a person from getting hit by the door as they read the sign.
The photo above shows the restroom sign next to the strike side of the door
The photo above shows the restroom sign 8″ from the door which is less than the 9″ min. required from the door the centerline of the sign.
The photo above shows the restroom sign between the wall and the drinking fountain.
The photo above shows the clear floor space less than 18″x18″. The drinking fountain is located inside the clear floor space
The p18″x18″ clear floor space must be located away from the swing of the door
The photo above shows the clear floor space less than 18″x18″. The drinking fountain is located inside the clear floor space
Can the sign be located on the door?
An accessible sign is required to be located on a wall alongside the latch side of the door. But there is one exception that allows the sign to be located on a door. If the door has a closer a sign can be located on the push side of the door.
EXCEPTION: Signs with tactile characters shall be permitted on the push side of doors with closers and without hold-open devices.
The photo above shows the sign located on the pull side of the door
Height of ADA Signage
The height of the sign is required to be mounted between 48″ to 60″ a.f.f. to the bottom of the raised characters
703.4.1 Height Above Finish Floor or Ground. Tactile characters on signs shall be located 48 inches (1220 mm) minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches (1525 mm) maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character
The photo above shows the sign mounted higher than 60″ a.f.f to the bottom of the raised characters
The photo above shows a sign with raised characters
The photo above shows a sign with raised characters mounted at 61 1/2″ a.f.f.
Summary
1) The location of the sign must be located on the wall closest to the strike side of the door of the room it designates
2) If there is no room adjacent the strike side, it is allowed to be located on a wall adjacent the door’s strike side
3) An 18″x18″ clear floor space and centered below the sign and located beyond the swing of the door must be provided.
4) At a double leaf door , the sign can be located adjacent eigher active leaf
5) At a double leaf with one active leaf, the sign can be located on the inactive leaf.
6) The sign may be located on a door provided that it is a push side approach and the door have a closer.
Monday, August 5th, 2024
The ADA regulations for building access only apply to built-in or fixed elements. Movable furniture and movable equipment (unless scoped in the standards specifically) are not covered by the Standards and do not have any requirements.
Scope of coverage. The 1991 Standards and the 2010 Standards apply to fixed or built-in elements of buildings, structures, site improvements, and pedestrian routes or vehicular ways located on a site.
My colleagues get confused about these requirements, so I am sharing some examples of when these rule can be ambigous and how we can clarify the requirements.
When elements that are not built in or fixed are not required to comply
Movable furniture is not required to comply with the ADA. Even if the furniture is a reception desk, a dining surfaces, or benches. That means that they don’t have any regulations, but they cannot be used as an accessible element that is required.
The image above shows movable tables in a cafeteria at a school. Even though a school is required to provide areas for kids and faculty with disabilities to eat lunch just like everyone else, the fact that these are movable will exempt them from any requirements found in the standards.
The image shown above shows a dining area that is not only movable but raised higher than the ground. But because it is not built in it does not have to be on an accessible route and the table does not have to have a knee space
The image shown above shows movable classroom tables. Since they are not built in, they will not have to be at a certain height or have knee clearance.
The image shown above shows a system’s furniture reception desk with a service counter. Because it is movable, the counter will not be required to comply with the sales and service counter requirements.
Even though the banquette itself is not scoped in the Standards, and even though the tables at this dining area is movable and also not scoped, what is scoped because it is a built in element is the charging outlet that is provided at the banquette. Because that charging outlet is fixed or built in, it will be required to be within reach (15″ min. a.f.f.)
When elements that are not built in or fixed are used to provide cane detection to protruding objects
Movable furniture and elements cannot be used to create cane detection for persons who are visually impaired. Cane detection is required to be permanently available because if the movable element is moved the cane detection will not be there. Below are some examples.
The image shown above shows a movable table below a pendant light. The pendant light is technically located along a circulation path because the table is not considered permanently in the location shown. It could potentially move and therefore the pendant light would be located in the open circulation path.
The pendant light was mounted at 63″ a.f.f. and therefore considered a protruding object.
The image shown above shows movable planters that are being used as cane detection to the open stairs beyond
The image shown above shows movable trash can that is being used as a cane detection for the paper towel dispenser that is protruding onto the circulation path. since the trash can is movable, it cannot be used as cane detection.
Movable elements being used to provide accessibility when a buiilt in or fixed element is not compliant.
Becuse only fixed or built in elements are scoped and have requirements, movable elements cannot be counted as the accessible element instead of the built in element. Below are some examples
In this kitchen, there are two built in microwaves that are mounted higher than the allowable reach range. The owner decided to provide a movable microwave as the accessible element, but as we have explained, this microwave can be moved and not returned, therefore it cannot be used as the “accessible” element.
But in this kitchen there is only a movable microwave and it will not be required to be within reach.because it is not technically there.
The image shown above shows a movable shower seat. If a shower seat is required, it must be built in and not mvable.
The bench shown above is not bolted down and therefore not considered a substitute for the built in enches at the lockers
Which movable elements are scoped and required to comply?
Even though ADA only applies to built in or fixed elements, there are a few elements that are movable but also scoped. Below are some examples:
The image shown above are of washer and dryers. Even thought they are movable, they are also technically built in because it is connected to the wall via venting. But even if they were not, there is scoping for the equipment on section 611.
Even though a beverage dispenser could be considered movable, most of the time it is part of the plumbing and built in by way of the connection of the water line. But even if it wasn’t built in, beverage dispensers are scoped by the standards and requirements are found in section 904.
Exercise equipment are also “movable” but are scoped and have requirements in the standards. The requirmements for Exercise equipment is found in section 1004
Monday, June 3rd, 2024
Accessible Signage Location
The 2010 ADA (and other States standards like Texas) section 216 requires that signage that designates interior rooms that are permanent (which means that their function will not change in the future due to the fixtures within). Those signs must have raised characters and braille. Although pictograms and symbols are not required, if they are provided, they must also comply with the standards.
Some of the requirements are for height and location of signs. This newsletter will focus on that requirement and will provide examples of some problematic rules.
Height of the sign
The 2010 ADA states that the signs required to comply must have raised characters and there should be brailled that matches the words of the raised characters and located directly below the corresponding words.
703.2 Raised Characters. Raised characters shall comply with 703.2 and shall be duplicated in braille complying with 703.3.
The height of the sign is in relationship to the raised characters. In other words, the Standards require that the bottom of the raised characters be located between 48″-60″ a.f.f.
703.4.1 Height Above Finish Floor or Ground. Tactile characters on signs shall be located 48 inches (1220 mm) minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches (1525 mm) maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character.
Door Signage that has both name of room and room numbers must also meet the requirements. The bottom most baseline of the raised characters should not be mounted lower than 48″ a.f.f. and the top most baseline should not be mounted higher than 60″ a.f.f.
The sign is mounted higher than 60″ a.f.f. to the baseline of the raised characters
Where should the sign be located?
Signs have requirements on where they need to be located.
1. If it is provided at a door, they must be mounted alongside the door at the latch side. Although they are allowed to be located on the push side of doors with closers.
The sign must be located adjacent the latch side of the door. If there is a sign on the door, it can stay there as long as there is also a second sign where it is required
The sign should not be located on the door on the pull side of the door because if a person is reading it, the door could open and hit them
2. Where a tactile sign is provided at double doors with one active leaf, the sign shall be located on the inactive leaf.
3.. Where a tactile sign is provided at double doors with two active leafs, the sign shall be located to the right of the right hand door.
4..Where there is no wall space at the latch side of a single door or at the right side of double doors, signs shall be located on the nearest adjacent wall.
Sign located at the wall adjacent the latch/handle of the door
The wall beyond the swing of the door is less than 18″ and therefore the sign did not have the centerline at 9″ at the floor space beyond the arc.
The sign can be mounted to a glass wall if it is adjacent the latch side of the door
5..Signs containing tactile characters shall be located so that a clear floor space of 18 inches (455 mm) minimum by 18 inches (455 mm) minimum, centered on the tactile characters, is provided beyond the arc of any door swing between the closed position and 45 degree open position.
The ADA figure shows the 18″x18′ clear floor space at the sign. It must be centered at the sign and also located beyond the arc of the door.
The clear floor space of 18″x18″ was obstructed by a drinking fountain
The clear floor space at the sign was obstructed by a drinking fountain.
Monday, May 13th, 2024
Usable Bathrooms
In the Fair Housing Design Manual, Requirement 7 states that a covered dwelling unit must have usable bathrooms. The definition of usable bathrooms is not fully accessible, like the ADA or the ICC ANSI A117.1, but rather required to:
Bathrooms must be designed and constructed so a person in a wheelchair can maneuver about the space and use fixtures and appliances. The guidelines provide specifications for baths which, when applied, provide a minimum level of accessibility.
To create Fair Housing “usable bathrooms” there are just a few requirements that we must incorporate into our designs. But some can be a bit confusing. This newsletter will explain those requirements and give you examples of when the confusion occcurs. This newsletter will only cover the bathroom for the dwelling units and not the common and public spaces.
Definition of bathroom
In The fair housing defines bathrooms as a room:
“which includes a water closet (toilet), lavatory (sink), and bathtub or shower. It does not include single-fixture facilities or those with only a water closet and lavatory”
Therefore powder rooms will not be required to be “usable” as outlined in the Guidelines, except for a few requirements that will be listed below.
Examples of powder rooms
Usable Bathrooms Usable bathroom specifications include:
1. An accessible route to and into the bathroom with a nominal 32- inch clear door opening (Requirements 3 and 4).
“The Guidelines specify that kitchens and all bathrooms, including powder rooms, must be on an accessible route; therefore, no part of kitchens or bathrooms may be located in a raised or sunken area unless an accessible route can be provided to that area.”
This requirement applies to all bathrooms, and also to powder rooms when the powder room is the only toilet facility on the entry level of a multistory dwelling unit in an elevator building.
2. Switches, outlets, and controls in accessible locations (Requirement 5).
3. Reinforced walls to allow for the later installation of grab bars around the toilet, tub, and shower stall; under certain conditions provisions for reinforcing must be made in shower stalls to permit the installation of a wall-hung bench seat (Requirement 6).
Hotel Ballroom for conferences or events
These are the minimums sizes for blocking, but keep in mind that to install future grab bars for mobility, it is recommended that longer ones be installed for longer grab bars in the future.
4. Maneuvering space within the bathroom to permit a person using a mobility aid to enter the room, close and reopen the door, and exit (Requirement 7).
5. Maneuvering and clear floor space within the bathroom to permit a person using a mobility aid to approach and use fixtures; fixture dimensions and placement are specified under certain conditions (Requirement 7).
clearances at the different fixtures in the usable bathrooms
clearance at the toilet can have an obstruction, but only 24″ deep
showers can only have a parallel approach
In dwelling units containing more than one bathroom
Some dwelling units have more than one bathroom. So the question is, how many of the bathrooms have to be “usable”? The answer is it depends (gotta love that answer)
The fair housing gives us two choices: Spec A or Spec B
(This is not to be confused with Type A and Type B units that are described in the ICC ANSI A117.1. Those are different standards and requirements.)
If you choose Spec A bathroom layout then ALL the bathrooms have to meet the “usable” requirements.
If you choose Spec B then only one must be usable
If Specification A is selected as the basis for designing a bathroom, all bathrooms in the dwelling unit also must comply with the A Specifications.
Spec A Batrhoom
(plumbing fixtures all in the same wet wall. perpendicular approach at bathing allowed and facility and clear floor space beyond the door)
If Specification B is selected, only one bathroom in the dwelling unit must meet those requirements;
Spec B Batrhoom
(fixtures are in different wet walls. parallel approach at bathing facility and clear floor space beyond the door)
all other bathrooms in the dwelling unit must be
1) on an accessible route (Requirement 4),
2) have doors with a nominal 32-inch clear opening (Requirement 3),
3) have switches, outlets, and controls in accessible locations
(Requirement 5),
4) and have reinforced walls around toilets, tubs, and shower stalls (Requirement 6).
Spec B Batrhoom only one of the bathrooms required to be “usable”
but the others must be on an accessible route
Abadi 
