Public Spaces

Accessible Counters

Thursday, July 1st, 2021

Abadi Accessibility is proud to support the Americans with Disabilities Act (ADA) 31st Anniversary. On July 26th we celebrate this important civil rights law that works to ensure all people with disabilities have the same rights and opportunities as everyone else. Celebrate with us by visiting: www.adaanniversary.org/ #ADA31 #ThanksToTheADA

How are you planning to celebrate Americans with Disabilities Act (ADA) 31st Anniversary? This July 26th the ADA National Network and individuals, communities, and organizations across the country will be participating. Learn how you can be involved by visiting www.adaanniversary.org/ #ADA31 #ThanksToTheADA

Introduction to our newsletter:

After I wrote my first newsletter about counters, my clients are still not clear on all the different requirements for the different types of counters and fixed or built-in surfaces that the ADA requires to be accessible. First of all let me review that there are five type of counters scoped in the ADA Standards: Work surfaces, dining counters, service counters, sales counters and check out counters. Then there are two type of counters that are not scoped: work area counters and non-work area common use counters that do not fall under the other listed. There are also Food service lines, as well as other portions public side service areas. For those please check out my newsletter I wrote I 2014.

This newsletter will explain the different requirements for dining surfaces, non-employee work surfaces and sales and service counters.

Dining Counters

According to Scoping section 226, at least 5% of seating spaces and standing spaces at dining surfaces must comply with 902. Standing spaces are those counters where people might stand to eat or drink rather than sit. Those counters must also comply. Some examples of dining counters are bars where drinks are served, fast food establishments with fixed tables, and booths and banquettes at a restaurant.

These fixed dining counters in a cafeteria is an example of a dining surface.

a bar is an example of a dining surface

Section 902 gives us direction on how to make the dining surfaces accessible:

  1. There must be a knee clearance complying with section 306 so that a person in a wheelchair will approach and use the counter in a forward approach
  2. The height of the counter must be between 28″-34″ a.f.f. PLEASE NOTE….WE RECOMMEND TO NEVER USE THE MINIMUMS OR MAXIMUMS WHEN DESIGNING.

A dining counter should have a 30″ width and a 17″ min. depth at the knee clearance.

A dining counter has a forward approach knee clearance and it is 34″ a.f.f.

This is a dining counter but also a service window. It is acceptable to have the dining counter in front of the service counter

Non-Employee Work Surfaces

Section 226 tells you that 5% of non-employee work surfaces must comply and meet the requirements set forth in section 902. These are also required to be dispersed throughout the space they are in. Section 902 states that a work surface must have a forward approach with a knee space per section 306 and be 30″ wide minimum and 34″ high maximum

Study carrols in a library is an example of a non-employee work surface

Diaper changing counters are also considered a “work surface”

A patient registration desk is another example of a non-employee work surface

All the requirements in section 902 are for non-employee work surfaces (or for the public). Employee work surfaces that are part of a work area are exempted until such time when a person with disabilities is hired at which point, the surface must be provided to accommodate them and their abilities.

Sales and Service counters

Where provided, at least one of each type of sales counter and service counter shall comply with 904.4.

Where counters are dispersed throughout the building or facility, counters complying with 904.4 also shall be dispersed.

Keep in mind that the requirements are the either sales or service counters. The term “transaction” is no longer used. A transaction could occur but it is not the only pre-requisite for compliance.

The counter shown above has different functions (some are sales and some are service). Each one must have a portion at an accessible height

Section 904 gives us the following requirements for sales and service counters:

  1. 36” high maximum
  2. Same depth as the main counter
  3. 36” length min.
  4. Parallel approach OR Forward approach allowed

the accessible couter must be 36″ a.f.f. maximum and at least 36″ long

A sales or service counter can have either with a forward approach knee clearance or a parallel or side approach.

The accessible portion of the counter must be the same depth as the main (or public) side of the counter. Even though the reception counter is deeper than the public counter, the accessible portion will only have to be 36″ a.f.f. maximun and 36″ min. long the same depth as the public counter (which can be higher than 36″ a.f.f.)

The reception desk is considered a “service” counter because information is a service a business would provide to their guests. The one shown above did not have a 36″ long counter

A service or sales counter may not be the type that is flipped up, or pushed in once it is used. it must be a permanent counter that is always available.

Inspector’s Corner

Tuesday, June 1st, 2021

Inspector’s Corner

Today’s newsletter I bring you some examples of violations that I found during my on site inspections. These specific ones are violations that were made because the standards were not so well understood. Hopefully these examples will give you some clarity for future installations.

Clearance at the drinking fountains

The drinking fountains that are mounted along a circulation path might be a protruding object if the leading edge is higher than 27″ a.f.f. When the leading edge is higher than 27″ a.f.f. which most of the time it will be the drinking fountains for standing persons, then that drinking fountain will be considered a protruding object. To resolve the violation, we typically see a cane detectable apron installed at the bottom edge of the high drinking fountain. Since the high drinking fountain is not for people in wheelchairs, but for people who are standing but have trouble bending down to drink, a knee clearance is not required. So technically the cane detectable apron could be mounted at any height as long as it reaches a minimum of 27″ a.f.f.

The misunderstanding is of the requirement that the clear floor space of the wheelchair be located centered with the low unit for them to use

602.2 Clear Floor Space. Units shall have a clear floor or ground space complying with 305 positioned for a forward approach and centered on the unit. Knee and toe clearance complying with 306 shall be provided.

So that means that the 30″ clear floor space will be partially located under the high drinking fountain

If the cane detectable apron located at the high drinking fountain is lower than 27″ a.f.f., it will reduce the required knee clearance at the low drinking fountain

The cane detactable apron is lower than 27″ a.f.f. which reduces the knee clearance which is centered at the low drinking fountain

In order to not have that violation, the cane detectable apron must be mounted exactly at 27″ a.f.f.

Post-mounted protruding objects

(this is not exactly examples of violations, but rather why it is not a violation)

The rules for protruding objects allows post or pylon mounted obects to project 12″ from its mounting surface. The figure below is from the ADA and TAS section 307.3 which shows the parameters of the protrusion limits.

My example is from an interior play area where there was a statue of one of their characters mounted on a pylon or tall base. The statue had a little hand and pigtail that projected beyond the edge of the base. But because the ADA and TAS allows a 12″ protrusion limit along the circulation path, the statue was not a protruding object.

The little hand of the statue projected 6″ beyond the base, which was compliant.

 

Another example of a post mounted protruding object is a stand pipe located at a means of egress stair landing. Because the means of egress is essentially a circulation path it will require that the protrusion limits that the ADA and TAS describe in section 307 be adhered to.

The stand pipe in the photo below does have an extension where the valve is projecting more 12″ beyond the pipe and mounted higher than 27″ a.f.f.

The stand pipe is a protruding object because the valve projects more than 12″ from the post onto the circulation path

Pendant lights as protruding objects

Sometimes the protruding objects occurs because the object is mounted below 80″ a.f.f. Pendant lights can be protruding objects if mounted too low. The condition shown in the photos below shows a play room with furniture mounted below the pendant lights. The pendant lights are mounted at 70″ a.f.f. and therefore are protruding objects.
But you might be asking why is it a violation since the furniture acts as our cane detection?
Good question…
What is a misunderstanding is that the only cane detection that is allowed must be fixed or buil-in (see the requirement below)

201.1 Scope. These standards apply to fixed or built-in elements of buildings, structures, site improvements, and pedestrian routes or vehicular ways located on a site.

because the furniture below the pendant lights are movable and not built in they cannot be use as cane detection

the pendant light is mounted at 70″ a.f.f. and is considered a protruding object

ANSI A117.1 vs. ADA

Monday, May 3rd, 2021

The 2010 ADA Standards for Accessible Design (The ADA for short) is sometimes used as a catch-all term for all requirements for designing for persons with dissabilities. What is sometimes misunderstood is that the ADA is a Civil Rights law with design guidelines for public accommodations and commercial facilities. But there are other laws and standards that govern how to design for persons with disabilities that are different from the ADA and still have to be followed. One of the standards are found in the building code. If a municipality has adopted Chapter 11 of the IBC that chapter references another Standards call the ANSI A117.1. The ADA and ANSI are very similar, but there are some differences. In this newsletter I will give you a few examples.

For the sake of this newsletter I wilil be discussing the 2017 ANSI A117.1 Standards. This may or may not be the Standared that has been adopted by the municipality you are designing under and you will need to verify which version you need to follow. Not all the versions have the same requirements.

304 Turning Space

Both the ADA and ANSI A117.1 have requirements for the size of a circular turning space. They used to be the same (60″ diameter), but In the 2017 version of the ANSI the size increased to 67″ min.
Below is the new figure for the 2017 ANSI

604.5.2 Rear Wall Grab Bar

Both in the ADA and the ANSI the section that discusses the rear wall grab bars is 604.5.2 But the location of the grab bar is measured differently in the ANSI than in the ADA. this confuses most installers and we typically find ADA violations based on the assumption that they are both the same.

Note the figure below. It is from the 2017 ANSI A117.1 604.5.2

It shows that the rear wall grab bar is located in relation to the side wall. It should measure 6″ from the side wall to the inner edge of the grab bar and it should have an overall dimension of 42″ min. from the side wall to the outer edge.

This is figure ANSI A117.1 604.5.2 from the 2017 version

Note the figure below. It is from the 2010 ADA section 604.5.2

It shows that the rear wall grab bar is located in relation to toilet. It should also be 36″ long min. just like the ANSI, but we locate it from the center of the toilet so that there is 12″ min. from the center to the inner edge and 24″ min. from the center to the outer edge.
The ADA rear wall grab bar location has no relation to the side wall.

This is figure 604.5.2 from the 2010 ADA Standards. It shows the rear wall grab bar and its lcoation in relation to the toilet.

502 Parking

There are two sections that the ANSI has that the ADA does not: parallel parking and Electrical vehicle charging station parking.

502.9 Parallel Parking

The 2017 ANSI Standards has guidelines for parallel parking for on-street parking. It requires a vehicle space plus an access aisle parallel to the curb and a curb ramp or accessible route close to the spaces.

The figure 502.9.1 above shows on-street parallel parking

502.11 Electrical Vehicle Charging Stations

The 2017 ANSI Standards provide requirements for Electrical Vehicle charging stations. Some of them are

  • Operable parts should be within reach
  • There should be an access aisl adjacent to the parking space with clear floor sapce next to the unit
  • Any protection bollards, curbs and wheel stops should not be located so it obstructs the route or the reaching.

Accessible Benches: Where are they required and how to be compliant

Monday, January 4th, 2021

Where are accessible benches required?

Compliance with ADA Section 903 (Benches) shall be required only when specifically referenced in the 2010 ADA Standards for Accessible Design. This also applies to Texas 2012 Texas Accessibility Standards. There is no specific scoping for benches, except when they are required in the the different sections of the ADA Standards. Because the ADA Standards only deals with fixed or built in elements, benches must be fixed or built in as well.

Benches complying with section 903 are only required at the following spaces:

  • Saunas (per section 612)
  • Locker Rooms (per section 803)
  • Dressing Rooms (per section 803)
  • Fitting Rooms (per section 803)
  • Holding Cells (807)

And all those benches must follow the requirements in section 903:

903.2 A Clear Floor or Ground Space next to the short axis.

 

The bench shown in the figure above is inside a dressing room which requires that the bench have back support as well as the 30″x48″ clearance parallel with the short axis of the bench

903.3 Size should be 42″ long and between 20″ and 24″ deep

903.4 Back Support.

903.5 Height should be 17″-19″

903.6 will holds 250 lbs

903.7 at Wet Locations the seat shall be slip resistant and does not accumulate water.

Saunas and Steam Rooms ADA 612.2

The sauna has a bench with back support, the proper length of 42″ and depth of 24″ with a 30″ x 48″ space next to its short axis

Dressing, Fitting, and Locker Rooms ADA 803.4

Dressing rooms are typically private rooms in doctor’s offices, imaging centers etc. which are provided for the purpose of changing out of clothes and into other garments

 

This dressing room does not have a compliant bench because the bench is movable, the door swings into it and no 30″ next to its short axis .

Fitting rooms are private rooms provided at retail stores for the purpose of trying on clothing for purchase.

This dressing room does not have a compliant bench in the room.

This fitting room does not have a compliant bench because it doesn’t have a 30″ space next to the short axis

Locker rooms are also considered “dressing rooms” if the lockers are used to keep uniforms or clothing like at a gym or a medical building where people will change into clothes for a specific purpose.

This bench is located up against the wall in a locker room and therefore has back support. Note that the 30″x48″ clear floor space is in front of the door which (although not recommended) it is allowed

This locker room does not have a compliant bench. It lacks back support and it is not a minimum of 20″ deep.

This is a bench that is not up against the wall so back support per figure 903.4 was provided, but they did not provide the 30″ x 48″ space next to the short axis. The lockers were in the way reducing the clearance to 21″ (see next photo)

This photo is the dimension of 21″ between the edge of the bench and the edge of the lockers next to it. The clearance should have been 30″ minimum

Holding Cells and Housing Cells ADA 807.2.2

 

This holding cell has a bench with back support, but it does not have a 30″ clearance next to the short side.

Other Bench locations

There may be other locations where benches are used. If a fixed bench is provided in other spaces besides the ones specifically listed in the Standards, they do not have to comply with section 903. Below are other locations where benches may be provided, but do not have to comply with the standards or be on an accessible route.

Benches on the exterior

What about fixed or built in benches at courtyards, amphitheaters or or even at parks? If they are part of an assembly area (with four or more benches for the use of an audience or seating for spectators) then it would have to comply only with assembly seating per section 221 and 802.

Otherwise, these benches are not scoped and do not have to comply with the requirements in section 903.

The benches shown in the photos above are located in a park. These benches are not required to comply. Even the one at the basketball court is not considered assembly seating unless there are four or more and meant to be part of the spectator seating.

Benches at shower rooms

Shower rooms often have benches, but those are not required to comply because a shower room is not technically a “dressing” room even though dressing and undressing might occur inside.

Benches are different than shower seats. The photo below shows a shower with a bench but no seat.

The bench shown in the photos above are located in a shower room. It is not inside the shower and therefore not considered a shower seat. Benches are not required in shower rooms and therefore do not have to comply with the Standards.

Bus stops also might have a bench

The bench adjacent to the bus stop and the one located inside the bus stop are not required to comply with either section 903 or section 802.

ADA only requires compliance in dressing rooms, fitting rooms, locker rooms, saunas, and holding cells. The spaces shown above are not required to provide a bench, therefore if a bench is provided it will not have to comply.

TDLR has a Technical Memo that explains this fact.

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

Need Barrier Free CEUs?

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.