This newsletter will be discussing the requirements for the 2010 ADA Standards for Accessible Design as well as the 2012 Texas Accessibility Standards. Other Standards and Codes might have different requirements

Accessible Means of Egress

Every once in a while I receive a phone call asking me about accessible exits. They wonder about the location of the exit, whether the door needs to be accessible, about stairs, stoops etc. My answer always confuses them:

The photo shown above is an exit door that has hardware on the exterior. If this door is also an entrance then it will have to comply

Section 207 of the ADA and TAS has two exceptions that might not be the same as the IBC:

1. The accessible means of egress can share the common path of egress if permitted by local building or life safety codes
2. Areas of refuge shall not be required in detention and correctional facilities.

There is an advisory, not required but advisable that the ADA and TAS also have regarding the accessible means of egress:

Advisory 105.2.4 ICC/IBC.

International Building Code (IBC)-2000 (including 2001 Supplement to the International Codes) and IBC-2003 are referenced for means of egress, areas of refuge, and railings provided on fishing piers and platforms.

At least one accessible means of egress is required for every accessible space and at least two accessible means of egress are required where more than one means of egress is required.

The technical criteria for accessible means of egress allow the use of exit stairways and evacuation elevators when provided in conjunction with horizontal exits or areas of refuge. While typical elevators are not designed to be used during an emergency evacuation, evacuation elevators are designed with standby power and other features according to the elevator safety standard and can be used for the evacuation of individuals with disabilities.

The IBC also provides requirements for areas of refuge, which are fire-rated spaces on levels above or below the exit discharge levels where people unable to use stairs can go to register a call for assistance and wait for evacuation.

Signage at the accessible means of egress is also required by ADA and TAS. Those rules will not be covered in this newsletter, but can be found in section 216.4

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Recessed Fixtures adjacent to water closets

In the ADA Standards, Texas Accessibility Standards and ICC ANSI A117.1 the rear wall grab bar is required to be a minimum 36″. There is an exception to be able to use a shorter when the water closet is located on the same wall as a recessed plumbing fixture.

604.5.2 Rear Wall. The rear wall grab bar shall be 36 inches (915 mm) long minimum and extend from the centerline of the water closet 12 inches (305 mm) minimum on one side and 24 inches (610 mm) minimum on the other side.

EXCEPTIONS:

1. The rear grab bar shall be permitted to be 24 inches (610 mm) long minimum, centered on the water closet, where wall space does not permit a length of 36 inches (915 mm) minimum due to the location of a recessed fixture adjacent to the water closet.

This is a plan view of the recessed shower adjacent to the water closet which creates the wall condition too short to install a 36″ grab bar. This condition is also allowed to have a 24″ rear wall grab bar installed centered on the toilet.

Recessed Doors

A door that is located within a wall that is no thicker than 8″ measured from its face to the front of the wall will be considered a “recessed” door. Also if there is an object located next to the door latch and it is not 8″ perpendicular from the face of the door to the front of the object, it will also be considered a “recessed” door.

404.2.4.3 Recessed Doors and Gates. Maneuvering clearances for forward approach shall be provided when any obstruction within 18 inches (455 mm) of the latch side of a doorway projects more than 8 inches (205 mm) beyond the face of the door, measured perpendicular to the face of the door or gate.

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The door shown above has a trash receptacle within the maneuvering clearance. Since the trash receptable is less than 8″ it is allowed to be included in the manuevering clearance to reach the door handle

The door shown above is located in a small alcove that is 8″ deep. The maneuvering clearance will be acceptable for a “recessed” door.

Recessed elements in Alcoves

A clear floor space for wheelchairs is required to be a minimum of 30″ x 48″. But if an element is located in an alcove that is more than 24″ deep, then the clear floor space will need to increase to 36″ wide for a forward approach or 60″ long for a side approach.

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The drinking fountain shown above is an alcove and therefore the clear floor space must be 36″ min. wide

The urinal shown above is an alcove and therefore the clear floor space must be 36″ min. wide. The width was less than 36″

Cane detectable apron

Lately I have been observing during my ADA/TAS inspections that most drinking fountains for standing people will have a cane detectable apron. A cane detectable apron is an item that is offered by the drinking fountain manufacturer in order to make their drinking fountains detectable for persons who are visually impaired. Since the person cannot see, they need to “feel” their way around. A person who uses a white cane to detect their environment will only be able to detect objects mounted at 27″ a.f.f. or below.

WBeware that there is a requirement that the clear floor space for the wheelchair accessible drinking fountain must be centered. This means that if the low drinking fountain is adjacent the high drinking fountain, half of the 30″ clear floor space will be located under the drinking fountain for standin persons.

If a cane detectable apron will be required at the high drinking fountain, it cannot be located lower than 27″ a.f.f. since it will also reduce the knee clearance for the low drinking fountain located adjacent to it.

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When is the apron NOT needed?

If the drinking fountains are already in an alcove, or a recess, then they will not need a cane detectable apron because the built in elements becomes the cane detection.

The cane detectable apron was not needed, sine they built walls to create an alcove where the drinking fountains would be mounted. These were not in a circulation path. In addition, they added the aprons to the low drinking fountain and reduced the knee space to less than 27″ a.f.f.

When there are misunderstanding

If I have seen many projects where cane detectable aprons are added when they are not needed.

• They are added at the drinking fountains for wheelchair users which then reduce the knee clearance
• They may be added when the drinking fountain is recessed
• They may be added lower than 27″ a.f.f. which reduces the knee clearance at the drinking fountain for wheelchair users adjacent.

The cane detectable apron was mounted at the wheelchair accessible drinking fountain which reduced the knee clearance

Introduction

There are times during inspections that I find some interesting cases of either violations to the ADA/TAS or some innovation in design that I sometimes share with my clients for them to learn for future projects.

Below are some examples:

But it is only finishes……

If you read my last newsletter (June: Alterations vs. Maintenance) I explained about alterations as defined by the ADA Standards as well as TAS. One of the still misunderstood projects that is considered alterations are flooring changes. The definition of alteration includes “re-surfacing of circulation paths”. A circulation path would include any flooring or ground surface where people walk or use their mobility devices on.

Alteration: A change to a building or facility that affects or could affect the usability of the building or facility or portion thereof. Alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, resurfacing of circulation paths or vehicular ways,

changes or rearrangement of the structural parts or elements, and changes or rearrangement in the plan configuration of walls and full-height partitions.

Flooring changes, even if it is replacing a floor finish with the SAME floor finish (carpet with carpet) will be considered an alteration and the ADA standards and the TAS will have to be applied. So what sections would apply?

Section 302 which requires firm, stable and slip resistant flooring. No openings greater than 1/2″.

Section 303 no changes in level greater than 1/4″ without a bevel, 1/2″ with a bevel or ramp when greater than 1/2″

And if the flooring occurs in areas that are considered a primary function, it will also trigger compliance with section 202.4

This figure shows the handrail extension that extends horizontally above the landing and returns to the post.

At several inspections recently, I have encountered handrails that rather than extending 12″ horizontally in the same direction of the ramp run beyond the top or bottom of the ramp run, they eiither turn 90 degrees, or don’t fully extend.

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This photo above shows a handrail that did not extend 12″ beyond the bottom of the ramp run

The handrail in the photo above did not extend 12″ in the same direction as the ramp run, but rather it turns 90 degrees which is not an extension and it is not allowed (unless the ramp was existing per excepton listed below)

There are a few exceptions for when handrails do not have to extend:

EXCEPTIONS:

1. Extensions shall not be required for continuous handrails at the inside turn of switchback or dogleg stairs and ramps.

2. In assembly areas, extensions shall not be required for ramp handrails in aisles serving seating where the handrails are discontinuous to provide access to seating and to permit crossovers within aisles.

3. In alterations, full extensions of handrails shall not be required where such extensions would be hazardous due to plan configuration.

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

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

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 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.

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:

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.

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

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

“Applying the ADA and TAS to Interior Design Projects”

September 12th

2:10 p.m.

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

or online available

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: