Public Spaces

January 2025: Drinking Fountain cane detactable apron

Thursday, January 2nd, 2025

Protruding Objects: An overview

The accessibility Standards are not only for mobility, but also for people who are visually impaired.

People with visual impairments (blindness, low vision etc.) will not be able to see their environment, but rather they feel their way around. They are taught to use a cane to feel their way. That cane can detect elements on the ground as well as any element mounted so that their leading edge (bottom usually) is lower than 27″ a.f.f.

Any element that is mounted on a vertical surface higher than 27″ above the finished floor and projecting more than 4″ from the mounting surface will be considered a hazard to persons who are visually impaired. That hazard is described in the ADA Standards as a “protruding object”

307.2 Protrusion Limits. Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the floor shall protrude 4 inches (100 mm) maximum horizontally into the circulation path.

The figure above shows the limits to what would be considered a protruding object.

Keep in mind that the definition of a protruding object in the standards state that objects which are located in a circulation path are the ones of which we need to be careful.

What might be confusing for us architects and designers is the definition of a “circulation path”. In architectural terms, the word “circulation” implies corridors, stairs, elevators. Because of that, we may not always think of “circulation” in terms of how people who are visually impaired define it. To them, any place they walk will be their “circulation path”.

Here is the definition found in the ADA:

Circulation Path. An exterior or interior way of passage provided for pedestrian travel, including but not limited to, walks, hallways, courtyards, elevators, platform lifts, ramps, stairways, and landings.

Which means that any “passage for pedestrian travel” will be a circulation path, exterior or interior.

Below are some examples of Protruding objects:

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

 

The photo above was taken at a restaurant. The dining counter had an open side that was higher than 27″ a.f.f. and projected more than 4″
The photo above was taken inside a restroom. The open diaper counter was mounted higher than 27″ a.f.f. and projected more than 4″ onto the circulation path around the restroom.
The photo above was taken inside an exit stairwell. The cross bracing is located along the circulation path to the door which leads you back into the building. Since it is leaning at a certain point, the leading edge is lower than 80″ a.f.f. and it is a protruding object.
The hi-lo drinking fountain shown above has the leading edge of the “high” fountain (for standing persons) mounted higher than 27″ a.f.f. and projects onto the circulation path more than 4″.


This drinking fountain is located in a recessed alcove, but it is still protruding onto the circulation path because the recess is not deep enough

Solutions for Correcting Protruding Objects

One of the ways that elements that are protruding objects can be corrected would be to create “cane detection”.

Remember that the reason why the element would be considered a protruding object is because it cannot be detected by a person who is visually impaired and uses a cane to find their way. If the element can be detected by using the cane, then it will NOT be a protruding object.

An example would be a hi-lo drinking fountain. The low drinking fountain IF mounted so that there is knee clearance (27″ a.f.f.) it will also be cane detectable (no higher than 27″ a.f.f.). But because the “high” drinking fountain is for standing persons and requires that it be higher than 27″ a.f.f. it will not be cane detectable. Most drinking fountain manufacturers have additional accessories that one can specify called “cane detectable apron” which can be installed at the higher drinking fountain (IF IT IS A PROTRUDING OBJECT) and it will therefore be able to be detected by a person who uses a cane.


The high drinking fountain shown above has a cane detectable apron installed which reaches exactly at 27″ a.f.f. making it cane detectable

Misunderstanding about cane detectable aprons

I have been noticing at new construction, that the cane detectable aprons are installed even when the drinking fountain is not a protruding object. And also they have been installed at every drinking fountain, even the low one for wheelchairs.


The photo above shows a drinking fountain located in an alcove. It is not technically protruding onto a circulation path and the walls on either side of the drinking fountains act as cane detection. So the cane detectable apron installed under the “high” drinking fountain was not required.

Not only is the drinking fountain shown above in an alcove and not protruding, and did not need a cane detectable apron, but the low drinking fountain would never need a cane detectable apron because if mounted for knee clearance it will be cane detectable without the apron, but when the cane detectable apron is installed it reduces the knee clearance to less than 27″ a.f.f.

This photo is another example of drinking fountain in recessed alcove, not protruding and each drinking fountain had the cane detectable apron installed.

Examples of elements that are NOT Protruding objects

Here are some wall-mounted elements that do not meet the criteria for protruding objects. Remember that for an object to be protruding it must meet the following criteria:

  • It must be located along a circulation path
  • It must be mounted so that the bottom of the object is higher than 27″ a.f.f.
  • It must be more than 4″ deep measured from the mounting surface to the front edge of the object
The paper towel dispenser is mounted higher than 27″ a.f.f. and projects more than 4″ from the vertical surface it is mounted on BUT it is not located in a circulation path. The fact that it is mounted between two lavatories in the top photo and between the toilet and lavatory in the second photo takes it away from a circulation path where a pedestrian would bump into it.
The photo above is a diaper counter that is mounted higher than 27″ a.f.f. and projects more than 4″ from the wall, but because it is located between a wall and a lavatory it is not in a circulation path.
Need Barrier Free CEUs?

On Demand Online courses:

Free Online CEU Gannett Flemming AIA Library: Designing for All: A conversation around the Principles of inclusive architcture and accessibiilty

Green CE On Demand webinar Understanding the 2010 Accessibility Standards

Green CE On Demand webinar “ADA and Residential Facilities”

Green CE on Demand webinar: How Accessible is your work place

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

We offer live online courses as well. If you are interested, please contact our office.

Visit our Resource Page that we are building to give you guidance on products and services

If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide”  “Applying the ADA” published by Wiley.

 

If you have any questions about these or any other topics, please feel free to contact me anytime.

December 2024: Obscure Requirements for Accessibility

Monday, December 2nd, 2024

ADA Requirements on Grab bars

The 2010 ADA Standards has requirements for grab bars position gives a range on section 609.

  • For adults the top of the gripping surface of the grab bar should be between 33″ to 36″ a.f.f.
  • For children, the top of the gripping surface is required to be installed between 18″ and 27″ a.f.f.

609.4 Position of Grab Bars. Grab bars shall be installed in a horizontal position, 33 inches (840 mm) minimum and 36 inches (915 mm) maximum above the finish floor measured to the top of the gripping surface, except that at water closets for children’s use complying with 604.9, grab bars shall be installed in a horizontal position 18 inches (455 mm) minimum and 27 inches (685 mm) maximum above the finish floor measured to the top of the gripping surface. The height of the lower grab bar on the back wall of a bathtub shall comply with 607.4.1.1 or 607.4.2.1

But what it doesn’t state or require is that the grab bars must be at the same height. Below is a photo of an inspection where the grab bars were both installed at the children’s height, but one was at the 18″ range and the rear on was at the 27″ range. According to TDLR and The US Access Board, this is not a violation of the Standards.

 

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.

Need Barrier Free CEUs?

We are currently scheduling our 1 HR HSW in person seminars for 2025

On Demand Online courses:

We offer live online courses as well. If you are interested, please contact our office.

Visit our Resource Page that we are building to give you guidance on products and services

If you want to learn more about these standards, be sure to check out my books:

The ADA Companion Guide” and “Applying the ADA” published by Wiley.

If you have any questions about these or any other topics, please feel free to contact me anytime.
vision at doors

November 2024: Inspector’s Corner- Vision at Doors

Friday, November 1st, 2024

November 2024: Inspector’s Corner

Vision Lights at Doors

The ADA requires that if a door has a vision light that it be mounted no higher than 43″ a.f.f. to the glazing.

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.

On inspections, this tends to be missed. One of the main reasons is because the architects drawings call out the height of the vision light as exactly 43″ or not at all

That would be fine since that is the requirement, but one thing to keep in mind is that a door manufacturer typically takes the dimension and places the vision panel from the bottom of the door, but most of doors get hung so the bottom of the door is slightly higher than finished floor. This creates a vision light that is higher than 43″ a.f.f.

New door with vision light

vision light mounted at 44 3/4″ a.f.f.

Ramps at Platform Lifts

The ADA and TAS allow the use of platform lift for some changes in level greater than 1/2″. This is allowed in existing conditions where it is technically infeasible to add a ramp or elevator. Most platform lifts provide ramps to exit. The ramp that is provided MUST comply with the ramp section (Section 405). The one violation that I notice for several platform lifts that are mounted on existing slabs is that the ramp is typically 15″ long and the change in level from the interior of the lift to the finished floor is more than 1.5″ and therefore the slope of the ramp is steeper than 1:12 (8.33%)

An interesting correction of a violation

The location of toilets are sometimes more than the 18″ maximum required from the side wall to the centerline of the toilet

This toilet was located 19 1/2″ from the side wall to the centerline. They could move the toilet, but what they did instead was a very good solution. The photo below shows what they came up with: They furred out the wall enough so that the side wall, grab bar and toilet paper dispenser were at the required location.

October 2024: 2017 ICC ANSI A117.1 vs. 2009 ICC ANSI A117.1 and 2010 ADA

Tuesday, October 1st, 2024

Accessibility Codes and Standards Codes

There are many different accessibility codes, standards and guidelines that we are required to use when we design. The two most prevelant codes for commercial and public accommodations is the IBC required ICC ANSI and the 2010 ADA Standards. They are very similar but the new ICC ANSI which is the 2017 version has several significant changes which do not harmonize with the ADA. When two codes/standards don’t agree, designers must use the MOST STRINGENT.

This newsletter will explain five main changes in accessibility codes. The 2010 ADA has the same technical standards as the 2009 ICC ANSI in the five examples I am presenting in the newsletter.

Turning Space

The 2017 ICC ANSI Standards changed and increased the size of the turning space

  • Turning Circle:In A117.1-2017, the circle has expanded to 67” in diameter and only 10” of it is permitted to overlap knee and toe clearance.
  • T-Shaped Turn: The previous T-shaped turn was a 60”x60” square with 12”x24” cutouts. A117.1-2017 gives three options for a T-shaped turn, as shown in the image below.

The first option is 68”x60” and has two 16”x24” portions removed from two corners with an 8”x8” chamfered interior corner. The second and third options are both 64”x60” with either 11”x22” or 12”x20” rectangles removed from two corners on one side. One arm or the base of each T-shaped turn option is permitted to overlap knee and toe clearance extending below an element.

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

September 2024:ADA Signage Location

Tuesday, September 3rd, 2024

The ADA regulations for singage location cover three things:

  1. Location relative to the door of the room it designates
  2. Installation Height of characters
  3. Clear floor space

This newsletter will explain each one and will give some examples of ambigous locations.

Scope of Coverage

The ADA has requirements on when a sign must comply with the Standards. These requirements are found in the scoping section 216. Not all signs must comply. Below are some of the signs that are required to meet certain minimum standards:

216.2 Designations. Interior and exterior signs identifying permanent rooms and spaces shall comply with 703.1, 703.2, and 703.5. Where pictograms are provided as designations of permanent interior rooms and spaces, the pictograms shall comply with 703.6 and shall have text descriptors complying with 703.2 and 703.5.

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.

August 2024:Fixed and Built in Elements

Monday, August 5th, 2024

The ADA regulations for building access only apply to built-in or fixed elements. Movable furniture and movable equipment (unless scoped in the standards specifically) are not covered by the Standards and do not have any requirements.

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.

My colleagues get confused about these requirements, so I am sharing some examples of when these rule can be ambigous and how we can clarify the requirements.

When elements that are not built in or fixed are not required to comply

Movable furniture is not required to comply with the ADA. Even if the furniture is a reception desk, a dining surfaces, or benches. That means that they don’t have any regulations, but they cannot be used as an accessible element that is required.

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

June 2024: Location of Signage

Monday, June 3rd, 2024

Accessible Signage Location

The 2010 ADA (and other States standards like Texas) section 216 requires that signage that designates interior rooms that are permanent (which means that their function will not change in the future due to the fixtures within). Those signs must have raised characters and braille. Although pictograms and symbols are not required, if they are provided, they must also comply with the standards.

Some of the requirements are for height and location of signs. This newsletter will focus on that requirement and will provide examples of some problematic rules.

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

The clear floor space at the sign was obstructed by a drinking fountain.

April 2024: Assembly seating vs. Assembly occupancy

Friday, April 5th, 2024

What ADA considers “Assembly” vs. IBC

When designing, we designers must remember that there are multiple regulations that we might have to follow. There is the local model codes that are adopted by the City or municipality that we are designing in. There is State requirements as well as Federal. One of the regulations we need to follow is the ones that require equal access for persons with disabilities. But as we design and reference the different codes and standards, we need to be aware that they are not the same or have the same requirements. For example the term “Assembly” is different in its application and definition in the IBC and ADA.

The ADA and TAS treat “assembly” differently than the IBC. The IBC defines assembly as an occupancy:

IBC 303.1 Assembly Group A

Assembly Group A occupancy includes, among others, the use of a building or structure, or a protion thereof, for the gathering of persons for purposes such as civic, social or religious functions;recreation, food or drink consumption or awaiting transportation.

This implies that any place a person gathers is considered “assembly”. These occupancies will also include spaces that do not have fixed elements, such as seats or counter.

The ADA and TAS on the other hand,treats “assembly” as an area. The Definition states that assembly areas:

106.5.10 Assembly Area. A building or facility, or portion thereof, used for the purpose of entertainment, educational or civic gatherings, or similar purposes. For the purposes of these requirements, assembly areas include, but are not limited to, classrooms, lecture halls, courtrooms, public meeting rooms, public hearing rooms, legislative chambers, motion picture houses, auditoria, theaters, playhouses, dinner theaters, concert halls, centers for the performing arts, amphitheaters,arenas, stadiums, grandstands, or convention centers

This implies that only certain areas that are meant for entertainment, educational or civic gatherings. And those areas must have fixed seating since the ADA and TAS only have scoping for Assembly Seating which are fixed.

Below are some examples of the required “assembly areas” that will need to comply with the Standards

Sports spectator seatiing must meet ADA Standards


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

January 2024: Protruding Objects

Wednesday, January 3rd, 2024

BECAUSE IT WAS A PROTRUDING OBJECT

What is a protruding object?

Most of the rules in the 2010 ADA Standards for Accessible design seems to be relating to people who use wheelchairs. But the guidelines apply to other disabilities besides mobility. There are guidelines to assist person who are hearing impaired, congnitively impaired as well as visually impaired.

People who are visually impaired use the built environment to find the way. They might use a cane to “feel” objects which will guide them and will assist them to avoid any hazards. People who use a cane can only detect objects that are located along their circulation path and mounted BELOW 27″ a.f.f.

A circulation path is not the same as an accessible route.

When you see the words “accessible route” in the ADA Standards it is describing the path a person in a wheelchair would use to get around. When you see the words “circulation path” in the ADA Standards it describes any path that a pedestrian would take regardless of disability. Most of the time, the circulation path applies to persons that are visually impaired.

People who are visually impaired use the built environment to find the way. They might use a cane to “feel” objects which will guide them and will assist them to avoid any hazards. People who use a cane can only detect objects that are located along their circulation path and mounted BELOW 27″ a.f.f.

Anything that is mounted ABOVE 27″ a.f.f. or below 80″ a.f.f. could be considered a protruding object IF it is more than 4″ from the mounting surface.

 

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.

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 photo above is showing a diaper counter located in the circulation path to the toilet compartments as well as the exit door. It also projects more than 4″ onto that circulation path making it a protruding object.

The photo above is showing a pendant light fixture mounted lower than 80″ a.f.f. and in a circulation path from one side of the room to the other. But you might say that there is a seat located right below it. Unless that seat is FIXED or BUILT IN it does not constitute a cane detectable element because it could be moved from that location. Only permanent elements will be able to be used as cane detection.

 

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 a clock mounted on a wall in a corridor of a school and lower than 80″ a.f.f.. The clock is a hazard to people who are visually impaired because it protrudes more than 4″ onto the circulation path.

 

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.

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 shows a rail below an open stair that acts as cane detection

 

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 cane detectable apron that is an accessory you can specify to be installed below the leading edge of the high drinking fountain. The cane detectable apron should be mounted exactly at 27″ a.f.f. so that it acts as cane detection and allows the wheelchair drinking fountain to have the required knee clearance.

The photo above shows panels on either side of a wall mounted counter which acts as cane detection

 

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

December 2023: Accessible Means of Egress

Friday, December 1st, 2023

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:

In section 207 of The 2010 ADA and 2012 TAS have the following requirements:

  1. Means of Egress shall comply with section 1003.2.13 of the IBC (2000 edition and 2001 supplement) or
  2. Means of egress shall comply with section 1007 of the IBC 2003 edition

That means that The ADA and TAS DO NOT have jurisdiction over the requirements for accessible means of egress. Only the AHJ will have oversight over the number and location of the accessible means of egress.

TAS and ADA do focus on entrances. So if an exit door is also an entrance then it would have to comply (if it is a required accessible entrance). The door, shown in the photo below, does not have door hardware to enter, so this would be a purely a means of egress and would not be required to comply on the exterior. There might be requirements depending on where it is located to be accessible on the interior if it was considered an entrance to the exterior (you would be “entering” the exterior)


 

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