What doors are required to comply with ADA?
There seems to be a confusion about which doors are required to comply with the Americans with Disabilities Act. Most people understand that doors that lead you to accessible public spaces and rooms have to comply. But many don’t realize that ALL doors that allows “user passage” must comply with the standards. There is just one exception: a door that allows user passage but it is leading into a room that is exempted from accessibiltiy (i.e. a machinery space).
Knowing that information, let’s delve into what doors are required to comply and what are the requirements.
Doors that allow user passage like the one shown above must comply.
Which Doors must comply?
In section 206.4 of the ADA it gives us the requirements for which type of doors must be accessible.
206.4 Entrances. Entrances shall be provided in accordance with 206.4. Entrance doors, doorways and gates shall comply with 404 and shall be on an accessible route complying with 402
206.5 Doors, Doorways, and Gates. Doors, doorways, and gates providing user passage shall be provided in accordance with 184.108.40.206.1
This paragraphs lets us know that only entrance doors are going to have requirements. Exit doors are not fully exempted. The door to “exit” a space is technically an “entrance” to the exit. Therefore the side of the door which allows user passage must also comply.
Even though this is a means of egress door and has limited requirements in the ADA Standards, it is considered a door that allows user passage and must comply.
206.5 continues to tell us which spaces must have doors that comply:
- Each entrance to a building or facility (there are some restrictions, so be sure to understand them)
- Within a building at least one door serving each room (even work areas)
- In transient lodging facilities all entrances providing user passage into and within guest rooms that ARE NOT required to provide mobility features (but only the clear width)
This floor plan shows a hotel room that is not required to have mobility features. All doors (except the shower door) which allows “user passage” into and within the room must comply. A 32″ clear width should be provided. All other requirements are not mandated.
A common misunderstanding is the term “user passage”. A user that they are describing is not only people who use wheelchairs, but also ambulatory and able bodied users. Therefore even if the room where the door is located is not large enought for a wheelchair, the door clear width into the room must still comply. Note the water closet room. That door must also comply with providing at least a 32″ clear width, even if the room is not large enough for a wheelchair to enter.
This storage closet appears to be the type that allows user passage, and therefore the door must comply with the techical requirements.
What are the technical requirements?
To find the technical requirements we look in section 404 which explains how to make the required doors accessible.
Doors, doorways and gates must meet the following standards:
- Must have a clear width of 32″
- Must have proper maneuvering clearances to allow for a person to open the door and go through
- The floor and ground surface at the maneuvering clearance must be stable, firm, slip resistant and must have a slope no steeper than 1:48
- A threshold that is not higher than 1/2″ must be provided
- The hardware must be the type that does not require tight grasping and twisting of the wrist, plus must be mounted between 34″-48″ a.f.f.
- The door should not close too fast (no faster than 5 seconds)
- The opening force should not be too heavy (no more than 5 lbs on an interior door)
- The bottom surface at the push side should be smooth
- If it has a vision light it should be mounted no higher than 43″ a.f.f. (a peep hole is not a vision light)
- And if there is an automatic door, there are some additional requirements (under 404.3)
This door had a clear width of 28 1/2″. The minimum requirement is 32″ clear
This picture shows the proper maneuvering clearance to reach the door handle and to go through the door
Even sliding doors are required to have maneuvering clearance. The only ones that will not is for shallow closets that do not provide user passage
This video shows you the requirements for door maneuvering clearances
The door shown above has a slope steeper than 1:48 at the maneuvering clearance, and a threshold higher than 1/2″
The door shown above has hardware that requires tight grasping and twisting of the wrist to operate
A dining counter has a forward approach knee clearance and it is 34″ a.f.f.
The door hardware in this door was mounted at 61″ a.f.f. (higher than the allowed 48″ a.f.f.)
Because the push side of the door must have a smooth surface, a foot opener cannot be used on the push side
In addition, the door hardware on the push side of the door must not be lower than 10″ a.f.f.
The vision light shown above was mounted higher than 43″ a.f.f. to the glazing.
Section 810.2 Bus Loading Zones
This newsletter will speak about Bus Loading Zones both in the Public Right of Way and inside a property (like a school or other facility).
The bus stop in the above picture does not show the proper requirements for loading and unloading. This newsletter will explain why
The bus stop in the above picture is at a school and appears to have the correct area for loading children with disabilities
Bus loading zones must have an area that 96″ long measured perpendicular to the curb or vehicle roadway edge, and a clear width of 60 inches (1525 mm) minimum, measured parallel to the vehicle roadway.
The video above shows why the 96″ long area parallel to the curb is required. The lift mechanism for a wheelchair user to enter and exit the bus requires that amount of space.
If there is a bus shelter there should be a path of travel from the bus shelter to the loading area. The path needs to be a minimum of 36″ wide. There should be an area inside the shelter that is 30″x48″ with a slope of no greater than 1:48
Parallel to the roadway, the slope of the bus stop boarding and aligning area shall be
the same as the roadway, to the maximum extent practicable. Perpendicular to the roadway, the slope of the bus stop boarding and alighting area shall not be steeper than1:48.
It is important to note the last requirement: The slope at a bus loading zone that is parallel with the road can be the same as the roadway and is not required to be 1:48
This bus loading zone does not have a 96″ long space parallel with the curb
Accessible Work Areas
Thank you to Marsha Godeaux from TDLR for taking the time to explain about employee work areas. Click here to watch the video.
This newsletter will cover Employee work areas. There is a misunderstanding that work areas are not required to comply with the ADA or TAS Standards. We will explain what is required to comply within work areas and what is exempted. Keep in mind that the requirements we are covering are only the 2010 ADA Standards and the 2012 Texas Accessibility Standards. The ABA which covers Federal Facilities do not have the same requirements.
What is a Work Area?
Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.
Work Area Equipment. Any machine, instrument, engine, motor, pump, conveyor, or other apparatus used to perform work. As used in this document, this term shall apply only to equipment that is permanently installed or built-in in employee work areas. Work area equipment does not include passenger elevators and other accessible means of vertical transportation.
Work cubicles are part of a work area
a Point of Sale counter is considerd a work area as long as the public is not required to approach it.
What are the requirements?
203.9 Employee Work Areas. Spaces and elements within employee work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area.
The image above summarizes the approach, enter and exist requriement
An example of a work area that only requires an approach, enter and exit would be a janitor’s closet. Elements within the janitor’s closet such as the faucet for the mop sink will not be required to comply.
An exam room is partially a “work” area and partially a “patient” area. The area that is only used by the doctor (the sink) will be exempted from having to comply.
What are some exceptions?
Employee work areas, or portions of employee work areas, other than raised courtroom stations, that are less than 300 square feet and elevated 7 inches or more above the finish floor or ground where the elevation is essential to the function of the space shall not be required to comply with these requirements or to be on an accessible route.
This toll booth is less than 300 s.f. and elevated more than 7″ a.f.f. and therefore do not require an accessible route to it or the ability to approach it and enter it.
Common Circulation Path
In addition to approach, enter and exit, if the employee work area is larger than 1,000 s.f.. then a common path within the work area to common use spaces shall be provided
206.2.8 Employee Work Areas. Common use circulation paths within employee work areas shall comply with 402.
A “common” circulation path is one that is used by more than one person and not intendend for work
Section 402 states that a minimum 36″ width shall be provided along the circulation path.
1. Common use circulation paths located within employee work areas that are less than 1000 square feet (93 m2) and defined by permanently installed partitions, counters, casework, or furnishings shall not be required to comply with 402.2.
This raised work area is allowed since the work area is less than 1,000 s.f.
If the path is around work area equipment, then it will not have to comply with the 36″ clear width.
This commercial kitchen has equipment that is an integral part of the work area. The 36″ min. circulation path in this space is not required to comply due to the location of the work area equipment.
Even though the only requirement for a work area is “approach, enter and exit”, it also requires that circulation path be provided. Part of the circulation path has to make sure there are no protruding objects projecting onto the circulation path more than 4″. This requirement are for any employee or visitor to the employee area that might be visually impaired.
the filing system is located along the common circulation path inside the office space and projects more than 4″ onto the circulation path.
What about other employee areas that are not work related?
The requirements thus far have been for areas that are considered part of the “work” areas in a space. But there are other areas that are also part of an employee area, but are not related to the work they perform. Those areas that are NOT related to their job description will not be exempted and must comply. Below are a few examples of areas that might be for employees only, but must be fully compliant with the Standards:
even though a break room is not a public area, it is still required to comply with the ADA and TAS because it is not considered a “work” area, but rather a space where they take a break from work.
LEED employee shower and employee restrooms
an employee shower or even an employee restroom are also not considered “work” areas and must comply.
Employee Locker Room
The lockers as well as the bench in this locker/dressing room must comply with the Standards
What happens when an employee is disabled?
The Standards sometimes provide additional guidance through “advisories”. These are NOT requirements, but they are suggestions that might make your design a better one. Below are some of the advisories on work areas:
Advisory 203.9 Employee Work Areas. Although areas used exclusively by employees for work are not required to be fully accessible, consider designing such areas to include non-required turning spaces, and provide accessible elements whenever possible.
Under the Title I of the ADA, employees with disabilities are entitled to reasonable accommodations in the workplace; accommodations can include alterations to spaces within the facility. Designing employee work areas to be more accessible at the outset will avoid more costly retrofits when current employees become temporarily or permanently disabled, or when new employees with disabilities are hired.
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: www.adaanniversary.org/ #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 www.adaanniversary.org/ #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.
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:
- 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
- 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:
- 36” high maximum
- Same depth as the main counter
- 36” length min.
- 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.