Accessible Counters

Thursday, July 1st, 2021

Abadi Accessibility is proud to support the Americans with Disabilities Act (ADA) 31st Anniversary. On July 26th we celebrate this important civil rights law that works to ensure all people with disabilities have the same rights and opportunities as everyone else. Celebrate with us by visiting: #ADA31 #ThanksToTheADA

How are you planning to celebrate Americans with Disabilities Act (ADA) 31st Anniversary? This July 26th the ADA National Network and individuals, communities, and organizations across the country will be participating. Learn how you can be involved by visiting #ADA31 #ThanksToTheADA

Introduction to our newsletter:

After I wrote my first newsletter about counters, my clients are still not clear on all the different requirements for the different types of counters and fixed or built-in surfaces that the ADA requires to be accessible. First of all let me review that there are five type of counters scoped in the ADA Standards: Work surfaces, dining counters, service counters, sales counters and check out counters. Then there are two type of counters that are not scoped: work area counters and non-work area common use counters that do not fall under the other listed. There are also Food service lines, as well as other portions public side service areas. For those please check out my newsletter I wrote I 2014.

This newsletter will explain the different requirements for dining surfaces, non-employee work surfaces and sales and service counters.

Dining Counters

According to Scoping section 226, at least 5% of seating spaces and standing spaces at dining surfaces must comply with 902. Standing spaces are those counters where people might stand to eat or drink rather than sit. Those counters must also comply. Some examples of dining counters are bars where drinks are served, fast food establishments with fixed tables, and booths and banquettes at a restaurant.

These fixed dining counters in a cafeteria is an example of a dining surface.

a bar is an example of a dining surface

Section 902 gives us direction on how to make the dining surfaces accessible:

  1. There must be a knee clearance complying with section 306 so that a person in a wheelchair will approach and use the counter in a forward approach
  2. The height of the counter must be between 28″-34″ a.f.f. PLEASE NOTE….WE RECOMMEND TO NEVER USE THE MINIMUMS OR MAXIMUMS WHEN DESIGNING.

A dining counter should have a 30″ width and a 17″ min. depth at the knee clearance.

A dining counter has a forward approach knee clearance and it is 34″ a.f.f.

This is a dining counter but also a service window. It is acceptable to have the dining counter in front of the service counter

Non-Employee Work Surfaces

Section 226 tells you that 5% of non-employee work surfaces must comply and meet the requirements set forth in section 902. These are also required to be dispersed throughout the space they are in. Section 902 states that a work surface must have a forward approach with a knee space per section 306 and be 30″ wide minimum and 34″ high maximum

Study carrols in a library is an example of a non-employee work surface

Diaper changing counters are also considered a “work surface”

A patient registration desk is another example of a non-employee work surface

All the requirements in section 902 are for non-employee work surfaces (or for the public). Employee work surfaces that are part of a work area are exempted until such time when a person with disabilities is hired at which point, the surface must be provided to accommodate them and their abilities.

Sales and Service counters

Where provided, at least one of each type of sales counter and service counter shall comply with 904.4.

Where counters are dispersed throughout the building or facility, counters complying with 904.4 also shall be dispersed.

Keep in mind that the requirements are the either sales or service counters. The term “transaction” is no longer used. A transaction could occur but it is not the only pre-requisite for compliance.

The counter shown above has different functions (some are sales and some are service). Each one must have a portion at an accessible height

Section 904 gives us the following requirements for sales and service counters:

  1. 36” high maximum
  2. Same depth as the main counter
  3. 36” length min.
  4. Parallel approach OR Forward approach allowed

the accessible couter must be 36″ a.f.f. maximum and at least 36″ long

A sales or service counter can have either with a forward approach knee clearance or a parallel or side approach.

The accessible portion of the counter must be the same depth as the main (or public) side of the counter. Even though the reception counter is deeper than the public counter, the accessible portion will only have to be 36″ a.f.f. maximun and 36″ min. long the same depth as the public counter (which can be higher than 36″ a.f.f.)

The reception desk is considered a “service” counter because information is a service a business would provide to their guests. The one shown above did not have a 36″ long counter

A service or sales counter may not be the type that is flipped up, or pushed in once it is used. it must be a permanent counter that is always available.

Alterations in areas containing a primary function

Monday, August 3rd, 2020


The ADA Standards (and the Texas Accessibility Standards) states:
106.5.5 Alteration. A change to a building or facility that affects or could affect the usability of the building or facility or portion thereof. Alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, resurfacing of circulation paths or vehicular ways, changes or rearrangement of the structural parts or elements, and changes or rearrangement in the plan configuration of walls and full-height partitions.
Normal maintenance, reroofing, painting or wallpapering, or changes to mechanical and electrical systems are not alterations unless they affect the usability of the building or facility.
When doing “alterations” in buildings you have two sets of requirements: Requirements for alterations (ADA Section 202.3) and requirements for alterations that occur in an area that contains a primary function (ADA Section 202.4)
If your alteration is in an area that is not a primary function, only the new things will have to comply. Some examples are doing renovation in bathrooms, break rooms, closets etc.
If your alterations are in an area that is considered primary function then all the new things must comply, but also the path of travel elements that serve the altered area including: accessible route, entrance, restrooms, drinking fountains and telephones that serve the altered area. In Texas they included parking that serves the altered area.
The yellow line in the figure above depicts the path of travel elements that must be compliant when an alteration occurs in an area that contains a primary function

Case studies

With the above information, let’s take a look at a few examples and what it would trigger:

Case Study #1: What if we do an alteration in an existing school of an entire bathroom?

This is an existing school building where they were going to renovate the existing toilet room.
  1. Restrooms are not a primary function
  2. They are demo-ing the entire restroom
  3. They are installing new fixtures and new partitions.
Because the toilet rooms are not a “primary function” in the school, only the new elements installed would have to comply

Case Study #2: What if we only renovate one element in the restroom?

This is an existing restroom, but only the lavatory will be altered. Because the ADA allows element by element alteration, only the lavatory will have to comply. The rest of the restroom that was not altered will remain as is and will not be required to be brought up to compliance.

Case Study #3: What if only the toilet is altered?

This one is a little more complicated. Just like with the lavatory, only the toilet would have to comply. But does that mean that it would also require compliant grab bars? What about compliant toilet paper dispenser? The answer is yes. Those are also elements that are part of the water closet.
One gray area question is whether the clearance around the water closet part of the toilet? Would the clearance need to be 60″ wide? If the toilet room was built prior to 2012, then it is allowed to remain at 36″ clearance.
The image on the left is the 1991 ADAAG clearance at the toilet. The image on the right is the 2010 ADA Standards clearance at the toilet. If the toilet was built prior to 2012 (the year that the new standard became mandatory) then it is compliant.

Case Study #4: What if new bleachers are installed in an existing gymnasium in the school?

  1. The gymnasium is a primary function
  2. The bleachers will have to comply
  3. The path of travel elements that serve the altered area must also comply

Case Study #5: What if we alter the floor at the gymnasium only?

  1. The gymnasium is a primary function
  2. The flooring must comply
  3. The path of travel elements that serve the altered area must also comply

Case Study #6

What if we paint the walls in the gymnasium only
  1. The gymnasium is a primary function
  2. Painting doesn’t affect the usability and therefore it is not an alteration
  • In Summary:

    •Existing buildings are not “grandfathered”. They must comply
    •Texas requires compliance at the time of construction
    •ADA requires compliance when it is readily achievable
    •Existing buildings that comply with 1991 ADAAG/1994 TAS are a safe harbor
    •Altered elements must comply
    •Altered elements in an area of primary function must comply, plus:
    •Accessible entrance
    •Accessible route
    •Accessible restrooms
    •Drinking fountains

    Here is a presentation I did about the subject

Clear Widths Along an Accessible Route

Friday, January 3rd, 2020
As most of us know, the minimum clear widths along an accessible route that the ADA requires are 36″ minimum clear.  But there are times when are allowed to be narrower or required to be wider.  This newsletter will explain those instances.

Clear Width Reduction


In the 2010 ADA guidelines, section 403 gives us a figure to follow which explains that the 36″ wide clear width can be reduced to 32″ clear as long as the distance that you travel through the narrower width is no more than 24″ deep.
403.5.1 Clear Width. Except as provided in 403.5.2 and 403.5.3, the clear width of walking surfaces shall be 36 inches (915 mm) minimum.
EXCEPTION: The clear width shall be permitted to be reduced to 32 inches (815 mm) minimum for  a length of 24 inches (610 mm) maximum provided that reduced width segments are separated by  segments that are 48 inches (1220 mm) long minimum and 36 inches (915 mm) wide minimum.

But do both sides of the path need to be 24″ long the way it is shown in the figure above?  Could one side be a wall or even a longer cabinet or obstruction?  I was inspecting a restroom and found that condition.  There was a cased opening to enter the toilet compartment area.  One side of the cased opening was 8″ deep and the other side was the restroom wall which was longer than 24″.

This is the photo of the cased opening along the route to the sinks
This is the plan of the cased opening (where it says “Align”) which part of it is 8″ on one side and longer than 24″ on the other side. The opening was less than 36″ wide.
The guidelines allow this.  As long as one side of the path is no more than 24″ long and it goes back to 36″ wide, it will be an acceptable condition.

Clear width at the approach to a toilet compartment


A clear path to a toilet compartment (both wheelchair and ambulatory) should  also have a  36″ minimum clear width.  Except that at the approach to the door it must increase to 42″ in width
604.8.1.2 Doors. Toilet compartment doors, including door hardware, shall comply with 404 except that if the approach is to the latch side of the compartment door, clearance between the door side of the compartment and any obstruction shall be 42 inches (1065 mm) minimum

The standard is giving us requirements for the door clearance only.  The path to the toilet compartment is still required to have a 36″ minimum clear width.  But the space to open the toilet compartment door and the  maneuvering clearance (if the approach is on the latch side) must have a  42″ minimum clear width between the door and the obstruction

This photo shows the plan view of a path to the ambulatory toilet compartment.

In the plan view above you can see a furred out column in front of the toilet compartments.  That fur out is located within the door maneuvering clearance of the ambulatory toilet compartment and it reduces the 42″ required width to 36″

This figure above shows the door maneuvering clearance at the latch side approach.  A toilet compartment door will only require 42″ of clear width not 48″ like a standard door.

Passing space


Along an accessible route you are required to have 36″ clear width.  This width is required to be widened to 60″ every 200 feet.  This is to allow people in wheelchairs and pedestrians to pass each other.
403.5.3 Passing Spaces. An accessible route with a clear width less than 60 inches (1525 mm) shall provide passing spaces at intervals of 200 feet (61 m) maximum. Passing spaces shall be either: a space 60 inches (1525 mm) minimum by 60 inches (1525 mm) minimum; or, an intersection of two walking surfaces providing a T-shaped space complying with 304.3.2 where the base and arms of the T-shaped space extend 48 inches (1220 mm) minimum beyond the intersection
Here is a video from the Access Board that explains it

Clear width at turns


When a wheelchair makes a ninety degree turn, a 36″ minimum clear width is allowed.

But when a wheelchair is required to make a 180 degree turn, like in a narrow corridor, or maybe in a queue line or library stacks, then the width will have to increase from 36″ to 42″ depending on what size the element they are turning around is.

403.5.2 Clear Width at Turn. Where the accessible route makes a 180 degree turn around an  element which is less than 48 inches (1220 mm) wide, clear width shall be 42 inches (1065 mm)  minimum approaching the turn, 48 inches (1220 mm) minimum at the turn and 42 inches (1065 mm) minimum leaving the turn.
EXCEPTION: Where the clear width at the turn is 60 inches (1525 mm) minimum compliance with  403.5.2 shall not be required.
For instance if the space that they are turning around is 60″ in depth, then the clear width can be 36″ min.  If the space is 48″, then the clear width will have to increase to 42″
This video will give you some guidance on turning and wheelchair clearances


Door Maneuvering Clearances

Wednesday, August 1st, 2018


In order for a person with disabilities to enter a building on their own, there needs to be enough room for them to get through the door and into the spaces.  This newsletter will explain what the requirements are for doors so that a person can easily open the door and go through it.
What types of doors need to comply?
In the 2010 ADA standards for accessible design the only doors that require compliance with doors that people will pass through:
ADA Section 404.2 Manual Doors, Doorways, and Manual Gates. Manual doors and doorways and manual gates intended for user passage shall comply with 404.2.
 That means that if a door is located in a shallow closet, for example, that door is not technically intended for a person to pass through and therefore it does not have to comply


Why do we need so much room in front of the door?
The amount of maneuvering clearances at the door depends on the approach to the door.  Section 404 shows you the different ways that a person could approach the door and gives you guidance for the amount of clearance a person will need to reach for the door handle, open the door and go through.
The most well-known requirements are the forward approach pull and push.
But why do we need so much room?  The rectangle shown in the figure provides the proper amount of space for a person with disabilities to reach the door handle, open the door and go through. Below are four images depicting the amount of space required for a forward approach pull side maneuvering of the door.
Interestingly enough, a door might be located in a thicker wall, or an object might be located on the same wall as the maneuvering clearance.  As long as the object is no more than 8” deep, or as long as the door is not located more than 8” from the face of the wall, it will be compliant for maneuvering for forward approach pull or push side.  Below are some examples:

This door is located in a recess that is less than 8” deep. The 18” on the pull side maneuvering can include the wall that is in front of the door.

This door has a paper towel dispenser next to the 18” maneuvering clearance at the latch side of the door

Since the paper towel dispenser is less than 8” deep, it can be part of the maneuvering clearance

But there are other ways one can approach the door, and the requirements for the amount of maneuvering clearance will change.  The table in section 404 shows the different approaches and the amount of space required for each.
The US Access Board created instructional videos to explain the standards. Here is the one about maneuvering clearances
Other types of doors
The requirements for doors also applies to toilet compartment doors. Except for the latch side approach which requires only 42″ of clearance, all other approaches will require the space per section 404
The requirements so far dealt with swinging doors and gates.  But besides the swing doors, there are also maneuvering requirements for sliding doors. These also require maneuvering and these are found in section 404.
this is a barn door that will require maneuvering clearance to open

Smooth Surface at Doors

Tuesday, August 8th, 2017

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”.

Abadi Access

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



Abadi Access

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.

Abadi Access

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


Abadi Access

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

Abadi Access

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

Abadi Access

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.

Abadi Access

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

Abadi Access

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

Abadi Access

This door does not extend to 10 inches from the ground, therefore it will not require a smooth surface at the bottom

Barrier Free Products

Wednesday, May 24th, 2017

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.

lift u
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.

magnetic lock

 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.

operable windows

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.

File Apr 30_ 11 58 38 PM

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”


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. 


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, FAIA RAS #240
Abadi Accessibility
214. 403.8714

Toe Clearance

Monday, April 24th, 2017

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.


Here is the link to the new memo.

Need CEUs

Green CE On Demand webinar “How Accessible is Your work place?”
Green CE On Demand webinar “ADA and Residential Facilities”
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide” “Applying the ADA” published by Wiley. 


They are available for sale now. (also available as an e-book)

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

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

Means of Egress Stairway

Monday, October 24th, 2016

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.
 Last month we discussed the stairs and the railings.   This newsletter will focus on the requirements under the ADA for exist stairways.


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.


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

Transient Lodging

Friday, July 1st, 2016

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:
  1. Where emergency warning systems are provided, alarms complying with 702 shall be provided in rooms with communication features
  2. 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

July 12th: “Applying the ADA and Fair Housing in Residential Facilities” at 11:00 a.m. for the ASID Dallas July Event: Day of CEUs and Happy Hour @ Daltile
August 11th “How Accessible Is your Workplace” Metrocon16  at 3:00 p.m.
August 12th.”How Accessible is your Workplace” Metrocon16 at 7:30 a.m
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:


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

Inspector’s Corner

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

Green CE live Webinar June 7th 12:00 p.m. “Applying the ADA on Existing 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:


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