Operable Parts and Reach Ranges

Monday, February 1st, 2021

Before we start designing…..

Before starting to design operable parts by looking in section 309, we should begin in section 106.5 Defined Terms. This section will give us guidance on what is defined as an operable part:

Operable Part. A component of an element used to insert or withdraw objects, or to activate, deactivate, or adjust an element.

Now that we know what is defined as an “operable part” we can then go to Section 205 which gives us information on how many and which type are required to comply with the technical standards found in 309.

Section 205 begins with some exceptions. According to this section, operable parts on an accessible element, accessible route and in accessible rooms must comply. In the same section we also have a few exceptions.

1.Operable parts that are intended for the use only by service or maintenance personnel do not have to comply:

The medical equipment in this patient room is only for the use of the medical service personnel and does not have to be mounted within reach range

2 . Dedicated use electrical receptacles do not have to comply

The outlets that are used for appliances or specific electrical uses above the counter will not have to comply

3 . Where two or more outlets are provided in a kitchen above the length of counter top that is uninterrupted by a sink or appliance, one outlet shall not be required to comply

There are two outlets above the counter. Because they are not interrupted by a sink or appliance only one outlet will have to comply

4 . Floor outlets are not required to comply
5 . HVAC diffusers shall not be required to comply
6 Redundant controls (except light switches) for a single element, one control in each space shall not be required to comply
7 . Cleats and other boat securement devices shall not be required to comply.
8 . Exercise machines and exercise equipment shall not be required to comply

The exercise equipment controls do not have to comply.

Section 309 Operable parts

Once we have determined which operable parts are required to comply, we read the requirements on those operable parts in section 309: There are several requirements but in this newsletter we will focus on reach ranges which are found in section 308.

The rules about reach ranges are to locate the maximum and minimum heights to the operable parts.. In essense the height to the parts of the element that will need to be operated so that the element can work.

309.3 Height. Operable parts whsll be placed within one or more of the reach ranges in section 308

Section 308 requires that the operable part be within reach. Either unobstructed forward or side.

This light switch was mounted so that its operable part is at 48 1/2″ a.f.f. rather than the required BELOW 48″ a.f.f. to the top of the switch (which is what make it operate)

The rocker light switch was mounted so that it was 48″ a.f.f. to the middle of the switch. The problem with this is that the switch is operable by pushing the top or the bottom of the switch, not the middle.

The low reach (forward or side) can be no lower than 15″ a.f.f The charging outlet at these booths are mounted 8″ a.f.f.

Operable parts could also be located so that they are reached over an obstruction, either forward or side approach.

the outlet at the wall behind the counter is a type of operable part that will need to be within reach range. Most of the times the outlets are located at the gyp board, which in this case it is located more than 25″ away from the edge

operable parts over the obstruction can only be located a maximum of 25″ from the edge of the obstruction. The soap dispenser is located 26″ away

operable parts at classroom lab tables must be within reach also

the operable part is more than 25″ from the edge of the obstruction

Operable parts have many requirements, including the ability to reach it in order to operate if. The reach range requirements are to the part of the element to operate it, rather than the middle of the element, or the top of bottom. In addition, the location should never be exactly at the “maximum” or “minimum” . Construction is not a perfect science and tolerances are built in to the requirements. So when we are designing the elements keep in mind how it is operated and always design within the reach range, not higher or lower.

Alterations in areas containing a primary function

Monday, August 3rd, 2020


The ADA Standards (and the Texas Accessibility Standards) states:
106.5.5 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.
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.
When doing “alterations” in buildings you have two sets of requirements: Requirements for alterations (ADA Section 202.3) and requirements for alterations that occur in an area that contains a primary function (ADA Section 202.4)
If your alteration is in an area that is not a primary function, only the new things will have to comply. Some examples are doing renovation in bathrooms, break rooms, closets etc.
If your alterations are in an area that is considered primary function then all the new things must comply, but also the path of travel elements that serve the altered area including: accessible route, entrance, restrooms, drinking fountains and telephones that serve the altered area. In Texas they included parking that serves the altered area.
The yellow line in the figure above depicts the path of travel elements that must be compliant when an alteration occurs in an area that contains a primary function

Case studies

With the above information, let’s take a look at a few examples and what it would trigger:

Case Study #1: What if we do an alteration in an existing school of an entire bathroom?

This is an existing school building where they were going to renovate the existing toilet room.
  1. Restrooms are not a primary function
  2. They are demo-ing the entire restroom
  3. They are installing new fixtures and new partitions.
Because the toilet rooms are not a “primary function” in the school, only the new elements installed would have to comply

Case Study #2: What if we only renovate one element in the restroom?

This is an existing restroom, but only the lavatory will be altered. Because the ADA allows element by element alteration, only the lavatory will have to comply. The rest of the restroom that was not altered will remain as is and will not be required to be brought up to compliance.

Case Study #3: What if only the toilet is altered?

This one is a little more complicated. Just like with the lavatory, only the toilet would have to comply. But does that mean that it would also require compliant grab bars? What about compliant toilet paper dispenser? The answer is yes. Those are also elements that are part of the water closet.
One gray area question is whether the clearance around the water closet part of the toilet? Would the clearance need to be 60″ wide? If the toilet room was built prior to 2012, then it is allowed to remain at 36″ clearance.
The image on the left is the 1991 ADAAG clearance at the toilet. The image on the right is the 2010 ADA Standards clearance at the toilet. If the toilet was built prior to 2012 (the year that the new standard became mandatory) then it is compliant.

Case Study #4: What if new bleachers are installed in an existing gymnasium in the school?

  1. The gymnasium is a primary function
  2. The bleachers will have to comply
  3. The path of travel elements that serve the altered area must also comply

Case Study #5: What if we alter the floor at the gymnasium only?

  1. The gymnasium is a primary function
  2. The flooring must comply
  3. The path of travel elements that serve the altered area must also comply

Case Study #6

What if we paint the walls in the gymnasium only
  1. The gymnasium is a primary function
  2. Painting doesn’t affect the usability and therefore it is not an alteration
  • In Summary:

    •Existing buildings are not “grandfathered”. They must comply
    •Texas requires compliance at the time of construction
    •ADA requires compliance when it is readily achievable
    •Existing buildings that comply with 1991 ADAAG/1994 TAS are a safe harbor
    •Altered elements must comply
    •Altered elements in an area of primary function must comply, plus:
    •Accessible entrance
    •Accessible route
    •Accessible restrooms
    •Drinking fountains

    Here is a presentation I did about the subject