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.

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

The ADA and ANSI have requirements for residential dwelling units and their kitchens. Although, the ADA does not have jurisdiction with non public accommodations such as Multi-family housing (which falls under the IBC/ICC requirements), they do deal with the type of residences that are considered “public accommodations” such as social service homes, fire station sleeping quarters, and apartments at places of education that are leased to faculty and students.

In these “residences” if there are kitchens provided, there is a requirement that a work surface be provided adjacent to the ovens.

804.3 Kitchen Work Surface. In residential dwelling units required to comply with 809, at least one 30 inches (760 mm) wide minimum section of counter shall provide a kitchen work surface that complies with 804.3.

The image shown above shows a 30″ clear floor space adjacent the oven door.

What are the requirements

The only kitchens that require a work surface are at ADA required residetial dwelling units (Section 809). Other kitchens and kitchennettes do not require the work surface adjacent the oven.

The photo above is a break room kitchennette with an oven. A work surface is not required at this kitchennette because it is not a residential dwelling unit

What are the requirements

Below are the requirements for work surfaces

804.3.1 Clear Floor or Ground Space.

• A clear floor space complying with 305 positioned for a forward approach shall be provided.
• The clear floor or ground space shall be centered on the kitchen work surface and shall provide knee and toe clearance complying with 306.
• EXCEPTION:
  Cabinetry shall be permitted under the kitchen work surface provided that all of the following conditions are met:(a) the cabinetry can be removed without removal or replacement of the kitchen work surface;(b) the finish floor extends under the cabinetry; and(c) the walls behind and surrounding the cabinetry are finished.

The kitchen above provided a work surface with a clear floor space centered under the counter

The kitchen above provided a work surface with doors in front of it, but since the flooring does all the way to the back wall and the surfaces are finished, they are allowed to have doors provided in front of the work surface.

The kitchen above did not provide a work surface adjacent the oven door.

The Work surface height should be no higher than 34″ a.f.f.

804.3.2 Height. The kitchen work surface shall be 34 inches (865 mm) maximum above the finish floor or ground.EXCEPTION: A counter that is adjustable to provide a kitchen work surface at variable heights, 29 inches (735 mm) minimum and 36 inches (915 mm) maximum, shall be permitted.

804.3.3 Exposed Surfaces. There shall be no sharp or abrasive surfaces under the work surface counters.

I have had several projects latetly where my clients have asked me to write them a letter that explains that their project was excempted from having to be reviewed or inspected because they were not “alterations”. One of them said that all they were doing was MEP upgrades and “finishes”. That made me question their request….

• What finishes?
• Where are the MEP upgrades occurring?
• Were they just doing mechanical and electrical upgrades?
• or werer there also plumbing changes involved?
• Were they installing new lighting or light switches as part of the upgrades?
• What finishes? painting, flooring, new cabinetry?

The concept of “alterations” is a confusing concept for most of us. The basic confusion is what is an alteration? The answers to my questions above would have given me some clarity. In the ADA and TAS an “alteration” has a specific (not so specific) definition. And in the definition it also tells you what is NOT an alteration. I will put the definition below and then I will explain why the request was not able to be fulfilled.

Historic Restoration, depending on what is being restored might be considered an alteration. If it happens in the vertical plane or the ceiling it may not because it may not affect the usabilitity.

“

The definition of alteration, includes “re-surfacing of circulation paths”. This would include flooring. Even if the flooring is being replaced “IN KIND” with the same material that was there before….it is an alteration.

Removing toilet partitions and replacing them is an alteration. Be careful when re-installing them. If they were not compliant before, they will need to be compliant at the time of installantion.

Rebuidling toilet compartments will require that they comply. Even if they were put back exactly where they were, it is an alteration. The wheelchair accessible toilet compartment will have to comply with the standards even if it did not originally. DON’T ASSUME THEY WERE COMPLIANT BEFORE

In an alteration, the standards only requires that the element that you are altering be compliant. In this project, they were only replacing the lavatory, therefore the lavatory is the only thing in the restroom that will need to comply at the end of the project.

Replacing one or two damaged carpet tile would be considered maintenance. Replacing an entire carpet would an alteration.

painting is not an alteration because it does not affect the usability of the building for persons with disabilities

changing ceilings is NOT an alteation becuase it does not affect the usability

adding pendant light fixtures could affect the usability, therefore adding them to an existing space will be an alteration.

replacing a broken toilet, may be considered “maintenance” if it does not require a permit and other elements are being altered. This will need to be evaluated on a case by case basis.

Alterations in Areas that contain a Primary Function:

Once you determine that your project is an alteration, then we have to explore where it happens? Is it located inside an area of your facility that is considered to have a function that is a major activity to the facility? This area would be considered a “primary function” according to the ADA and TAS

Definition of: Primary Function. A major activity for which the facility is intended. Areas that contain a primary function include, but are not limited to, the customer services lobby of a bank, the dining area of a cafeteria, the meeting rooms in a conference center, as well as offices and other work areas in which the activities of the public accommodation or other private entity using the facility are carried out.

If the area you are altering is considered a primary function, then Section 202.4 will apply:

break rooms are not considered a “primary function”. If any renovation occurs inside the break room, it will not trigger the “path of travel” elements to be in compliance

restrooms are not considered a “primary function” except in rest stops. If any renovation occurs inside the restrooms (other than at rest stops), it will not trigger the “path of travel” elements to be in compliance

parking is not the “primary function” of a facilty and therefore will not trigger compliance with the path of travel elements.

Alterations that affect the usability of or access to an area containing a primary function include, but are not limited to:

(i) Remodeling merchandise display areas or employee work areas in a department store;

Introduction:

The Fair Housing Design Manual as well as the ICC ANSI A117.1 has a requirement for clearances between counter and appliances. They also have clearance requirements between kitchen counters and walls. But when the kitchen counter is next to a wall that is not part of the kitchen it gets a bit confusing how to apply the standards. This newsletter will give you some examples and will explain the difference in the requirements.

Clear width along the accessible route vs. Clearance between counters

In the fair housing design manual Requirement 4: Accessible route into and through the covered unit, the clear width of the accessible route must be a minimum of 36″ wide. Keep in mind that the clear width through the unit is measured from finished wall to finished wall (including base boards)

“

The accessible route inside this bathroom was less than 36″ wide. The lavatory counter and toilet reduced the clear width of the path to the closet

When designing kitchens using the Fair Housing (and even ANSI and ADA) there is a requirement to have a minimum clearance between counters and even kitchen walls and counter that is wider than the accessible route. Requirement 7: Usable Kitchens provides guidance on clearance between counters:

The pictures above shows a kitchen counter facing the pantry wall that is less than 40″ clearance

counters and walls that are associated with the ktichen must be 40″ away from the facing counter or wall in a pass through or galley kitchen

There are a couple of exceptions in the Fair Housing depending on where the sink is located. See the figure below

The figure above shows two Fair Housing exceptions when there is a sink at the end of the “U”, a 40” clearance is allowed.

The ADA has a different interpretation of a “U-Shape” kitchen and when there is a dead end/galley but no pass through, it will also require a 60” clearance

This is the ADA figure showing that kitchens require a turning space, therefore when it is not a pass through galley kitchen layout, it will require a minimum of 60” from counter to counter.

The ANSI A117.1 Standards shows a similar galley type kitchen that is not a pass through and might create a “U-Shape” but it does not require a wider space.

The figure above is of the ANSI A117.1 Standards for Type A unit kitchen. Type B is similar.

This kitchen had U-shape counters but the clearance was less than 60″ wide

What is you have a kitchen next to an accessible route? Is the wall that is part of the accessible route but next to the kitchen considered part of the kitchen? That is the confusing part. When in doubt you can use the 40″ clearance since the accessible route is just a minimum. But below are some examples of when the walls adjacent to a a kitchen may be considered the accessible route and only require 36″ clear width.

This graphic shows the minimum clear width at the accessible route to ENTER the kitche which must be a minimum of 36″ wide, AND the minimum 40″ clearance between counters INSIDE the kitchen.

This graphic shows a peninsula counter. The wall next to the end counter is the entrance to the kitchen and can be 36″ minimum clear width

This is a kitchen counter next to a wall that is not in the kitchen. That clearance only has to be a minimum of 36″ clear width because that is part of the accessible route through the unit.

Even though the island counter is part of the kitchen the aisle between the window and the island is considered the accessible route into the kitchen. That clearance can be 36″ minimum. This clearance was 39″ which is acceptable.

This kitchen island located next to a “corridor” to enter the kitchen had a base cabinet ALMOST 36″ from the adjacent wall, but the counter itself had an overhang and it was only 30″ from the adjacent wall which narrows the clear width to less than 36″ wide

When measuring the clear with we measure it to the narrowest points. The base boards in dwelling units might reduce the clear with. Make sure you allow for tile thickness, base board thickness or overhangs when you design to ensure that your end result will yield a MINIMUM of 36″ clear width

The parallel clear floor space at sinks, as at sink when bowls are ranges and cooktops, must be centered on the bowl of unequal size or appliance.

In addition to the turning space, the kitchen must be arranged so there is a 30-inch x 48-inch clear floor space for a parallel approach centered on the sink, range, or cooktop. The centerline of the fixture or appliance must be aligned with the centerline of the clear floor space.

In kitchens of residential dwelling units there is a requirement to provide a “work surface” with a knee clearance with a floor space centered and allowing a forward approach.