Public Spaces

High Obstructed Reach Range over lavatories and Clear floor space requirements

Friday, October 2nd, 2020

Introduction

This month’s newsletter we are excited to speak to Ms. Marsha Godeaux from TDLR where she will be clarifying a common question they receive. It has to do with the reach range over obstructions and clear floor spaces below the obstruction.

The 2010 ADA Standards and the 2012 TAS (even the 2009 ICC ANSI A117.1) has a requirement that the depth of the clear floor space below an obstruction should equal the high reach range over an obstruction.


308.2.2 Obstructed High Reach. Where a high forward reach is over an obstruction, the clear floor space shall extend beneath the element for a distance not less than the required reach depth over the obstruction.

Therefore if we have to reach to a faucet, or a soap dispenser mounted behind the sink then we are also required to have the same amount of space at the floor directly under the operable part.

And the way we measure the clear floor space is to use the figure showing the toe clearance. The 30″x48″ clear floor space should be measured from the operable part above and must be no deeper than 25″ and no less than 17″.

This sink section shows all the correct knee and toe clearance but it also shows a piece of blocking at the base board which measures 17″. Unless the faucet is also at 17″ from the edge of the counter, this detail does not provide the correct amount of clear floor space under the sink to allow for the reach range to the faucet.

This sink was built in a similar design as the detail with only 17″ of depth at the toe clearance, which was not enough clear floor space for the high reach required to the faucet or the test tube racks or even the outlet behind the sink.

This clear floor space was only 17″

This section shows the relationship between the high reach above and the clear floor space below.

This lavatory has a faucet 20″ from the edge of the counter.

The clear floor space below the lavatory is more than 20″ from the operable part which is compliant.

The reach range at the sink or lavatories should always be a forward approach even though high reach can also be parallel.

So to summarize, the amount of depth required to reach an operable part above a sink or lavatory (such as faucets, soap dispensers, paper towel dispensers, electric outlets etc) should have an equal or greater amount of clear floor space below the operable part.

New parking requirements in Texas

Tuesday, September 1st, 2020

Introduction

In Texas, Beginning Aug. 1, 2020, a new rule from The Texas Department of Licensing of Regulation relating to markings and signage required for Accessible Parking Spaces went into effect.  Rule 68.104 (Texas Administrative Code) implements House Bill 3163, passed by the 86th Texas Legislature in 2019. The Elimination of Architectural Barriers (EAB) Advisory Committee recommended adoption of the rule during its June 15, 2020 meeting, and it was adopted by the Texas Commission of Licensing and Regulation at their June 30, 2020, meeting.

All projects registered with TDLR on or after August 1, 2020 must comply with the rule, as well as Texas Accessibility Standards requirements related to parking spaces. Any new or alteration construction projects that begin on or after August 1, 2020 (including those that do not meet the $50,000 threshold requiring registration with TDLR), must also satisfy the rule if they include accessible parking requirements. Rule 68.104 is available on TDLR’s Elimination of Architectural Barriers webpage.

Rule 68.104 is available on TDLR’s Elimination of Architectural Barriers webpage.


68.104. Accessible Parking Spaces.

(New section effective August 1, 2020, 45 TexReg 5166)

  • (a) A paved accessible parking space must include:
  • (1) the International Symbol of Accessibility painted conspicuously on the surface in a color that contrasts the pavement;

(2) the words “NO PARKING” painted on any access aisle adjacent to the parking space. The words must be painted:

  1. in all capital letters;
  2. with a letter height of at least twelve inches, and a stroke width of at least two inches; and
  3. centered within each access aisle adjacent to the parking space and;

These images are from California Code Title 24 but it is very close to what TDLR is requiring

(3) a sign identifying the consequences of parking illegally in a paved accessible parking space. The sign must:

  1. at a minimum state “Violators Subject to Fine and Towing” in a letter height of at least one inch;
  2. be mounted on a pole, post, wall or freestanding board;

  1. be no more than eight inches below a sign required by Texas Accessibility Standards, 502.6; and
  2. be installed so that the bottom edge of the sign is no lower than 48 inches and no higher than 80 inches above ground level.
  • (b) A parking space identification sign that complies with Texas Accessibility Standards, 502.6, that includes the requirements in subsection (a)(3)(A) satisfies subsection (a)(3).

This sign complies with TAS 502.6 which is acceptable for the new requirements

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Circulation Paths

Monday, February 3rd, 2020

There are a few of requirements in the 2010 ADA Standards that speak about  ways that people get around.  Some are described as either  “circulation path”,  “path of travel”,  “accessible route” or “vehicular path”.  Those all speak about either a car, wheelchair or pedestrian means of getting different places.  In my experience, there is a misunderstanding about the difference between “circulation path” and “path of travel” and “accessible route”.

Path of Travel and Accessible route are mainly describing the “unobstructed” path that a wheelchair user would take.

But a circulation path is speaking about a path where any pedestrian would use to get around.  As it pertains to Americans with disabilities, this term is used for persons who are visually impaired, but are still able to walk.


The idea is that a person who cannot see very well cannot detect certain hazards along the path that he will take to find his way around (i.e. the circulation path).  This newsletter will discuss this concept and will give examples of some “circulation paths”

Protruding Objects

When a person who is visually impaired is walking to find their way, that is a description of his or her “circulation path”.  Since they cannot see, we are required to make sure there are no hazards along their path.  Those hazards are any objects located along the circulation path that are mounted higher than 27″ a.f.f. or lower than 80″ a.f.f. and projects more than 4″ onto the path.

….because the bar is a protruding object

A protruding object, cannot be detected by a cane which is one of the ways that a person who is visually impaired finds their way. Here is a video by the US Access Board that explains this topic.

Circulation Path

What becomes confusing for people is the other terms in the standard.  What is a circulation path?  What is an accessible route?  What is a path of travel?  A circulation path is different than an accessible route.  An accessible route is solely for people in wheelchairs.  It must be a certain width and should be located so that people in wheelchairs can use it without much effort.

A circulation path, on the other hand,  can be used by anyone.  It describes the path that a person who can walk will be taking.  And that can really be anywhere that leads you from one place to another.  Below are some examples:

The obvious circulation path is a corridor.  That is what most people think of when they see the words “circulation path”.  Along a corridor, make sure the sconces are not mounted lower than 80″ a.f.f. if they are deeper than 4″.

A corridor is a circulation path.

A circulation path can be anywhere where people are walking.  So from one side of the bar shown below to the other side is a circulation path and the counter should not project more than 4″ onto it.

The bar top projects more than 4″ onto the circulation path between one side of the bar to the other.

The path to the restroom door is a circulation path.  The paper towel dispenser is mounted along that path and it is deeper than 4″, therefore it is a protruding object.

The paper towel dispenser in the restroom is located along the circulation path.

The circulation path to the desk has a display cabinet that projects more than 4″ onto it.

The display case is located in the circulation path to the desk.

The path to the restroom door is considered the circulation path. The drinking fountain is located on the circulation path of that door and it is a protruding object.

The drinking fountain projects more than 4″ onto the circulation path to the restroom door.

The drinking fountain in the photo below is also located along the circulation path too the restroom door.  It is partially recessed, but since the bottle filler is not the same depth as the drinking fountain it does not provide cane detection.

The drinking fountain is located along the circulation path to get to the door beyond.

The circulation path to the lavatory has a hand dryer projecting onto it.

The path to the lavatory is the circulation path.

Any place in a plaza where people walk is part of a circulation path.  The sculpture is located within the circulation path and the angled parts come down to less than 80″ a.f.f. and are considered protruding objects.

The planters were added at each angle as cane detection.

When discussing circulation paths, keep in mind that although an accessible route is a circulation path because that is where wheelchairs will go, a circulation path is not an accessible route.  A circulation path is where ANYONE can go.  There may be many more examples of circulation paths, so let’s keep them free from hazards and protruding objects.

Clear Widths Along an Accessible Route

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

Clear Width Reduction

 

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

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

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

Clear width at the approach to a toilet compartment

 

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

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


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

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

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

Passing space

 

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

Clear width at turns

 

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

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

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

 

Revisiting Employee Work Areas

Wednesday, September 4th, 2019
I am still getting questions about work areas. So in honor of Labor day, let’s revisit what is required. I think one of the things that confuse people is what is a work area.
This newsletter will  give an overview of what requirements exist in the ADA and TAS about work areas and when the ADA Standards apply.
—————–

Work Areas

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.

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.
 

Circulation within a work area

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.
 

 

Section 402 states that a minimum 36″ width shall be provided along the circulation path.
EXCEPTIONS: 
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 
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.
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.

Modular furniture that is not permanently installed are not required to comply. This is for any furniture in general.  They also do not require knee clearances, heights of counters etc. (according to Advisory 206.2.8 Employee Work Areas Exception 1)

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)

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
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

Employee Restrooms

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.

Employee parking

after
Parking that is designated for employees should have accessible spaces as well.

Vocational or Professional schools

Vocational schools and professional school, such as nursing school, dental school, or medical schools,  and culinary 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.
One example that I have encountered lately is a nursing school with “Exam” rooms that they use to simulate being in a Dr. office examination room.  In the real work area the sinks and counter and equipment in those rooms would be exempted.  But in a school setting, because you cannot discriminate against a student who might be disabled, and must provide the opportunity to attend the course, accommodations will have to be available.
The number of exam rooms that must be accessible is not scoped.  So in escense all teaching exam rooms would require that everything within be accessible.  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
medical equipment in a nursing school will have to be within reach
Equipment in a teaching mechanic shop would have to comply

December 2018: Drinking Fountains for children with disabilities

Tuesday, December 4th, 2018

Drinking Fountains-overview

 Most of the dimensions found in the ADA are for adults.  There are a few technical requirements that are for children.  One of them is for drinking fountains.  What gets confusing is that the requirements listed are for adults.  So how do we incorporate the children’s drinking fountains in our design?

Scoping:

The requirement for drinking fountains are found in the ADA section 211.  They pertain to drinking fountains located on the exterior as well as the interior of the facilities

The minimum number of drinking fountains that must be provided are two.  One of them must be for a person in a wheelchair and one must be for a standing person, or a person that cannot bend down.

these two drinking fountains are located so that the spout of one is at the height for wheelchairs and the spout of the other is for standing persons

There is an exception that allows us to use a single drinking fountain that has a low spout and a high spout can be used instead of two separate ones.

This clarification tells us that the two drinking fountains required to be provided do not have to be in the same location.  So as long as you have the proper number in the facility, you are compliant.

Approach

Drinking fountains are required to have a  30″x48″ clear floor space with a forward approach knee space and centered on the unit.

 

The 30″ width must be centered on the drinking fountain

the clear floor space must be provided as a forward approach and the drinking fountain should have a knee and toe clearance so that the clear floor space can be located under the unit

There is one exception for children.   A parallel approach is permitted at units for children’s use where the spout is 30 inches  maximum above the finish floor or ground and is 3½ inches  maximum from the front edge of the unit, including bumpers.

a 30 inch x 48 inch clear floor space positioned for a parallel approach as long as the spout is no farther than 3 1/2 inches from the front of the unit and the spout is no higher than 30 inches a.f.f.

This exception gives us guidance that it is allowed to use a children’s height drinking fountain instead of an adult height wheelchair drinking fountain.  So if you are providing the two minimum number of wheelchairs required in the scoping, one must be for an adult standing and one can be for a child.  You are not required to provide a third drinking fountain for an adult in a wheelchair.

These drinking fountains would be acceptable for both children and for standing people. The spouts would have to be at the proper heights, but no additional adult wheelchair accessible drinking fountain would be required

It is recommended that you do provide an adult wheelchair drinking fountain if your facility will have both adults and children as the primary users.  But if you have a pre-school with drinking fountains for children in the classrooms, these can be counted as your 50% of the required drinking fountains.

 

Accessible Dining and Work Surfaces

Monday, October 1st, 2018

Dining and Work Surfaces                      

 The ADA was developed for the sole purpose of making sure that the disabled community was included in all areas of our society.  This includes going out to eat with family, friends or just on their own. It also includes being able to go shopping, to the bank or to the library on their own.

In the ADA Standards Section 226 and 902 speak about dining surfaces as well as work surfaces which, when designed correctly, gives people with disabilities the freedom to use facilities and commercial buildings independently.

Dining Surfaces

The ADA requirements apply to  “fixed” or “built-in”  dining surfaces where food or drink will be consumed.  I will use the words “tables” and “counters” interchangeably with dining surfaces.  At a restaurant (for example), 5% of each type of fixed tables and counters used for either sitting or standing are required to be accessible.  They also must be dispersed throughout the space.  The accessibility requirements are:

– A clear floor space positioned for a forward approach meeting the requirements for section 305 and 306 shall be provided.  In the photo below, there is a clear floor space, but it is not 30″ minimum like section 305 requires.

  

– A dining surface should be a minimum of 28″ a.f.f. and a maximum of 34″ a.f.f. in height. The dining counter in the photo below is 42″ a.f.f. and it did not have a portion that was lower.  Since this is a different type of seating, it will also be required to comply, even though there might be fixed tables elsewhere in the dining facility.

Furniture that is loose will not be subject to these standards.  And because the standards apply to fixed “surfaces”, if there is fixed seating but no fixed tables, it will not comply.  The booth in the photo below had fixed seating, but the “accessible” table was not built in.

Bar counters must also be accessible (even if there are tables nearby that can be used to serve drinks).  Since the requirements state that 5% of the counter must comply, the ADA requires that we take the entire length of the bar and make 5% of it accessible.  A minimum width of 30″ must be provided in order to meet the requirements of section 305.  In addition, the depth of the counter must be a minimum of 17″ so that a forward approach can be achieved per section 306.  The bar in the photo below does have a lower portion but it does not have the 17″ in depth required for a wheelchair to pull up and drink at the counter.

The Texas Department of Licensing and Regulation issued a Technical Memorandum TM 2013-14 which explains how they would like the amount of space required for a wheelchair at bars to be calculated.  They explain that a measurement of 18″ per person shall be used to calculate the number of seating and standing capacity of a dining surface.  Then we take 5% of that number to determine the number of accessible spaces required at the bar.

 

“Work Surfaces”

Section 902  also discusses non-employee “work surfaces”.  These are surfaces such as check writing surfaces at retail stores, counters that are used to fill out forms at reception desks or bank teller counters, and even counters that are used to study like in a library.  5% of the work surfaces must meet the requirements.  Work surfaces have a forward approach with proper knee space and be no higher than 34″ a.f.f.

This counter is another example of a “work surface”

Inspector’s Corner: Dining counters

 A lower dining counter at 34″ a.f.f. maximum is required for people in wheelchairs, but we have to keep in mind that a “clear” floor space that is 30″x48″ is also required.  The counter below is at 34″ a.f.f. but the fixed stools do not allow a wheelchair user to sit at it.

Inspector’s Corner

Tuesday, September 4th, 2018
It’s been a while since I have shared some of my inspection stories with you.  Below are a few interesting things I have found during my last few inspections.

Children’s play areas

At one of my inspections recently, there was a children’s playground equipment that provided a transfer step for children that allows children with disabilities to transfer onto the steps 
The child would place his or her wheelchair next to the transfer platform or step and climb onto the steps.
this child is using the transfer platform to climb onto the playground equipment
In order for the child to be able to climb on, the platform must be a minimum of 11″ above the ground and no higher than 18″.
But in my inspection, the platform was covered in mulch and it did not get any higher than 4″ above the ground
new playground equipment at a daycare


the height of the platform was 4″ above the ground

Does a curb ramp need a landing at the bottom?

When we think of ramps, one of the things we think of are landings at the top and bottom of the ramp run.  But a curb ramp, even though it is a ramp, does not have the same requirements as a ramp that does not cross a curb.  For more details on the different requirements between a ramp and a curb ramp, you can read my past newsletter on that topic by clicking the link.
A curb ramp does have a requirement for a type of landing at the top of the ramp, but not at the bottom.  And the landing that is required at the top of the curb ramp does not have to have a slope of 1:48 in all direction nor does it have to be 60″ in depth
But a curb ramp is not required to have a landing at the bottom.  So the photo below shows a curb ramp and the area at the bottom is not a landing, therefore it can be less than 60″.  It should probably be 48″ since that is the minimum clearance for a wheelchair, but it is not specifically required.

Non-circular handrails

The 2010 ADA Standards, as well as the 2012 TAS and the ANSI A117.1, allow handrails shape to be non-circular.
I had an inspection recently where the handrail wasn’t circular in shape, but it was completely flat.  I did a double take and wondered if that was acceptable.  But according to the standards which states:
505.7.2 Non-Circular Cross Sections. Handrail gripping surfaces with a non-circular cross section shall have a perimeter dimension of 4 inches (100 mm) minimum and 6¼ inches (160 mm) maximum, and a cross-section dimension of 2¼ inches (57 mm) maximum.
 
So as long as the perimeter was a minimum of 4″ then and the cross section 2 1/4″ maximum then it would be compliant.
The handrail I inspected was 2″ wide, therefore it was technically compliant
this handrail has a non-circular shape
this handrail was 2″ wide and 1/4″ thick

Accessible operable parts and mechanisms

Tuesday, July 3rd, 2018
One of the guidelines that seem to be misunderstood is for operable parts.  This guideline requires that an accessible operable part have a mechanism that allows for operating or use without tight grasping or pinching, twisting of the wrist, with less than 5 lbs of force and to operate using only one hand.
ADA section 309.4 Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.
 
Why this is required?
There are persons that don’t have proper use of their hands.  People with rheumatoid arthritis for example, or cerebral palsy, have a hard time grasping elements.  Also, there are people, like amputees, or people that were born without hands or fingers that cannot operate elements which require tight pinching.  In addition, some people with disabilities or older people may not have the amount of strength required to operate an element or activate an operable part if the force required is more than 5 lbs.  Therefore, the ADA design guidelines provides rules to assist those people to navigate their environment in an equal manner.

Scoping:

Operable parts on accessible elements, accessible routes, and in accessible rooms
and spaces shall comply with with the standards.  There are some exceptions which explain that certain operable parts do not have to comply:
1. Operable parts that are intended for use only by service or maintenance personnel
2. Electrical or communication receptacles serving a dedicated use (like a refrigerator)
3. Where two or more outlets are provided in a kitchen above a length of counter top that is uninterrupted by a sink or appliance, one  outlet shall not be required to comply
4. Floor electrical receptacles
5. HVAC diffusers
6. Except for light switches, where redundant controls are provided for a single element, one control in each space  shall not be required to comply 
7. Cleats and other boat securement devices
8. Exercise machines and exercise equipment
9. Operable windows that are only operated by staff and not occupants
There is an advisory  that gives us more guidance and explanation;
205.1 General. Controls covered by 205.1 include, but are not limited to, light switches, circuit breakers, duplexes and other convenience receptacles, environmental and appliance controls, plumbing fixture controls, and security and intercom systems.
 
Section 309 
Operable parts have three requirements:
1) They must be within reach ranges as spelled out in the Section 308
the operable part of the coffee maker must be no higher than 48″ a.f.f.
2) They must have a 30″x 48″ clear floor space to reach the operable part as specified on 305.  The clear floor space should have a slope no steeper than 1:48 (2%) in all directions.
the slope at the push button door opener was steeper
than 2%
3) and the operable part should be the type that will not require tight grasping and twisting of the wrist and no more than 5 lbs, like explained before.
this feminine napkin dispenser operable part requires tight grasping and pulling to operate
this faucet has an operable part that requires graping and twisting to activate
Below are some more examples.

Fire Extinguisher cabinet

I get this question a lot about fire extinguisher cabinets:
“Do we mount the cabinet so that the top of the fire extinguisher is between 15″-48″ a.f.f.?”
The answer is no.  The reach range is for “operable parts” of fixed elements.  So a fire extinguisher would not be the operable part, but the handle to open the cabinet would be.  So one should locate the fire extinguisher cabinet door handle between 15″-48″ a.f.f.
the operable part is the handle to open the cabinet door

Emergency Nurse calling

Another operating mechanism that is confusing is the emergency call button located in medical care facilities and long term care facilities. They are used when a patient or resident needs a nurse.  They are typically located next to the toilet and in the shower and they are required to have a string that reaches the floor.  The string is used if a patient or resident falls and they need to pull the string if they can’t get up.
this call button has a red lever that can be pushed down with a closed fist which has a compliant operable part
this call button also has a lever that can be pushed down with a closed fist which is a compliant operable part
this call button is only able to be activated by grasping and pulling the string. This would not meet the requirements for accessible operable parts
In order for the call button to be compliant, it must not only have the string, but it should have a second way of calling the nurse which will not require tight grasping and pulling.

Adjustable mechanism at the hand held shower

One of the operating mechanism that is forgotten is the one required to adjust a hand held shower unit.
the hand held unit height can be adjusted using the wheel next to the vertical bar.  The wheel requires tight grasping and twisting to
operate it and therefore not a compliant operating mechanism.
Once the height is adjusted, the mechanism to loosen or tighten the adjustable part is not always used again.  But the initial action to adjust must meet the requirements.  So the adjustable mechanism must also comply.
this mechanism does not require tight grasping to loosen or tighten
this adjustable mechanism requires pinching to loosen

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Turning Space Requirements

Wednesday, May 2nd, 2018

Let’s understand the turning space requirements:

A turning space within a room or space is typically depicted by a dashed circle or a dashed “T”. It is an imaginary space that we allocate for turning by a person in a wheelchair. But it can really be located anywhere within that room or space as long as there is adequate room and no obstructions. There are some restrictions for the turning space, and this newsletter will explain them.

Where are turning spaces required?

A turning space is not required in every space. The ADA requires turning spaces in the following spaces:
1) Toilet and bathing rooms

2) Saunas and Steam rooms

3) Dressing, Fitting and Locker rooms

4) Patient rooms in medical care and long term care facilities

5) Kitchens and Kitchennettes

6) Holding cells
7) courtrooms
8) All rooms in a residential dwelling unit served by an accessible route (except if that space is less than 30″ wide or deep)

9) Amusement ride loading zones
10) Fishing piers
11) Play components in the same level (or next to a swing)
12) Shooting facilities

ANSI A117.1 also requires turning space at doors in series

Changes in Level at Turning Spaces

Besides the size of the turning space as shown in the introduction, the ADA also requires that the turning space have a stable firm and slip resistant ground surface, no slope greater than 1:48 and no changes in level are allowed.

304.2 Floor or Ground Surfaces. Floor or ground surfaces of a turning space shall comply with 302. Changes in level are not permitted.

EXCEPTION: Slopes not steeper than 1:48 shall be permitted.

But in the same section, there is an advisory that explain “changes in level”

Advisory 304.2 Floor or Ground Surface Exception.
As used in this section, the phrase “changes in level” refers to surfaces with slopes and to surfaces with abrupt rise exceeding that permitted in Section 303.3.

In other words, if you have a change in level that meets the exact requirements in section 303, but doesn’t exceed them, then it is permitted within the turning space.

Below are the figures which illustrate the two changes in level that are permitted within a turning space.

A change in level that is 1/4″ tall is acceptable in a turning space

A change in level that is 1/2″ tall with a beveled edge is also acceptable

So how does this information get applied? One example is a restroom with a roll-in shower.

Can the turning space be partly inside the shower as shown in the image above? What if the shower had a 1/2″ curb? Then can the turning space be partially inside the shower?

The answer is, yes, if the curb meets the requirements of Figure 303.3.

a collapsable curb can be part of a turning space as long as it collapses to 1/4″ max

Need Barrier Free CEUs?

Online courses:

Green CE On Demand Webinar: “Understanding the 2010 ADA Standards for Accessible Design”

Green CE On Demand webinar “How Accessible is Your work place?”

Green CE On Demand webinar “ADA and Residential Facilities”

AIA U online course: “Applying the ADA on Existing and Altered Buildings”
or
Green CE “Applying the ADA on Existing and Altered Buildings”

If you want to learn more about these standards, be sure to check out my books:
“The ADA Companion Guide” “Applying the ADA” published by Wiley.
book cover

(also available as an e-book)