Public Spaces

Changes coming to the Texas Accessibility Standards

Monday, May 2nd, 2022


Changes to the Texas Accessiblity Standards have been proposed and are open for public comments. The new standard, once adopted would be called The 2022 Texas Accessibility Standards.

This newsletter will give you a few proposed changes. These have not been adopted yet, and if you have any comments for TDLR before they implement them, the comments will be accepted until May 9th, 2022 using this link

2022 Texas Accessibility Standards Changes

Here are a few of the changes that are being proposed:

1. Outdoor Developed Areas. There will be a brand new chapter for Outdoor developed areas, Section 245 and Chapter 11. These will include trails, beaches, camping and picnic areas (just to name a few).

2. Advisory. Many of the advisories have become part of the Standards

3. Definition of Alteration. The definition of “alteration” has change slightly to include clarification on “circulation paths”. It now includes flooring as part of the definition:

106.5.5 Alteration. A change to a building or facility that affects or could may 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 including carpets, floors, or fields, 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

The exemption for employee work areas clarified what “approach, enter and exit” means

203.9 Employee Work Areas. …..

“Approach, enter, and exit” means that people using wheelchairs must be able to enter and back out of the space. Employee work area doors, doorways, and gates, therefore, must comply with TAS 404 except the maneuvering clearance is limited to the “enter” side unless required for egress by TAS 207.1.

The picture above shows the diagram which explains the requirements for a work area entrance.

4. Licensed Physical and Occupational Therapy spacesused to have to go through a variance process in order to allow them not to be accessible. The proposed changes makes them not required and will no longer need a variance.

203.15 Licensed Physical and Occupational Therapy Training Areas Including Bathrooms and Kitchens. Licensed provider areas that are purposefully inaccessible for the intent of training persons with disabilities to function in a simulated home environment for when they leave therapy and return home shall not be required to comply with accessible features. The user must be able to get to the area but may not necessarily be required to provide an accessible route within the space for training purposes. 

Physical Therapy areas will no longer require a variance not to comply

5. Electrical Vehicle Charging Stations. TDLR has issued many Technical Memos throughout the years. The 2022 TAS will incorporate some as part of the standards. One of them is about Electrical Vehicle parking and charging spaces. The requirements will now be part of the 2022 TAS in section 244, 208 and 502. 

This is the requirements from the Technical Memo for Electrical Vehicle Charging Stations. They will now be part of the new standards


A built example

A charging station. The 2022 TAS will require a clear floor space to reach the accessible one.

6. 208.1 Parking Facilties. TDLR has clarified that parking facilities that are served by valet parking are not exempted from compliance with 208 and must have accessible parking. 

7. Curb ramps at public right of way. THEY’RE BACK!!! Detectable warnings (truncated domes with contrasting color) are being proposed to come back on the Standards. Don’t kill me!

curb ramps located within the public right of way are proposed to have detectable warnings.

Be sure you get involved in the public comments. We need your voices and opinions to be heard to ensure that the Standards are clear and are providing proper guidance for design professionals so we can design and build environments for persons with disabilities that are inclusive and safe.

Detectable Warnings

Friday, April 1st, 2022


If you have been around for a minute in the building industry you have seen our esteemed “truncated domes” come and go, and come and go…well it happened again….When the ADAAG was published in 1991, there was a section called “Detectable Warnings”. These were elements used for people that were visually impaired to assist them in navigating their exterior environment. A detectable warning had texture and contrasting color so a person who used a cane could feel the texture as he walked and maybe if they had low vision they could detect a change in color. Both of these methods allowed them to be aware that there might be a hazard on its way.

The detectable warning texture was required to be “truncated domes” located at a curb ramp and later it was added to pedges at a train track platforms.

This is a curb ramp inside the property line with detectable warnings.

This is a train platform edge with detectable warnings.

The ADA Standards for Accessible Design and the Texas Accessibility Standards

After the 2010 ADA Standards for Accessible Design was passed into law, the rules about detectable warnings changed. Before, detectable warnings were required at curb ramps. The new version now only requires it at train platform edges. Curb ramps inside of the property line (which is all that ADA regulates) will no longer require texture or color on it.

The picture above built in microwaves mounted above the 48″ allowable reach range. They added a counter top microwave that was not built in. This does not alleviate the lack of reach range.

Public Right of Way

The Public Right of Way guidelines (which are only proposed and have not been adopted), as well as municipalities and Department of Transportation may require that detectable warnings be provided at the bottom 24″ of the curb ramp. This will allow people that are visually impaired be aware that there might be a hazard beyond the texture.

The ADA does not have requirements beyond the property line. Therefore the public right of way does not fall under the ADA.

The Texas Department of Licensing and Regulation used to have a section in Chapter 68 which required detectable warnings at curb ramps within the public right of way, but they eliminated that in the most current version of the Rules. Click Here to see what they require.

TDLR no longer requires detectable warning at curb ramps at the public right of way.

The figure above shows the requirement for detectable warnings listed in the Public Right of Way Guidelines

The curb ramp has detectable warnings per the Department of Transportation and the Public Right of Way Guidelines. Check your municipality to make sure what it requires

Inspector’s Corner

Tuesday, March 1st, 2022


I perform ADA, Fair Housing and Texas Accessibility Standards on site inspection and assessments every Wednesday. Some days I find unique conditions that I like to share with you so we can learn from them and be sure they do not happen to you also. This newsletter will give you some of my latest intersting finds.

Vision Lights at Doors

The ADA requires that all doors that require user passage comply with all the portions of the section 404. Door that reqired “user passage”

But are all doors required to comply? What about doors that are only used for employees? The doors shown below are into a commercial kitchen. The vision lights for doors that allow user passage must be mounted no higher than 43″ a.f.f., but these type of doors have the vision light mounted higher. Here is the standard:

404.2.11 Vision Lights. Doors, gates, and side lights adjacent to doors or gates, containing one or more glazing panels that permit viewing through the panels shall have the bottom of at least one glazed panel located 43 inches (1090 mm) maximum above the finish floor.

The vision lights requirement are for ALL doors that require user passage unless the room beyond is excempted (like IT closets or other machinery spaces). Employee work area doors must have the ability to approach, enter and exit, therefore those doors into employee work areas like commercial kitchens will also have to comply.

During one of my inspections, I went to a restaurant and they had the door into the kitchen with vision lights higher than 43″ a.f.f. The owner was confused. It is not so simple to understand why this door would have to comply, but keep in mind that the ADA protects persons with disabilities from discrimination at the work place. If a person in a wheelchair gets hired as manager, the vision light allows them to see inside so they don’t get hit by the door. Be sure to specify one of the doors with the vision lights lower.

The picture above shows a commercial kitchen door with vision lights mounted higher than 43″ a.f.f. This is not compliant.


The picture above shows a commercial kitchen door with vision lights mounted lower than 43″ a.f.f. This is compliant.

Fixed or Built in elements

The ADA only deals with fixed or built in elements. At one of my inspections there was a break room with built in microwaves that were mounted higher than the allowable reach range. To solve the violation they added a microwave to the counter. This did not resolve the violation, because it is not a “built in” element and does not satisfy the requirement. Below is what the ADA states about what elements are scoped in the standards:

“Scope of coverage. The 1991 Standards and the 2010 Standards apply to fixed or built-in elements of buildings, structures, site improvements, and pedestrian routes or vehicular ways located on a site. Unless specifically stated otherwise, the advisory notes, appendix notes, and figures contained in the 1991 Standards and the 2010 Standards explain or illustrate the requirements of the rule; they do not establish enforceable requirements.”

The picture above built in microwaves mounted above the 48″ allowable reach range. They added a counter top microwave that was not built in. This does not alleviate the lack of reach range.

Protruding Objects

There are rules in the ADA Standards that pertain to people who are visually impaired. Since they cannot detect objects mounted higher than 27″ a.f.f. we typically design and built the objects so that they are recessed or have some sort of cane detection. But in one of my inspections, the drinking fountain was recessed, but not far enough, so that the leading edge was still projecting onto the circulation path more than 4″

The picture above shows a recessed drinking fountain that is located in a corridor. But the leading edge still projects more than 4″ onto the circulation path and therefore was considered a violation of the protruding object rule

The drinking fountain projects 5″ ontothe circulation path

Elevator Exception

Monday, February 7th, 2022

When is an elevator required?

The ADA Scoping section 206.2.3 Multi-Story Buildings and Facilities requires that there will be an accessible route connecting all stories or mezzanines in a multi-story building:
“206.2.3: At least one accessible route shall connect each story and mezzanine in multi-story buildings and facilities.”
An accessible route can be provided throught a ramp or elevator. There are some times when the accessible route can be a wheelchair lift, but they are limited to what Section 206.7

This is the Ed Roberts Campus building in Berkley California

This is an example of a platform lift-there are restrictions on when you can use one

This is an example of an elevator. There are also exceptions one can take on what type of elevator you can use.

There is another section of the Standards that requires an accessible route in a n alteration where a new stair is added to connect two stories: Stairs and Escalators in Existing Buildings. In alterations and additions, where an escalator or stair is provided where none existed previously and major structural modifications are necessary for the installation, an accessible route shall be provided between the levels served by the escalator or stair unless exempted by 206.2.3 Exceptions 1 through 7.

In the photo above, the retail store added a stair to connect to the story above. An elevator would have to be provided to connect to the second story. If there is already an elevator in the building outside the store, it is acceptable (although not advisable) to use that elevator. But if the building does not have an elevator, one must be provided inside the store.

EXCEPTIONS: There are certain instances when an accessible route will not be required. Below are some of those exceptions:

ADA Section 206.2.3 EXCEPTION:

1. In private buildings or facilities that are less than three stories or that have less than 3000 square feet (279 m2) per story, an accessible route shall not be required to connect stories provided that the building or facility is not a shopping center, a shopping mall, the professional office of a health care provider, a terminal, depot or other station used for specified public transportation, an airport passenger terminal, or another type of facility as determined by the U. S. Attorney General. ……
This exception is only for privately owned buildings which have two stories only. If they have more than two stories, in order to take the exception each stroy has to be less than 3,000 square feet per story.
But also the exception removes shopping centers or shopping malls. So even if the shopping center is only two stories tall, they must provide an accessible route.

This is a two story shopping center. An elevator will be reqired to reach the second floor

The other exceptions are for public buildings owned by a State or Local government or publically funded.
2. Where a two story public building or facility has one story with an occupant load of five or fewer persons that does not contain public use space, that story shall not be required to be connected to the story above or below.
This means that any public building that is two stories and has more than five occupants on the second story will have to have an elevator connecting the stories.

This is a picture of a municipality office on the second floor which has less than 5 occupants in that floor.

And another exception is of historic buildings that are more than two stories
7. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, an accessible route shall not be required to stories located above or below the accessible story.

A new lab counter in an existing science classroom is an alteration to an area containing a primary function

Some other exceptions are for residential facilities, multi-story rooms in a transient lodging, detention and correctional facilities, air traffic control towers.
There are other requirements for accessible routes that are beyond the scope of this newsletter, but we will make one in the next few months.

Explaining alterations in areas that contain a primary function

Tuesday, January 4th, 2022

Click here to view the introduction video to explain the requirements for alterations in the ADA


One of the things that is confusing to some of my clients is the requirements for “alterations”. The ADA Standards for Accessible Design applies to certain types of buildings: Commercical Facilities and Public Accommodations that are built new or existing buildings, facilities or elements that are “altered”.
ADA 101.1 General. The requirements are to be applied during the design, construction, additions to, and alteration of sites, facilities, buildings, and elements to the extent required by regulations issued by Federal agencies under the Americans with Disabilities Act of 1990 (ADA).
ADA 201.1 Scope. All areas of newly designed and newly constructed buildings and facilities and altered portions of existing buildings and facilities shall comply with these requirements.
Basically, the ADA requires that not only new construction comply with the Standards, but also remodels and what they call “alteration” projects.
But what is an alteration?
The ADA defines alterations as follows:
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. 
So if your project meets the definition of alteration, then it must comply with the ADA sections 202.3, 202.4 and 202.5. The newsletter will explain more in detail below.
Below are some examples of “alterations”

The picture above shows new flooring being installed. This is considered re-surfacing of a circulation path. This would meet the definition of alteration

The picture above shows a historic building that will be restored. This would meet the definition of alteration

The picture above shows a building that was damaged and will be re-constructed. This would meet the definition of alteration

The picture above shows a demolition plan that is removing walls which will essentially reconfigures the plan. This is an alteration

The ADA also tells us what is NOT an altertion:

(from definition) the 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.

The picture above shows a sidewalk that has broken pieces. Correcting the sidewalk would be considered maintenance and not an alteration

Not all “finishes” are exempted from having to comply. Painting vertical surfaces is an example of a project that is not an alteration.

Finishes that affect the “usability” such as flooring will trigger compliance.

What is required when the project is an alteration?

When it is determined that an “alteration” is occuring (based on the definition), then we must follow the requirements in section 202.3 which states:
202.3 Alterations. Where existing elements or spaces are altered, each altered element or space shall comply with the applicable requirements of Chapter 2.
In essense, everything new must comply with the standards. There are three exceptions: elements that are not altered (unless as noted in ADA 202.4 which we will discuss next), when it is technically infeasible (and in some jurisdictions will require a waiver or variance from the AHJ in order to make the determination) and when residential dwelling units that are not required to be accessible are altered.
EXCEPTIONS (listed in 202.3):
1. Unless required by 202.4, where elements or spaces are altered and the circulation path to the altered element or space is not altered, an accessible route shall not be required.
2. In alterations, where compliance with applicable requirements is technically infeasible, the alteration shall comply with the requirements to the maximum extent feasible
3. Residential dwelling units not required to be accessible in compliance with a standard issued pursuant to the Americans with Disabilities Act or Section 504 of the Rehabilitation Act of 1973, as amended, shall not be required to comply with 202.3.
We will focus on Exception #1 which gives us guidance if required by section 202.4. Let’s explore that section:

202.4 Alterations Affecting Primary Function Areas.

Before we delved into the additional requirements in section 202.4 it is important to understand what is considered a primary function:
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.
Mechanical rooms, boiler rooms, supply storage rooms, employee lounges or locker rooms, janitorial closets, entrances, corridors, and restrooms are not areas containing a primary function.
A building could have many “primary functions”. In a school for example, you would have the primary function of learning, working, performing. So alterations in classrooms, as well as in the administration offices or theater will be considered alterations in areas of primary function.

A new lab counter in an existing science classroom is an alteration to an area containing a primary function

A new dining counter at an existing restaurant is an alteration of an area that contains a primary function

A new reception counter at a lobby is an alteration of an area that contains a primary function

A restroom in an office building or school is NOT a primary function space (unless it is the major activity which the building is intended, such as a rest stop, or a bathroom in a hotel guest room). Thus any alterations within the restroom is not an alteration to an area containing a primary function.

What happens when we our project affects a primary function area?

When an alteration occurrs in an area that contains a primary function, then we not only must follow the requriements of 202.3 (which state that all new elements must comply), but in addition, the path of travel elements that serve the altered area must also comply, even if they are outside the scope of the project.
202.4 Alterations affecting primary function areas. In addition to the requirements of 202.3, an alteration that affects or could affect the usability of or access to an area containing a primary function shall be made so as to ensure that, to the maximum extent feasible, the path of travel to the altered area, including the rest rooms, telephones, and drinking fountains serving the altered area, are readily accessible to and usable by individuals with disabilities, unless such alterations are disproportionate to the overall alterations in terms of cost and scope as determined under criteria established by the Attorney General. In existing transportation facilities, an area of primary function shall be as defined under regulations published by the Secretary of the Department of Transportation or the Attorney General.

The diagram above shows the yellow line which depicts the path of travel elements leading to the “altered” area. The path of travel begins at the site arrival, then goes to the accessible entrance. It passes existing restrooms, drinking fountains and telephones that serve the altered area. All these existing path of travel elements must comply with the standards.

When a project is going to be done in an area that contains a primary function, and it is an alteration (based on the definition), the scope should include existing path of travel elements that serve the altered area IF they do not comply. There are a couple of exceptions: If the building owner (landlord) is not paying for the tenant’s improvement and if the existing conditions fall in the “Safe Harbor” clause. More on what is a safe harbor, read my newsletter on the subject.

But I am not CHANGING the function….
Many of my clients ask me that question. What if the function of the project stays the same but we are still doing a renovation of the space?
  1. The definition of alteration has nothing to do with “changing a function”. That terminolgoy appears in the model codes, but not in the ADA. An alteration that affects an area that contains a primary function can remain the same and still trigger compliance with 202.4 path of travel elements.


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 (it is where we learn physical education)
  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:
  • Altered buildings, facilities and elements must comply
  • Altered elements in an area of primary function must comply, plus:
  • the Accessible entrance
  • the Accessible route
  • the Accessible restrooms
  • the Drinking fountains
  • the Telephones
  • But not all of them, just the ones that serve the altered area
  • Existing elements that comply with 1991 ADAAG/1994 TAS are a safe harbor

A did a presentation and attached is the .pdf for your information

Accessible sales and service counters

Thursday, December 2nd, 2021

Sales and Service counters

Just in time for the holidays when people are shopping, this newsletter will explain what is required for people with disabilities to be able to shop and make purchases at retail stores.

The ADA Standards in section 904.4 states where provided, at least one of each type of sales counter and service counter shall comply and be accessible. Below you will see the technical requirements.

The picture above shows an “L” shape counter that has many services. Therefore each type of service will require an accessible counter.. These counters have parallel approaches.

The picture above is an information counter which is considered a “service” counter. This counter has a forward approach which is not required, but allowed. One thing to keep in mind is that no “transaction” is required for it to be considered a service counter.


Section 904.4.1 gives us the requirements that a sales or service counter must be 36” high maximum above the finished floor (it can be lower). The counter must be an integral part of the main counter. It cannot be folding, or flipping or tacked on the side of the counter.


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 shown below is deeper than the public counter that is higher, the accessible portion will only have to be the same depth as the counter that is taller since that is the “public’ sales counter.


An accessible sales and service counter must be 36″ long minimum (it could be longer). Remember that the standards when they state a minimum, you are allowed to make it longer.

This counter is at the right height, but it is shorter than 36″

A reception that is a piece of furniture, not built in or fixed, will not have to comply with the standards, although we recommend that you provide accommodations if possible.

This accessible portion is an integral part, but a portion projects more than 4″ onto a circulation path. This was probably intended to have a forward approach knee and toe clearance (which is not required, but allowed). The counter must have cane detection on either side in order that it does not create a protruding object.


At an accessible portion of the sales and service counters, a parallel approach or a forward approach with a knee and toe clearance are allowed (depending on the preference). Either one is acceptable, but if you decide to create a forward approach, then a knee and toe clearance that complies with section 306 must be provided.

The service counter shown above has forward approach with a knee clearance

The service counter shown above has parallel approach.

Tolerances and the ADA

Monday, November 1st, 2021

Are there any allowable tolerances in the ADA?

Construction is not a perfect science. No matter how accurate we try to draw or how careful one is to build and install materials, there will probably always be some error or omission that comes up. Best practices is to allow for the possibility of mistakes by incorporating ranges into our design. That is also what we find in the ADA and other accessibility guidelines.

How does the ADA deal with construction tolerances? First of all the tolerances ONLY apply to “construction”. There are no tolerances allowed in design. Therefore as architects and designers, we must design our spaces with enough room for construction errors. I recommend to my clients to not design to the maximums or minimums written in the Standards.

Most dimensions in the ADA Standards are specified as a minimum, maximum, or as a range. In a few areas, absolute dimensions are specified.

The detail shown above is showing the absolute maximums and minimum dimensions shown in the ADA Standards. There is no room for construction errors. My recommendation is to detail below the maximum and above the minimums so that you build some tolerances prior to construction.


The 2010 ADA provides some requirements with a specified range. For example, the location of the toilet should be between 16”-18”. When a range is stated, it provides an adequate tolerance and therefore no tolerance outside of the range at either point is permitted.

The ADA provides a range for the location of a water closet

This water closet is not compliant because it is located at 18 1/2″ from the side wall to the centerline of the toilet. Even though this water closet is located just 1/2″ beyond the allowable high range, because there was a low and high number as ranges, tolerances are not allowed. Tolerances are built in to the range.

Maximum and Minimums

When the ADA states a maximum or a minimum dimension that does not have two specific minimum and maximum end points, tolerances may apply. For example, a door pull side maneuvering clearance is stated to require 18″ min. If the door has a maneuvering clearance that exceeds the minimum allowable dimension instead, it might be allowed according to the amount of lee way given as the industry standard. According to the Access Board, only 3/32″ is allowed as tolerances for door maneuvering clearances.

The ADA figures above show the minimum manevering clearances at the door

The door above has a maneuvering clearance of less than 18″. The clearance is 17″ clearance. Even though it is only 1″ less than what the minimum requires it does not comply with industry tolerances of 3/32″

According to the US Access Board and the Department of Justice, tolerance is an unintended, but permitted (i.e., “tolerated”), variation from a specified dimension resulting from the process of construction or manufacture. The ADA Standards recognize conventional industry tolerances for dimensions not expressed as a range. This applies to field work, not design work. Tolerances necessary for a particular manufacturing process are also permitted. Information on specific tolerances may be available from industry and trade organizations, code groups and building officials, and published references.

The position of the U. S. Access Board – as formalized in the ADA/ABA Guidelines in Section 104.1.1 – is that industry standard tolerances should be relied on when questions regarding this issue arise. However, not many trades have codified specific tolerances for many of the elements mentioned in ADA/ABA Guidelines, nor have they developed accepted industry protocols for measuring when questions of accessibility arise. Our colleagues at Corada has completed research on where to find industry standard tolerances. Here is the link

Absolute dimensions

Some dimensions in the ADA are a complete absolute. For example in a transfer shower you are only allowed a 36″x36″ size . There is no maximum or minimums allowed and there is not a range. Therefore industry standard tolerances are allowed. Some manufacturers will make the walls 36″x36″ but the base is narrower.

The shower above was built larger than 36″x36″

The depth of the shower was 39″

The width of the shower was 39″

Sometimes I get asked why is the transfer shower need to be exactly 36″ x36″? Below is the image of the Access Board’s reply. The shower is designed and built so that a person with disabilities can easily and safely transfer onto the shower seat and be able to reach not only the controls but the grab bars as well without much difficulty and without losing balance.

In our research we found that if the shower is constructed of gypsum board, there is a 1/8” tolerance allowed by the industry. This was found in David Kent Ballast, AIA CSI’ Handbook of Construction Tolerance page 198.


Remember that as you design, allow for construction mistakes (because we all know they happen). There are no tolerances allowances for design mistakes.

If the ADA gives you a range, don’t design to the highest or the lowest number. Always pick a number in the middle.

If the ADA gives you a number not to exceed, then there might be some tolerances, but again do not design to the maximum or minimum number they give you. Always allow for some built in tolerances.

If the ADA gives you an absolute number, then the industry standard tolerances will be able to be used if that number is not achieved. These vary but some references below have codified it.


National Engineering Handbook

David Kent Ballast, AIA CSI’ Handbook of Construction Tolerance

Doors that allow user passage

Friday, October 1st, 2021

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

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.

Bus Loading Zones

Wednesday, September 1st, 2021

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

Technical Requirements

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

Employee Work Areas

Monday, August 2nd, 2021

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.

Protruding Objects

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:

Break Rooms

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.