Section 404.2.10 Door and Gate Surfaces
The 2010 ADA Standards require that the push side of swinging doors have the bottom rail that is 10″ measured vertically from the finish floor or ground be “smooth”.

This door is a flush door and therefore considered to have a “smooth surface” within 10″ from the floor
Sometimes the doors are paneled by joints and may not be considered to have a “smooth surface”. If there are joints in the surface below 10″ from the finish floor, it is only allowed to be within 1/16 inch of the same plane as the other to be considered “smooth”.

This paneled door is not considered to have a smooth surface because there are joints deeper than 1/16 inches and below 10″ a.f.f. creating a paneled effect.

The locking mechanism on this door is more than 1/16 inches from the face of the bottom rail and therefore will not be considered to have a smooth surface

This door has glass panels that are located above 10 inches a.f.f. , therefore the bottom rail is considered smooth
According to the 2010 ADA , the smooth surface should extend full width of the door or gate. This may be an issue when door hardware is located within the 10 inch smooth surface.

The kick plate extends the entire width of the door and therefore considered to have a smooth surface

The door hardware at this door is located within the 10 inches and therefore it is not considered to have a smooth surface

The hinges have a chrome plate on either side of the door which makes the bottom rail not smooth since it is not extending all the way across the door
There are some exceptions:
1. Sliding doors shall not be required to comply with section 404.2.10

This door does not have a smooth surface within 10″ of the floor, but since it is a sliding door then it is allowed
2. Tempered glass doors without stiles and having a bottom rail or shoe with the top leading edge tapered at 60 degrees minimum from the horizontal shall not be required to meet the 10 inch bottom smooth surface height requirement.

This door has tempered glass and the bottom rail is tapered 60 degrees at the top, therefore the 4″ height of the bottom rail is compliant

This bottom rail is not tapered and it is less than 10″ high, therefore is it not compliant
3. Doors and gates that do not extend to within 10 inches (255 mm) of the finish floor or ground shall not be required to have smooth surface at the bottom of the gate or door

This door does not extend to 10 inches from the ground, therefore it will not require a smooth surface at the bottom
2017 AIA Convention Expo in Orlando Florida
I just attended the 2017 AIA Convention Expo and met with some vendors about their new products for barrier free design. I am not endorsing or recommending these products. These are interesting products that might work well for barrier free applications. I hope you find these interesting as well.
LIFT-U Accessor Convertible Walkway
I visited with the folks at LIFT-U on their convertible walkways. If you are walking along a walkway (exterior or interior) and you encounter a change in level, this product will create a ramp for you with a push of a button. It is surface mounted and will require electricity. Below is a video of how it works.

Convertible walkway
One of the limitations with this product is that it will only go up to 6″ in height. The length of the ramp that it creates is only six feet long to achieve a 1:12 maximum slope at a 6″ maximum height curb. So if you encounter a taller change in level, this product will not work for ADA compliance. In addition, if you are approaching a door, it will only comply if there is a 60″ landing in front of the door. But in general, this product seems to have a lot of potential.
Cavity Sliders
We visited with the folks at Cavity Sliders and they showed us their ADA Magnetic accessible hardware by Cavilock. This lock is used for pocket or sliding doors and can be used with one hand, does not require tight grasping, pinching or twisting of the wrist to operate and it requires less than 5 lbs to lock and unlock.

We ran across an interesting product that is installed onto any window to open and close it electronically. This can be used any place that requires operable windows to be accessible. Some examples are assisted living centers, schools, hotels etc. The ADA requires that operable windows meet also the reach range and operation requirements. The lock should be not only mounted within reach range (no higher than 48″ a.f.f.) but also not require more than 5 lbs to lock and unlock. This mechanism assists in the opening and makes the windows accessible.
Just Manufacturing
Just Manufacturing has come up with a way to have an accessible sink that is also deeper than 6 1/2″. They taper than sink in the front 30 degrees which allows for proper knee clearance and makes the sink farther back which allows it to be deep for more practical uses.
ADA Enviro Series 30 degrees lavatory system.
Need CEUs
Building Professionals Institute seminar, Arlington Texas
Understanding the Fair Housing Act- August 10th Metrocon17 Dallas Texas
Green CE On Demand webinar “How Accessible is Your work place?”
Green CE On Demand webinar “ADA and Residential Facilities”
AIA U online course: “Applying the ADA on Existing and Altered Buildings”
or
Green CE “Applying the ADA on Existing and Altered Buildings”
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:
“The ADA Companion Guide” “Applying the ADA” published by Wiley.
Section 306 Toe Clearance
In the 1991 ADAAG, there was a figure (Figure 31) which showed dimensions for knee and toe clearances. There was a lot of confusion as to why the “toe” clearance was shown as 6″ MAX? Why not minimum? why couldn’t we have more toe clearance under a sink, drinking fountain or desk?
What was throwing us off was the fact that the figure showed the toe clearance dimension to the rear wall where the sink/lavatory was mounted. That was misleading.
The 6″ dimension on the figure is not a construction dimension. It is not giving you a requirement for a distance to the rear wall. In fact we don’t care where the rear wall is, since we are given guidance about knees and toes which occur in the front of the element.
This section shows a protective skirt with a dimension at the bottom shown 6″ from the rear wall. The 6″ dimension is showing the toe clearance. The dimension that they should have shown is the 17″ min. depth from the front of the counter.
The 2010 ADA Standards revised the figure to remove the rear wall reference. But did it make it more clear?
The question remains: why is the 6″ a maximum and not a minimum?
In order to understand, you must read the words of the standard:
306.1 General. Where space beneath an element is included as part of clear floor or ground space or turning space, the space shall comply with 306. Additional space shall not be prohibited beneath an element but shall not be considered as part of the clear floor or ground space or turning space.
What the standards are trying to explain is that when designing your floor space that will be used by a person in a wheelchair, make sure you allocate the toe clearance so that most of the required 17″-25″ of depth occurs in front of the obstruction, and only 6″ should be counted beyond the obstruction.
The 30″x 48″ rectangle can go underneath a sink for a depth of 17″ where 11″ will be considered knee clearance and 6″ will be considered toe clearance (11″+6″=17″). If the depth is 19″, then the knee space will be allowed to be 13″ and the toe clearance will be 6″ (13″+6″=19″) etc. You can always increase the knee clearance at the front of the obstruction, but the maximum depth that can be designated for the toes will only be 6″.
The toe clearance should be 17″-25″ deep. The blocking shown on the section is not required to be provided to create the 6″ max of toe clearance.
My colleague drew this picture to show this concept. It’s not prohibited to have more than 6″ beyond the protective panel, it’s just not considered part of the “toe clearance”.
The requirement is used for measuring turning spaces or clear floor space that uses the floor under objects such as sinks, lavatories, drinking fountains or desks. So the 6″ under an element is the only amount allowed to be considered “toe clearance”. Any more than 6″ it’s just air space.
News from TDLR
There is a new Technical Memoradum from TDLR explaining the smooth surface at doors.

Accessible means of egress exit stairway
The 2010 ADA Standards Section 207 references the International Building Code (IBC)-2000 (including 2001 Supplement to the International Codes) and IBC-2003 for means of egress, areas of refuge, and railings provided on fishing piers and platforms.
At least one accessible means of egress is required for every accessible space and at least two accessible means of egress are required where more than one means of egress is required. The technical criteria for accessible means of egress allow the use of exit stairways and evacuation elevators when provided in conjunction with horizontal exits or areas of refuge. While typical elevators are not designed to be used during an emergency evacuation, evacuation elevators are designed with standby power and other features according to the elevator safety standard and can be used for the evacuation of individuals with disabilities.
The IBC also provides requirements for areas of refuge, which are fire-rated spaces on levels above or below the exit discharge levels where people unable to use stairs can go to register a call for assistance and wait for evacuation.
Doorways
Entry doorways are subject to the ADA standards. If the door is an entrance and a means of egress they must comply. But a means of egress only door does not. According the the US Access board The ADA Standard requires the door entering into the egress stair to comply. It is technically considered an “entrance” to the exit stairway.

This means of egress door is allowing entry into the exit stair and therefore will have to comply with door hardware, vision light location and maneuvering clearnaces among other things.
After entering compliance is required with IBC thus the door maneuvering clearance is not required in the stairwell for re-entry but could be required by the IBC. The door at the bottom at the stairs is also subject to IBC requirements.
This photo shows a door maneuvering from the inside of the stairway leading back into the building. It is not 18″ min., but since it is not an entry door into the stairway it only has to meet the requirements per the IBC. Maneuvering clearances that the ADA dictate may not apply in this case.
Signage
Doors at exit passageways, exit discharge, and exit stairways shall be identified by tactile signs complying with ADA Section 703.1 which states that a visual and tactile characters must be provided; Section 703.2 which describes the raised or tactile characters required including braille (section 703.3) and how to mount it (703.4); and Section 703.5 which describes the requirements for visual characters.
This sign shows raised characters and braille
An exit passageway is a horizontal exit component that is separated from the interior spaces of the building by fire-resistance-rated construction and that leads to the exit discharge or public way. The exit discharge is that portion of an egress system between the termination of an exit and a public way.
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 Section 703.5.
Need CEUs
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with
SSTL Codes
If you want to learn more about these standards, be sure to check out my books:


They are available for sale now. (also available as an e-book)
If you have any questions about these or any other topics, please feel free to contact me anytime.
Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714
marhoads@abadiaccess.com
www.abadiaccess.com
It is summer and it is time to take vacations! As you travel you might stay at hotels or motels. People with disabilities also enjoy traveling and the ADA has requirements for guest rooms in hotels (as well as other type of transient lodging) that will accommodate mobility impairments, visual impairments and hearing impairments as well. This newsletter outlines a few of the requirements for designing transient lodging facilities for people with disabilities.
Guest Rooms with Mobility features
A hotel must have a certain number of rooms provided with features that people in wheelchairs and other mobility equipment will use. The number of guest rooms required is based on the total number of guest rooms in the hotel and based on the table below

This table will also tell you how many rooms without “roll in showers” are required. Once you have more than 50 guest rooms then you will need to provide a roll in shower (and it the number gets greater as the number of guest rooms increase). When a guest room states that a room should not have roll in showers, then a accessible tub or transfer shower should be provided.
In addition, these rooms must be dispersed by type of rooms, type of beds and type of amenities provided in the room.
Other items that are required for mobility are the following:
1) All doors in the hotel must have a clear width of 32″ min. Since traveling is a social activity, and people with disabilities would travel with friends and family, they should be able to go “visit” another room. The clear width makes that possible. Mobility rooms doors must also meet the requirement in
Section 404
2) Living and dining areas within the guest room must be accessible.

3) At least one sleeping area shall provide a clear floor space complying with 305 on both sides of a bed. The clear floor space shall be positioned for parallel approach to the side of the bed.
4) At least one bathroom that is provided as part of a guest room shall comply with
603. No fewer than one water closet, one lavatory, and one bathtub or shower shall comply with applicable requirements of 603 through 610. In addition, required roll-in shower compartments should have a seat within.
This restroom is not compliant due to the fact that there is no enough clearance at the toilet, the mirror is mounted too high and the flush control is located opposite of the transfer side. There are other issues with the shower.
5) If vanity counter top space is provided in non-accessible guest toilet or bathing rooms, comparable vanity counter top space, in terms of size and proximity to the lavatory, shall also be provided in accessible guest toilet or bathing rooms.
6) Kitchens and kitchenettes shall comply with
804.
7) Turning space shall be provided within the guest room.
8) Where operable windows are provided in accessible rooms for operation by occupants, at least one opening shall comply with
309.
9) Other elements must comply with the standards, such as reach ranges for closet rods, locks, and other fixed elements.
Guest Rooms with Communication features
In addition to mobility features, a certain number of rooms must also provide communication features. These would be for people that are hearing impaired and visually impaired. The number of rooms with communication features are found in the table below:

These rooms must be dispersed also by type of rooms. Only 10% of the communication rooms can also be a mobility rooms.Factors to be considered in providing an equivalent range of options may include, but are not limited to, room size, bed size, cost, view, bathroom fixtures such as hot tubs and spas, smoking and nonsmoking, and the number of rooms provided.
Some other requirements for these rooms are:
- Where emergency warning systems are provided, alarms complying with 702 shall be provided in rooms with communication features
- Visible notification devices shall be provided to alert room occupants of incoming telephone calls and a door knock or bell. Notification devices shall not be connected to visible alarm signal appliances. Telephones shall have volume controls compatible with the telephone system and shall comply with 704.3. Telephones shall be served by an electrical outlet complying with 309 located within 48 inches (1220 mm) of the telephone to facilitate the use of a TTY

Need CEUs
August 16th: “ADA and Urban Regeneration” at AIA Dallas (Time TBD)
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with
SSTL Codes
If you want to learn more about these standards, be sure to check out my books:
Wednesday, June 1st, 2016
The Texas Department of Licensing and Regulation requires that commercial projects that are over $50,000 in construction cost get a third party plan review as well as inspection. During inspections I often see violations that tend to occur more often than others. In this newsletter you will find three examples of items that happen often enough where I think it would be important to bring it to your attention. Hope this prevents these violations to happen to you.
Door Hardware
Herculite doors are very popular in office buildings. The door hardware varies in location and size. Some of the hardware that we see are vertical handles that will sometimes reach the floor.
This door has vertical handle that almost reaches the ground.
The 2010 ADA and the 2012 TAS require that the bottom surface of swing doors have smooth surfaces up to 10″ a.f.f. on the push side.
404.2.10 Door and Gate Surfaces. Swinging door and gate surfaces within 10 inches (255 mm) of the finish floor or ground measured vertically shall have a smooth surface on the push side extending the full width of the door or gate. Parts creating horizontal or vertical joints in these surfaces shall be within 1/16 inch (1.6 mm) of the same plane as the other. Cavities created by added kick plates shall be capped.
When the door hardware extends to the ground, or below 10″ a.f.f., the door would not have a smooth surface.
Shell building finish out
When I inspect empty shell buildings at strip shopping centers or office parks, I inspect elements that are new and installed. Since there are no tenants at the point of the inspection, the entry door that is provided is only inspected for slopes and heights at threshold. The location of the parking spaces in relation to the doors that are provided is also inspected, since the ADA and TAS require that the accessible parking space is located at the shortest distance to the door.
208.3.1 General. Parking spaces complying with 502 that serve a particular building or facility shall be located on the shortest accessible route from parking to an entrance complying with 206.4. Where parking serves more than one accessible entrance,parking spaces complying with 502 shall be dispersed and located on the shortest accessible route to the accessible entrances.
In this shell building the accessible parking spaces are located at the shortest accessible route to just one door. Since there are several entrances, the parking spaces should be dispersed.
As tenants move in and new doors are added, parking spaces may be in violation of the proximity to the entry. Every time a new tenant moves in and alters his space, the inspection will include the existing parking that might have already been inspected during the shell building inspection. The existing parking might be a violation to an already inspected building if the location is not the shortest route to the entry.
The accessible parking space in this shopping center is located in front of one tenant space. There are other doors which imply that new tenants will move in and therefore the parking for those will be in violation.
Handrail extensions
Many times I see new ramps get built into existing sites. ADA and TAS require that ramp handrails extend 12″ on the top and bottom of the ramp.
505.10 Handrail Extensions. Handrail gripping surfaces shall extend beyond and in the same direction of stair flights and ramp runs in accordance with 505.10.
EXCEPTIONS: 1. Extensions shall not be required for continuous handrails at the inside turn of switchback or dogleg stairs and ramps.
2. In assembly areas, extensions shall not be required for ramp handrails in aisles serving seating where the handrails are discontinuous to provide access to seating and to permit crossovers within aisles.
3. In alterations, full extensions of handrails shall not be required where such extensions would be hazardous due to plan configuration
Many times the handrail extension is not done correctly. I typically see them turning the corner.

This ramp handrail does not extend 12″ beyond the ramp run, but instead it turns to avoid projecting into the existing sidewalk. Because this is a new ramp, during design there would have been an opportunity to give enough room for the ramp handrail extension.
As you can see in this picture, there is a level on the sidewalk. This indicates a slope which is part of the ramp. The handrails were not extended all the way to the end of the ramp run on this ramp.
The hand rail extension is located just shy of the end of the ramp run in this ramp.
Need CEUs
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with
SSTL Codes
If you want to learn more about these standards, be sure to check out my books:


They are available for sale now. (also available as an e-book)
If you have any questions about these or any other topics, please feel free to contact me anytime.
Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714
marhoads@abadiaccess.com
www.abadiaccess.com
Monday, February 1st, 2016
Which projects have to comply?
The Federal Fair Housing Act covers newly constructed multi-family housing projects that are first time occupancy residential. The projects must also have more than four dwelling units. In an a building with elevators, ALL dwelling units must comply with the guidelines. In a building without an elevator, only the first floor units must comply. If the building is only two story units, then none of them must comply.
In addition to the Fair Housing Act, some municipalities have also adopted the ANSI A117.1 for their residential dwelling units. These dictate that a certain percentage must be built as with mobility features (for the mobility impaired) and a percentage with communication features (for the hearing and visually impaired)
Seven Requirements
The Fair Housing Act Guidelines have seven requirements for the covered residential dwelling units. Here is the definitions. This newsletter will just give an overview and will not describe all the details for each requirement. We will plan to explain in more detail in future newsletters:
REQUIREMENT 1
Accessible Building Entrance on an Accessible Route:
Covered multifamily dwellings must have at least one building entrance on an accessible route, unless it is impractical to do so because of terrain or unusual characteristics of the site. For all such dwellings with a building entrance on an accessible route the following six requirements apply.
REQUIREMENT 2
Accessible and Usable Public and Common Use Areas:
REQUIREMENT 3
Usable Doors:
All doors designed to allow passage into and within all premises must be sufficiently
wide to allow passage by persons in wheelchairs.
REQUIREMENT 4
Accessible Route Into and Through the Covered Dwelling Unit:
REQUIREMENT 5
Light Switches, Electrical Outlets, Thermostats and Other Environmental
Controls in Accessible Locations:
All premises within the dwelling units must contain light switches, electrical outlets, thermostats and other environmental controls in accessible locations.
REQUIREMENT 6
Reinforced Walls for Grab Bars:
All premises within dwelling units must contain reinforcements in bathroom walls to allow later installation of grab bars around toilet, tub, shower stall and shower seat, where such facilities are provided.
REQUIREMENT 7
Usable Kitchens and Bathrooms:
Dwelling units must contain usable kitchens and bathrooms such that an individual who uses a wheelchair can maneuver about the space.
Inspector’s Corner
Requirement 1 of the Fair Housing Act states that an accessible entrance is required to the dwelling units. This photo shows three steps up to the stoop which leads to the entrance, and no ramp or lift to get them to the stoop. This unit does not meet the requirement.

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