Public Spaces

April 2023: Updates to Signage in the 2010 ADA

Monday, April 3rd, 2023

Accessible signage can be a very confusing topic. Even after all these years of practicing my accessibility consulting, I am still learning a thing or two. Sadly they can even be confusing to signage manufacturers and installers.

Accessible signs require the following things:

  1. Raised and Brailled Characters
  2. Contrasting background
  3. San Serif Fonts
  4. Height and location
  5. If using Pictogram, there are requirements
  6. If depicting accessible spaces the use of the ISA (International Symbol of Access)

This newsletter will focus on a few common errors I encounter during my inspections mainly about Raised and Braille characters, contrasting background and location

 

Raised Characters

The accessible signage will require that the characters describing the space whether it be a number or letters, must be raised. They should be at least 1/32″ above the surface of the sign.

This graphic shows the minimum requirement for the raised characters of a sign.
There should also be Braille below the words that states the same words that are provided. So all words and numbers should be duplicated by Braille

The restroom had a painted sign on the door but the characters were not raised and it did not have brailled as a duplicate. This is not compliant

This restroom has more than six toilets and urinals combined, therefore one compartment should be for wheelchairs and one compartment should be for other mobility devices (ambulatory)

Contrasting Background

At one of my inspections I encountered some signs that were all white. The raised characters were white as well as the background. The raised characters and the background were too similar in color and therefore there was no adequate contrast.

The requirement for contrasting color is intended for people with low vision. The sign would be too difficult to read without contrast.

 

The sign shown above did not have the required contrast between the raised characters and the background

Location

Signage that identify permanent rooms must be located on the latch side of the door or as close as possible on the latch side of the door. It must be located between 48″-60″ to the bottom of the raised characters and there must be a floor space of 18″x18″

The sign shown above did had a drinking fountain at the floor area and did not have a clear 18″x18″ at the floor in front of the sign

In addition to permanent rooms, signage with Braille and raised characters must also be located at Exit Stair, Exit Passage Way and Door

ADA Section 216.4.1 Exit Doors. Doors at exit passageways, exit discharge, and exit stairways shall be identified by tactile signs complying with 703.1, 703.2, and 703.5.

In addition to permanent rooms, signage with Braille and raised characters must also be located at Exit Stair, Exit Passage Way and Door

ADA Section 216.4.1 Exit Doors. Doors at exit passageways, exit discharge, and exit stairways shall be identified by tactile signs complying with 703.1, 703.2, and 703.5.

When are accessible signs NOT required?

Not all signs have to meet the accessibility guidelines. Here are the ones that do not required raised characters, brailled etc.

1. Building directories, menus, seat and row designations in assembly areas, occupant names, building addresses, and company names and logos shall not be required to comply with 216.2.

2. In parking facilities, signs shall not be required to comply with 216.2, 216.3, and 216.6 through 216.12.3.

3. Temporary, 7 days or less, signs shall not be required to comply with 216.4. In detention and correctional facilities, signs not located in public use areas shall not be required to comply with 216

 

Wheelchair accessible vs. Ambulatory Toilets

Wednesday, March 1st, 2023

One of my clients inspired me to write this newsletter. She asked me how many toilets needed to be accessible by the 2010 ADA/2012 TAS. This newsletter will cover multi-user restrooms, single user restrooms and restrooms that could be used for both adults and children.

Multi-User Restrooms

In a multi-user (Gang restroom) one of the toilet compartments must have an accessible toilet used for wheelchairs. The size depends on whether the toilet is wall hung or floor mounted. Also if you are designing for children and they will be the primary user, then the size will be similar to having a floor mounted toilet even if you use a wall mounted. See the figure below

The ADA and TAS has an advisory describing what is a toilet compartment:

Advisory 213.3.1 Toilet Compartments. A toilet compartment is a partitioned space that is located within a toilet room, and that normally contains no more than one water closet. A toilet compartment may also contain a lavatory. A lavatory is a sink provided for hand washing. Full-height partitions and door assemblies can comprise toilet compartments where the minimum required spaces are provided within the compartment.

This is the figure found in the 2010 ADA and the 2012 TAS that shows the size of the wheelchair toiilet compartment.

This photo shows mulitple toilet compartments. Only one compartment will have to be provided for wheelchair users. And there are more than six toilet compartments which also requires an ambulatory compartment.

What is an Ambulatory compartment?

If the restroom has six or more waterclosets/toilets and urinals then the ADA and TAS requires that an ambulatory toilet compartment be provided IN ADDITION TO the wheelchair toilet compartment. These are for people who use other mobility devices such as walkers, crutches, etc.

2010 ADA 213.3.1 Toilet Compartments. Where toilet compartments are provided, at least one toilet compartment shall comply with 604.8.1. In addition to the compartment required to comply with 604.8.1, at least one compartment shall comply with 604.8.2 where six or more toilet compartments are provided, or where the combination of urinals and water closets totals six or more fixtures.

This figure shows the requirements for ambulatory toilet compartments. Notice the depth. Even though the wheelchair toilet compartment allows a 56″ depth, the ambulatory requries a minimum of 60″.

This figure shows a person that uses a cane using the ambulatory toilet compartment.

This restroom has more than six toilets and urinals combined, therefore one compartment should be for wheelchairs and one compartment should be for other mobility devices (ambulatory)

Single User Toilet Rooms

The ADA and TAs both require that EVERY toilet room provided be accessible.

213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603.
There are several exceptions to this:
EXCEPTIONS:
1. In alterations where it is technically infeasible to comply with 603, altering existing toilet or bathing rooms shall not be required where a single unisex toilet room or bathing room complying with 213.2.1 is provided and located in the same area and on the same floor as existing inaccessible toilet or bathing rooms.
2. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, no fewer than one toilet room for each sex complying with 603 or one unisex toilet room complying with 213.2.1 shall be provided.
3. Where multiple single user portable toilet or bathing units are clustered at a single location, no more than 5 percent of the toilet units and bathing units at each cluster shall be required to comply with 603. Portable toilet units and bathing units complying with 603 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
4. Where multiple single user toilet rooms are clustered at a single location, no more than 50 percent of the single user toilet rooms for each use at each cluster shall be required to comply with 603.
Based on exception 4, when you have single user restrooms in a cluster, then only 50% are required to be accessible. Make sure you round up to the nearest whole number (so if you have three restrooms in a cluster, you would need two accessible ones)

 

This image shows two single user restrooms in a cluster and only one would have to comply. They opted not to take the exception, but they could have.

In a single user restrooms is provided with one toilet, then that one toilet must be accessible. If the single user restroom has two toilets, again only one of the toilets is required to be accessible.

213.3.2 Water Closets. Where water closets are provided, at least one shall comply with 604.213.3.3

 

This restroom shows two toilets. Even though one is for adults and one is for children, the ADA only requires that one be accessible. Of course this is a minimum requirement and would be a good idea to have both be accessible since they will be used by different people.

Electrical Vehicle Charging Stations

Wednesday, February 1st, 2023

Electrical Vehicles are very popular and the need for Electrical Vehicle Charging Stations (EV) has been on the rise. Even though there were electrical vehicles before the ADA Standards were published and there were Electrical Vehicle Charging Stations (EV), the ADA did not have requirements for accessible electrical vehicle parking or charging stations. The US Department of Energy did issue a directive on work place EV stations, but it has not been adopted as part of the ADA.

“As the U.S. Department of Justice has not issued formal accessibility guidelines addressing electric vehicle charging stations, the Texas Department of Licensing and Regulation issues the following technical clarifications until such time as federal standards become available and are adopted”.The Texas Department of Licensing and Regulation (TDLR) issued Technical Memo TM 2012-01 which gives the requirments for the electrical vehicle charging parking spaces and this newsletter will explain and give examples.

Electrical Vehicle Charging Stations

Per TM 2012-01: “If electric charging stations are provided in new or existing parking lots, parking garages or other location containing parking spaces, twenty percent (20%) but not less than one, of each type of charging station in each cluster on a site shall meet the following criteria:

In the photo above, there are no accessible EV stations. 20% but not less than one of these electrical vehicle charging stations are required to be provided for persons with disabilities.

Each cluster of electrical vehicle charging spaces will have to comply with the 20% rule.

Controls:

Controls and operating mechanisms for the accessible charging station shall comply with TAS 309 and shall be within the forward reach ranges specified in TAS 308.2;

Charging stations must have a clear floor space measuring 30″x48″ minimum so a person in a wheelchair can approach it and use it. That clear floor space, must have a slope of 2% in all directions.

There is a bollard in the way of the controls at this EV station

Charging stations controls should be within reach range for either a forward or side approach depending on the space allowed. The controls in the photo above shows it far from the edge and higher than 48″ a.f.f. which appears to not be within reach.

Size of Vehicle spaces and access aisle

Per TM 2012-01: The vehicle space(s) with the accessible charging station shall be at least 96 inches wide and shall provide a 36 inch wide (minimum) accessible route complying with TAS 402 on both sides of the vehicle space to allow the user adequate space to exit their vehicle and access both sides of the vehicle.


The charging stations in the photo above shows the two 36″ aisle on both sides of the space.
Signage:

Directional and informational signage complying with TAS 216.3/703.5 shall designate the location of the accessible charging stations.

 

If not all EV stations are accessible, there needs to be a directional signage that shows a person with disabilities where it is located.

Some recommendations: NOT MANDATORY

Striping of the accessible routes is recommended but not required.

The striping at the accessible route is not required, but it is advisory to provide it. This is an image from the California code

The symbol of accessibility is recommended but not required.

The International Symbol of Accessibility shown in the photo above is for the accessible parking space which is also being used as the accessible EV station. The accessible EV station may not be the accessible parking for non-electrical vehicles. They must have its own separate parking spaces.

The International Symbol of Accessibility shown in the accessible electrical vehicle charging station parking space is not rerquired. The photo above shows the symbol, but it does not meet the minimum requirements in Texas or California

The signs above are examples and layout of signage. They are for illustrative purposes only and are not intended to imply that there are no other options available.

When does the ADA Require a centered approach?

Thursday, September 1st, 2022

Part 2

We have been discussing when we should make our clear floor space centered on the elements. This is a continuation of the commercial guidelines outlined in the ADA. For Part 1 refer to the August Newsletter.
Below are some other instances that the ADA will require that there be a clear floor space that is centered.

Residential Kichen Work Surface

In kitchens of residential dwelling units (not located in multi-family housing, but required by section 233 to be accessible, there is a requirement to provide a “work surface” with a knee clearance with a floor space centered and allowing a forward approach.
804.3 Kitchen Work Surface (Residential only)
804.3.1 Clear Floor or Ground Space. A clear floor space complying with 305 positioned for a forward approach shall be provided. The clear floor or ground space shall be centered on the kitchen work surface and shall provide knee and toe clearance complying with 306.

 

The image above shows a residential kitchen with a sink as well as a “work surface” which provides a forward approach. The work surface is required that the clear floor space below it be centered at the surface. The sink is not required to provide a clear floor space that is centered.

The image above shows a residential kitchen work surface and it is centered at the surface.

Altered Sales and Service counter

When an existing sales and service counter is altered, they must provide an accessible portion. Typically a sales or service counter must be 36″ long minimum, but if they cannot accommodate that length they would be allowed to only provide a 24″ counter as long as there is a clear lfoor space centered and parallel to the counter.
904 Sales and Service counters
904.4 Sales and Service Counters.
EXCEPTION: In alterations, when the provision of a counter complying with 904.4 would result in a reduction of the number of existing counters at work stations or a reduction of the number of existing mail boxes, the counter shall be permitted to have a portion which is 24 inches (610 mm) long minimum complying with 904.4.1 provided that the required clear floor or ground space is centered on the accessible length of the counter.

The image above shows an example of a counter which has a parallel approach at the lower counter and the clear floor space is also centered at the accessible portion. The length is unknown, but this would be an example of how the exception could be taken.

Playground transfer system

When playgrounds have elevated components that require an accessible route, one way that they can reach the elevated portion is via a transfer system. That transfer system will also require to have a parallel clear floor space centered at the platform.
1008.3Playground Transfer Systems
1008.3.1.3 Transfer Space. A transfer space complying with 305.2 and 305.3 shall be provided adjacent to the transfer platform. The 48 inch (1220 mm) long minimum dimension of the transfer space shall be centered on and parallel to the 24 inch (610 mm) long minimum side of the transfer platform. The side of the transfer platform serving the transfer space shall be unobstructed.

The image above shows a transfer system at an elevated play structure. There is room for the clear floor space to be centered at the platform.

Pool transfer walls and platforms

Pools and spas (jacuzzis/hot tubs) are required to have an accessible entry (or two depending on the size of the pool). There are several options for the accessible entry. One is a transfer wall and another a transfer platform. The transfer wall or the transfer platform must have a clear floor space centered at the deck to assist with entry to the pool.
1009.4 Pool Transfer Walls
1009.4.1 Clear Deck Space. A clear deck space of 60 inches (1525 mm) minimum by 60 inches (1525 mm) minimum with a slope not steeper than 1:48 shall be provided at the base of the transfer wall. Where one grab bar is provided, the clear deck space shall be centered on the grab bar. Where two grab bars are provided, the clear deck space shall be centered on the clearance between the grab bars.

The image above shows a transfer wall with two grab bars at a jacuzzi. There is room for the clear floor space to be centered between the two grab bars.

1009.5 Pool Transfer Platform

1009.5.2 Transfer Space. A transfer space of 60 inches (1525 mm) minimum by 60 inches (1525 mm) minimum with a slope not steeper than 1:48 shall be provided at the base of the transfer platform surface and shall be centered along a 24 inch (610 mm) minimum side of the transfer platform. The side of the transfer platform serving the transfer space shall be unobstructed.


 

1) Texas Association of Interior Design

September 12th

2:10 p.m.

Ludowici Dallas Design Center | 133 Manufacturing St, Dallas, TX 75207

or online available

2) ALSA Oklahoma City

3:00 p.m.

When does the ADA require a centered approach?

Monday, August 1st, 2022

Part 1

In the 2010 ADA and the 2012 Texas Accessibility Standards there are certain elements that require front approach and centered clear floor space on the element, but not all of them do. This newsletter will enumerate the one’s that do. Other elements such as lavatories and sinks only require forward approach but the clear floor space is not required to be centered.

Below are the elements that require a clear floor space to be centered:

Drinking fountains

Drinking fountains are one of the elements listed in the ADA and TAS that require that the wheelchair drinking fountain have a clear floor space centered on the unit. The clear floor space must also be a forward approach.

602 Drinking Fountains

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

 

The image above shows the required clear floor space at the drinking fountain. It must be a forward approach and it must be centered on the wheelchair accessible drinking fountain. If it is located at an alcove deeper than 24″ the clear floor space must be widened to 36″ wide.

There are two violations that occurr with this requirement. One is that sometimes the drinking fountains are located along a corridor and not in an alcove. This creates a protruding object issues (see this newsletter that explains that). In order to resolve the protruding object, a cane dectable apron is sometimes installed at the bottom of the “high” drinking fountain and the apron reduceds the ability to have a forward approach because it might be lower than 27″ a.f.f.

The image above shows how the clear floor space centered under the “low” drinking fountain spans below the “high” one and if there is an apron below the 27″ a.f.f. it will prevent the use of the drinking fountain by a wheelchair.

Number two is that sometimes the drinking fountains are located in an alcove and the walls creating the alcove reduce the 30″ clearance which must be centered. The wall adjacent to the wheelchair accessible drinking fountain should be a minimum distance of 15″ from the centerline of the drinking fountain to the inside of the wall.

The image above shows how the clear floor space centered under the “low” drinking fountain must be a minimum of 15″ from the center of the drinking fountain to the inner edge of the alcove.

Washer and Dryer

The washer and dryer must also have the clear floor space centered on the appliance and must have parallel approach.
611 Washer and Dryer

611.2 Clear Floor Space. A clear floor or ground space complying with 305 positioned for parallel approach shall be provided. The clear floor or ground space shall be centered on the appliance.

This sometimes causes issues if the washer and dryer are located inside a closet. The doors may reduce the clearance.

The image above shows a set of washer and dryer located inside a utility closet. The doors do not open 180 degrees and reduce the clear floor space to less than 24″ from the centerline of the dryer to the edge of the floor space.

Signage

The signage that designate permanent rooms must have an 18″x18″ clear floor space centered on the sign.

703 Signage

703.4.2 Location. ….Signs containing tactile characters shall be located so that a clear floor space of 18 inches (455 mm) minimum by 18 inches (455 mm) minimum, centered on the tactile characters, is provided beyond the arc of any door swing between the closed position and 45 degree open position.

The image above shows a sign which has a drinking fountain in front of it, therefore the requirement for a clear floor space centered on the sign has not been met.

Lavatories and Sinks

One of the misconceptions is that a clear floor space at the sink or lavatory is required to be centered. The approach must be forward, but the clear floor space is not noted as needing to be centered, like the other sections do. Therefore by omission we understand that the clear floor space can be offset.

606 Lavatories and Sinks

606.2 Clear Floor Space. A clear floor space complying with 305, positioned for a forward approach, and knee and toe clearance complying with 306 shall be provided.

The image above shows a wheelchair clear floor space that is not centered at the lavatory. The clear floor space under the lavatory can be offset if there is an obstruction such as a paper towel dispenser next to the lavatory.

 

July 2022: Inspector’s Corner-Products

Friday, July 1st, 2022

July 2022: Inspector’s Corner

I do ADA inspections every Wednesday and I always find some interesting things that I wanted to share. Here are some interesting solutions and products that are good for accessibility, and I will show them in this newsletter.

Diaper Changing Counters and Cane Detection

A diaper changing counter will sometimes be located in a circulation path around the restroom and when it is left open it can be a protruding object. TDLR issued a technical memo on the topic. Here is the linkAt some of my inspections I have seen some interesting ways of handling this:

The figure above shows the requirements for objects mounted in a circulation path so they will not be hazards for people with visual impairments.

The photo above shows a diaper changing counter in the open position and located on the circulation path to the toilet compartments and exit door and is a protruding object.

Recently I have seen this Koala diaper counter installed. What is unique and interesting about it is that they are taking into consideration the “protruding object” concern and they have designed it so that the handle you use to open it, once it is in the down position, acts as cane detection.

This diaper counter’s handles will reach below 27″ a.f.f. if installed correctly and it acts as cane detection.

 

Reflective Surface at Mirrors

Most of us understand the rule about mirrors over lavatories or sinks. They must be located so that the reflective surface is not higher than 40″ a.f.f. I was recently at an inspection where the mirror had a frame as part of the mirror where the outer edge was the reflective surface, then frosted glass and back to the reflective surface. Obviously, the intent was for a person in a wheelchair to be able to see themselves in the mirror, so although technically there is a reflective surface at 40″ a.f.f., the real “mirror” was above that.

The mirror in the picture above has a frosted glass frame that has an outer edge made of the reflective surface of the mirror.

The “reflective” surface of the mirror (as the Standards intended) will be the one above the frosted glass, even though there is a reflective surface below the frosted glass.


 

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Pictograms on Signs

Wednesday, June 1st, 2022

Introduction:

Accessible signage can be a very confusing topic. Even after all these years of practicing my accessibility consulting, I am still learning a thing or two. Sadly they can even be confusing to signage manufacturers and installers.
Accessible signs require the following things:
  1. Raised and Brailled Characters
  2. Contrasting background
  3. San Serif Fonts
  4. If using Pictogram, there are requirements
  5. If depicting accessible spaces the use of the ISA (International Symbol of Access)
This newsletter will focus on a few common errors I encounter during my inspections.

Raised Characters

The accessible signage will require that the characters describing the space whether it be a number or letters, must be raised. They should be at least 1/32″ above the surface of the sign.

This graphic shows the minimum requirement for the raised characters of a sign.

There should also be Braille below the words that states the same words that are provided. So all words and numbers should be duplicated by Braille

The restroom had a painted sign on the door but the characters were not raised and it did not have brailled as a duplicate. This is not compliant

The restroom sign has both raised letters and characters and braille duplicated below the words. This is a compliant sign..

Pictograms

What are pictograms? It is a figure that represents the words of the sign. Pictograms are not required, but if you use them the field they are in should be 6″ minimum. The pictogram can be smaller than that, but the field must be at least 6″ tall.

Pictograms must be located ABOVE the words they are describing. Per section 703
703.6.3 Text Descriptors. Pictograms shall have text descriptors located directly below the pictogram field. Text descriptors shall comply with 703.2, 703.3 and 703.4.

The pictogram at this sign is located below the words describing it. That is not compliant

Changes coming to the Texas Accessibility Standards

Monday, May 2nd, 2022

Introduction:

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

Introduction:

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

Introduction:

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