The photo above was taken inside a restroom. The paper towel dispenser is located in the circulation path to the lavatory

The situation pictured above is not idea, but if both grab bars are between 18″ and 27″ a.f.f. it is compliant with the ADA and TAS.

Fair Housing Showers

The Fair Housing Design Guidelines has a requirement that states that if a unit only has a shower as the only bathing facility, then it must be a minimum of 36″x36″.

For the shower as the only bathing fixture: In both Specification A and B bathrooms, when a stall shower is the only bathing fixture in the covered dwelling unit it must be at least 36 inches x 36 inches in size.

This requirement would not allow a 30″x60″ shower as the ADA allows. But the requirements are not so clear. HUD (Fair Housing First) clarified that requirement and allow a shower that is less than 36″ wide as long as the total square inches meets or exceeds 36″x 36″ shower.

The photo above is the shower in a one bedroom unit and it is the only bathing fixture in the unit

The shower was 33″ x 60″ which has a square inches that exceeds 36″x36″ and therefore compliant.

Clear Floor Space

The clear floor space increased from 30″x48″ to 30″x52″

Clear Widths

The clear width in the 2010 ADA and the 2009 ICC ANSI A117.1 were a minimum of 36″ and it was allowed to narrow to 32″ when a 24″ length was being crossed.

The 2017 ICC ANSI A117.1 on the interior remains 36″ clear width, but the reduction of 32″ is only allowed every 52″ apart.

On the exterior the clear width increased to 48″ minimum

Push side door maneuvering clearance

The 2010 ADA Standards and the 2009 ICC ANSI A117.1 requires 48″ length for maneuvering clearance on the push side.

The 2017 ICC ANSI A117.1 increased to 52″ in length on the push side of the door.

Electrica Vehicle Charging Station

Transient lodging changes

The 2017 ICC ANSI A117.1 added requirements height of mattresses in transient lodging guest rooms and added requirements for motorized wheelchairs for charging and transfer space. This is not required by the 2010 ADA or the 2009 ICC ANSI A117.1

The picture above shows a sign for an office suite. Since these may not always be office (could be storage, conference rooms etc) This sign is not designating “permanent” rooms and do not have to comply

216.4 Means of Egress. Signs for means of egress shall comply with 216.4.

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.

216.4.2 Areas of Refuge. Signs required by section 1003.2.13.5.4 of the International Building Code (2000 edition) or section 1007.6.4 of the International Building Code (2003 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1) to provide instructions in areas of refuge shall comply with 703.5.

216.4.3 Directional Signs. Signs required by section 1003.2.13.6 of the International Building Code (2000 edition) or section 1007.7 of the International Building Code (2003 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1) to provide directions to accessible means of egress shall comply with 703.5

216.6 Entrances. Where not all entrances comply with 404, entrances complying with 404 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1. Directional signs complying with 703.5 that indicate the location of the nearest entrance complying with 404 shall be provided at entrances that do not comply with 404.

The sign is a directional sign which provides information to the accessible entrance

Here are the sections referenced above and what they are about:

703.1- gives guidance for raised and tactile characters and braille

703.2- Gives the requirements for raised characters

703.3- Gives the requirements for Braille

703.4- Gives the requirements for Installation Height and Location of signage

Location of ADA Signage

The ADA requires that accessible signs be located alongside the door at the latch side:

703.4.2 Location.

• Where a tactile sign is provided at a door, the sign shall be located alongside the door at the latch side.

The picture above shows the Accessible sign designating the permanent restroom was located next to the latch side of the door

The picture above shows the Accessible sign designating the permanent room was located next to the latch side of the door and it is either mounted on the side light or on the wall away from the glass. Either of those locations are acceptable.

The picture above shows the Accessible sign designating the permanent restroom was located next to the hinge side of the door

• Where a tactile sign is provided at double doors with one active leaf, the sign shall be located on the inactive leaf.

The picture above shows the Accessible sign designating the permanent restroom was located next to the hinge side of the door

• Where a tactile sign is provided at double doors with two active leafs, the sign shall be located to the right of the right hand door.

The picture above shows the Accessible sign at double doors with two active leaves designating the permanent room can be located at either side of the doors

• Where there is no wall space at the latch side of a single door or at the right side of double doors, signs shall be located on the nearest adjacent wall.

The picture above shows the Accessible sign at walls outside the restrooms. The doors did not have enough room for a sign at the latch side so they can be located at the wall closest to the strike

The picture above shows the Accessible sign at the hinge side of the restroom door

The picture above shows the Accessible sign at walls outside the restrooms without doors. A cased opening will be similar to a door. The sign can be located anywhere along the wall.

Clear Floor Space to read the signs

ADA reqires that signage have a clear floor space of 18″x18″ beyond the swing of the door and centered below the sign.

• 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 the reason why the 18″x18″ must be located beyond the swing of the door. This prevents a person from getting hit by the door as they read the sign.

The photo above shows the restroom sign next to the strike side of the door

The photo above shows the restroom sign 8″ from the door which is less than the 9″ min. required from the door the centerline of the sign.

The photo above shows the restroom sign between the wall and the drinking fountain.

The photo above shows the clear floor space less than 18″x18″. The drinking fountain is located inside the clear floor space

The p18″x18″ clear floor space must be located away from the swing of the door

The photo above shows the clear floor space less than 18″x18″. The drinking fountain is located inside the clear floor space

Can the sign be located on the door?

An accessible sign is required to be located on a wall alongside the latch side of the door. But there is one exception that allows the sign to be located on a door. If the door has a closer a sign can be located on the push side of the door.

EXCEPTION: Signs with tactile characters shall be permitted on the push side of doors with closers and without hold-open devices.

The photo above shows the sign located on the pull side of the door

Height of ADA Signage

The height of the sign is required to be mounted between 48″ to 60″ a.f.f. to the bottom of the raised characters

703.4.1 Height Above Finish Floor or Ground. Tactile characters on signs shall be located 48 inches (1220 mm) minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches (1525 mm) maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character

The photo above shows the sign mounted higher than 60″ a.f.f to the bottom of the raised characters

The photo above shows a sign with raised characters

The photo above shows a sign with raised characters mounted at 61 1/2″ a.f.f.

Summary

1) The location of the sign must be located on the wall closest to the strike side of the door of the room it designates

2) If there is no room adjacent the strike side, it is allowed to be located on a wall adjacent the door’s strike side

3) An 18″x18″ clear floor space and centered below the sign and located beyond the swing of the door must be provided.

4) At a double leaf door , the sign can be located adjacent eigher active leaf

5) At a double leaf with one active leaf, the sign can be located on the inactive leaf.

6) The sign may be located on a door provided that it is a push side approach and the door have a closer.

The image above shows movable tables in a cafeteria at a school. Even though a school is required to provide areas for kids and faculty with disabilities to eat lunch just like everyone else, the fact that these are movable will exempt them from any requirements found in the standards.

The image shown above shows a dining area that is not only movable but raised higher than the ground. But because it is not built in it does not have to be on an accessible route and the table does not have to have a knee space

The image shown above shows movable classroom tables. Since they are not built in, they will not have to be at a certain height or have knee clearance.

The image shown above shows a system’s furniture reception desk with a service counter. Because it is movable, the counter will not be required to comply with the sales and service counter requirements.

Even though the banquette itself is not scoped in the Standards, and even though the tables at this dining area is movable and also not scoped, what is scoped because it is a built in element is the charging outlet that is provided at the banquette. Because that charging outlet is fixed or built in, it will be required to be within reach (15″ min. a.f.f.)

When elements that are not built in or fixed are used to provide cane detection to protruding objects

Movable furniture and elements cannot be used to create cane detection for persons who are visually impaired. Cane detection is required to be permanently available because if the movable element is moved the cane detection will not be there. Below are some examples.

The image shown above shows a movable table below a pendant light. The pendant light is technically located along a circulation path because the table is not considered permanently in the location shown. It could potentially move and therefore the pendant light would be located in the open circulation path.

The pendant light was mounted at 63″ a.f.f. and therefore considered a protruding object.

The image shown above shows movable planters that are being used as cane detection to the open stairs beyond

The image shown above shows movable trash can that is being used as a cane detection for the paper towel dispenser that is protruding onto the circulation path. since the trash can is movable, it cannot be used as cane detection.

Movable elements being used to provide accessibility when a buiilt in or fixed element is not compliant.

Becuse only fixed or built in elements are scoped and have requirements, movable elements cannot be counted as the accessible element instead of the built in element. Below are some examples

In this kitchen, there are two built in microwaves that are mounted higher than the allowable reach range. The owner decided to provide a movable microwave as the accessible element, but as we have explained, this microwave can be moved and not returned, therefore it cannot be used as the “accessible” element.

But in this kitchen there is only a movable microwave and it will not be required to be within reach.because it is not technically there.

The image shown above shows a movable shower seat. If a shower seat is required, it must be built in and not mvable.

The bench shown above is not bolted down and therefore not considered a substitute for the built in enches at the lockers

Which movable elements are scoped and required to comply?

Even though ADA only applies to built in or fixed elements, there are a few elements that are movable but also scoped. Below are some examples:

The image shown above are of washer and dryers. Even thought they are movable, they are also technically built in because it is connected to the wall via venting. But even if they were not, there is scoping for the equipment on section 611.

Even though a beverage dispenser could be considered movable, most of the time it is part of the plumbing and built in by way of the connection of the water line. But even if it wasn’t built in, beverage dispensers are scoped by the standards and requirements are found in section 904.

Exercise equipment are also “movable” but are scoped and have requirements in the standards. The requirmements for Exercise equipment is found in section 1004

Height of the sign

The 2010 ADA states that the signs required to comply must have raised characters and there should be brailled that matches the words of the raised characters and located directly below the corresponding words.

703.2 Raised Characters. Raised characters shall comply with 703.2 and shall be duplicated in braille complying with 703.3.

The height of the sign is in relationship to the raised characters. In other words, the Standards require that the bottom of the raised characters be located between 48″-60″ a.f.f.

703.4.1 Height Above Finish Floor or Ground. Tactile characters on signs shall be located 48 inches (1220 mm) minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches (1525 mm) maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character.

Door Signage that has both name of room and room numbers must also meet the requirements. The bottom most baseline of the raised characters should not be mounted lower than 48″ a.f.f. and the top most baseline should not be mounted higher than 60″ a.f.f.

The sign is mounted higher than 60″ a.f.f. to the baseline of the raised characters

Where should the sign be located?

Signs have requirements on where they need to be located.

1. If it is provided at a door, they must be mounted alongside the door at the latch side. Although they are allowed to be located on the push side of doors with closers.

The sign must be located adjacent the latch side of the door. If there is a sign on the door, it can stay there as long as there is also a second sign where it is required

The sign should not be located on the door on the pull side of the door because if a person is reading it, the door could open and hit them

2. Where a tactile sign is provided at double doors with one active leaf, the sign shall be located on the inactive leaf.

3.. Where a tactile sign is provided at double doors with two active leafs, the sign shall be located to the right of the right hand door.

4..Where there is no wall space at the latch side of a single door or at the right side of double doors, signs shall be located on the nearest adjacent wall.

Sign located at the wall adjacent the latch/handle of the door

The wall beyond the swing of the door is less than 18″ and therefore the sign did not have the centerline at 9″ at the floor space beyond the arc.

The sign can be mounted to a glass wall if it is adjacent the latch side of the door

5..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 ADA figure shows the 18″x18′ clear floor space at the sign. It must be centered at the sign and also located beyond the arc of the door.

The clear floor space of 18″x18″ was obstructed by a drinking fountain

Outdoor or indoor bleachers for spectators

Outdoor or indoor bleachers for spectators

Outdoor or indoor bleachers for spectators

Performance Theater

Court rooms

Assembly Seating

The ADA and TAS have requirements (Scoping) for assembly and it is mainly dealing with fixed seating. Assembly seating is ONLY located in the assembly areas listed in the definition: classrooms, theaters, court rooms etc. And they must be fixed for them to meet the criteria for ADA/TAS requirements to be met.

One of my clients is an airport and they were concerned about the lounge seating at the terminal gate waiting area. A passenger lounge at the terminal gate is NOT an assembly area per ADA and TAS, and therefore no wheelchair seats are required. In addition, most of the lounges have seats that are not fixed and are considered “furniture” which are also not required to comply with persons with disabilities.

Airport terminal Gate passenger waiting lounge. These seats are not located in a TAS/ADA defined “assembly” area. Therefore there is no requirements to provide accessible seating in the lounge.

What is NOT assembly areas per ADA but are Assembly occupancies

The IBC catagorizes areas where people congregate as assembly occupancies. The Assembly occupancy is broad and encompasses many facilities. They are not all required to comply with the ADA Assembly seating requirements. Below are some examples of what the IBC considers an Assembly occupancy, but will not trigger compliance with ADA Assembly areas.

Restaurants. If they were fixed tables, they would have to comply with ADA section 226 and 902

Classrooms with non fixed seating or tables. If they were fixed tables, they would have to comply with ADA section 226 and 902

Hotel Ballroom for conferences or events

Library reading areas. Even if they were fixed seats they would not be required to comply

But are any object that extends more than 4″ from its mounting surface a “protruding object”?

No….only if they are also located in a circulation path.

A circulation path in the ADA is not the same as what we design professionals think of a circulation path. We think of it ONLY as corridors, walkway, elevators, stairs….

A circulation path in the ADA describes ANY place that a able bodied pedestrian will be going. This would include the path you would take to go from the doorway to the toilet inside a restroom, the path from the toilet to the sink inside a restroom, the path from a doorway to your seat in a conference room or classroom, the path from one room to a different room etc.

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The photo above is showing a drinking fountain in a circulation path from one room to another

Some people ask me, but there is plenty of room in the middle of the corridor where the drinking fountain does not protrude…..Yes, but a person who is visually impaired who uses a cane to find their way is trained to walk close to the walls in order that they can tap the cane on a surface which will gude them to where they are going. So the middle of the corridor would not be THEIR circulation path.

The drawing above is showing a plan of a lavatory located on the way to the urinals and showers at this lavatory might be a protruding object if the leading edge is mounted higher than 27″ a.f.f. which is possible since the knee space for a lavatory is required to be a minimum of 27″ a.f.f.

The floor plan above is showing a set of drinking fountains in an alcove. It appears as though the alcove puts them away from the circulation path, but because the alcove is wide a person who is visually impaired could accidentally walk into the drinking fountain if one of the leading edges are higher than 27″ a.f.f.

The photo above is showing stair with exposed risers and treads. There is no cane detection and a person who is visually impaired could bump their head on the edges.

There are some requirements that sometimes get mistaken for protruding objects. For example, there is a rule that forbids certain objects to overlap the clearance of the toilet in a restroom. Designers might think that the rule pertains to protruding objects and as long as the object within the clearance of the toilet is less than 4″ it is allowed to overlap.

That is not correct.. The protuding object rule, remember, has to do with persons who are visually impaired. The requirement at the toilet has to do with persons in wheelchairs where such objects would prevent them from easily transfer onto the water closet.

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The photo above is showing a paper towel dispenser that is overlapping the clearance around the toilet. This is NOT a protruding object because it is not lcoated in a circulation path. The paper towel dispenser is located between the toilet and the lavatory which both act as cane detection away from the paper towel dispenser. This however is a violation of the overlap rule for toilets (ADA section 604.3.2)

Some Solutions

Below are some solutions to resolve the protruding objects.

The figure above shows a way to provide cane detection by using a rail below an open stair

The photo above trash receptable mounted below the paper towel dispensers that are protruding more than 4″ onto a circulation path inside the restroom. This trash receptible reaches below 27″ a.f.f. which makes it cane detectable.

The photo above shows a furred out wall that acts as cane detection to the wall mounted TV located in a circulation path.

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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