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.
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 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.
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
A work place can be complicated to understanding as it pertains to the requirements for accessibility. Some spaces in work areas are exempted while some require full access. Because the ADA requires that a person with disabilities is given the same opportunity to seek employment, an employer may not decide that his establishment will not employ persons with disabilities, and therefore will not make the work areas accessible. So what does the ADA require the employer to provide?
This newsletter will give an overview of what requirements exist in the ADA about work areas and when the ADA Standards apply.
According to the ADA the definition of an employee work area is:
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.
Per the 2010 ADA Standards for Accessible Design:
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.
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.
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.
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.
In addition to approach, enter and exit, the employee work area shall also comply with the following sections of the ADA Standards: 206.2.8, 207.1, and 215.3. These will be explained in detail below.
206.2.8 Employee Work Areas. Common use circulation paths within employee work areas shall comply with 402.
The circulation path should meet the requirements for ADA Section 402 which includes a minimum 36″ width 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 employee work area is less than 1,000 s.f. and therefore the step is allowed
Common use circulation paths located within employee work areas that are an integral component of work area equipment shall not be required to comply with 402.3.
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.
Advisory 206.2.8 Employee Work Areas
Exception 2. Large pieces of equipment, such as electric turbines or water pumping apparatus, may have stairs and elevated walkways used for overseeing or monitoring purposes which are physically part of the turbine or pump. However, passenger elevators used for vertical transportation between stories are not considered “work area equipment” as defined in Section 106.5.
An accessible route/circulation path up to the elevated walkway used to monitor work area equipment is not required to be provided.
Common use circulation paths located within exterior employee work areas that are fully exposed to the weather shall not be required to comply with 402.
A dumpster is considered an extension of a work area. Although a circulation path within the work area might be required, because the dumpster is located on the exterior and fully exposed to the weather, a circulation path will not be required.
Advisory 206.2.8 Employee Work Areas Exception 1. Modular furniture that is not permanently installed is not directly subject to these requirements
The modular furniture in an open office is not required to be installed so that there is a minimum 36″ width is provided. They are essentially exempted from having to comply (unless they are permanently attached to the ground or wall)
207.1 Employee work areas are required to have an accessible means of egress per the requirements in the IBC
215.3 Employee Work Areas. Where employee work areas have audible alarm coverage, the wiring system shall be designed so that visible alarms complying with 702 can be integrated into the alarm system.
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:
The sink in this break room and the height of the counter are required to comply. The microwave shown in this photo is not permanently attached and therefore the reach range is not required to comply.
LEED Showers for employees
Some showers that are accessed through a private office have less requirements. But if it is a common use shower for all employees to use, then they must comply with section 608
All restrooms including employee restrooms must comply with the requirements in Sections 603-606
Employee Locker Rooms
The lockers as well as the bench in this locker/dressing room must comply with the Standards
Employee dining counters
5% of the dining counter is required to be between 28″-34″ a.f.f. and provide a knee space like the photo above.
Parking that is designated for employees should have accessible spaces as well.
Vocational schools where they teach how to use certain “work area equipment” is not exempted. Because it is considered a “public accommodation” , the equipment or access to it will have to be provided. Sometimes that is not reasonable, and at that situation, the school will have to get a variance from TDLR or provide reasonable accommodations for the students with disabilities
Barrier Free Day in Dallas Texas
Experience what it is like to have a disability and be in a work space. The AIA Dallas Codes and Standards Committee is having their annual Barrier Free Day this May 5th. If you would like to participate, please sign up today
. If you would like to just get a 1 hr. Barrier Free CEU, join us at the happy hour where participants will share their experience of their day with a disability.
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)
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:
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.
Accessible and Usable Public and Common Use Areas:
All doors designed to allow passage into and within all premises must be sufficiently
wide to allow passage by persons in wheelchairs.
Accessible Route Into and Through the Covered Dwelling Unit:
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.
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.
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.
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.
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:
Sunday, March 24th, 2013
In the new ADA there are residential scoping and technical guidelines. But these guidelines only deal with Federally funded housing, residences in places of education or social service establishments that have dwelling within. Other residential facilities, do not fall under the ADA, but Fair Housing or Model Codes. There are four types of residential projects, but only two are required to follow the ADA Standards.
- Single Family Housing
- Multi-Family Housing
- Federally funded multi-family housing
- Residential facilities as defined by ADA
This newsletter will explain single and multi-family housing that are not required to meet ADA Standards.
Privately funded Multi-Family Housing
The Fair Housing Act requires that any multi-family project be made accessible to the disabled community. Therefore the owner of a multi-famly property cannot discriminate against a family or individual who is disabled on the grounds that the property is not accessible.
ALL multi-family housing projects are required to be accessible per the Fair Housing Act. This includes apartment complexes, and even condominiums as long as there are four or more units in the property.
Here are the requirements from the fair housing act guidelines:
– At walk-ups (no elevator) ALL ground level units must meet the requirements
– in an elevator building ALL units must meet the requirements
Building code and ADA does have percentages for how many units are required to be fully compliant vs. adaptable, but fair housing does not. Therefore all units must be designed using the minimum guidelines listed below.
There are seven requirements:
1) Accessible building entrance on an accessible route: At least one entrance into the building or unit
2) Accessible and Usable public and common use areas: Places such as parking lots, mail boxes, recreational area, lobbies, laundry areas, community building must be accessible and usable.
3) Usable doors: all doors that allow passage must be wide enough (32″ nominal) and the main entrance must have proper hardware
4) Accessible route into and through the covered dwelling unit
5) Light switches, Electrical outlets, thermostat and other environmental controls in accessible locations
6) Reinforced walls in bathrooms for future installation of grab bars
7) Usable kitchens and bathrooms: Should be designed and constructed so an individual in a wheelchair can maneuver in the space provided. No knee clearances are required
To understand more in detail the requirements, visit the Fair Housing Act website or click here for the Design Manual
Single Family Housing
Single family homes, duplexes, triplexes and multi-story townhouses are not required to be accessible by any accessibility standards. Therefore any single family home development are essentially exempted from having to be accessible to the disabled.
A new movement called “Aging in Place” are advocating for remodeling or retro-fitting homes in order to make them more usable to the disabled and more universally designed so that families can stay together as they age. Below are some of the enhancements we did in a kitchen of a family with a disabled mother and son. It is also good for their able body husband.
Before the upgrades:
After the upgrades:
This was a remodel of a single family home. We installed a pull down shelving which made the shelves within reach range
Click here to watch the video of pull down shelving
For more information
If you want to learn more about the new Standards, The ADA Companion Guide explains the 2004 ADAAG Guidelines with commentary and explanations throughout. The 2004 Guidelines were adopted by the DOJ to create the 2010 Standards and by Texas to create the 2012 TAS. This book explains the technical requirements for both.
If you have any questions about these or any other topics, please feel free to contact me anytime.
Marcela Abadi Rhoads, RAS #240