Stairs

February 2024: Inspector’s Corner

Friday, February 2nd, 2024

Edge protection at ramps

There is a standard that requires that the side edges of a ramp be protected from wheelchair casters from falling off the edge if the ramp edges are open and located 10″ above the ground. Edge protection along ramp runs and landings keep wheelchair casters and crutch tips on the surface and can be provided by curbs, barriers, or extended surfaces.

At one of my inspections yesterday, there was a ramp that had handrails alongside of low planter wall (so the edges were not open). But it also had a low bar that was mounted 4″ above the surface of the ramp. The additional edge protection was not required, since there was no drop off on either side of the ramp edges.

 

The ramp shown above had a low wall that acted as edge protection AND a low rail that was also intended to be edge protection.“

The photo above shows the low rail that was intended as edge protection. The ramp did not require it since the edges were not exposed.

Cane detection

When an object is located along a circulation path and mounted higher than 27″ a.f.f. , said object is not “cane detectable” (read last month’s newsletter which discussed Protruding Objects)

At one of my inspections yesterday, there were two examples of cane detection: one was not necessary and one was a good example of a prevention from becoming a protruding object.

Below are the two examples:

The photo above shows a diaper counter located along a circulation path in a restroom. It is a recessed type diaper counter with handles that project out onto the path. (the diaper counter was a Koala product)

 

But the handles are only 3 1/2″ from the mounting surface which does not make it a protruding object.

Once the diaper counter is down, and if it is left down, It could be a protruding object….but the handles are now below the counter and will act as cane detection.

The photo above shows the handles below the counter that are mounted lower than 27″ a.f.f. and act as cane detection.

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.

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.

Accessible routes in a multi-story tenant space

Friday, January 4th, 2019

Accessible routes

#ADAFact
The accessible route for people with disabilities must be located so it coincides with the route that everyone else will be taking.
This is the basic tenet of the ADA is for equal access.  The scoping lets us know:
 
206.3 Location. Accessible routes shall coincide with or be located in the same area as general circulation paths. Where circulation paths are interior, required accessible routes shall also be interior
 
In other words, if a route is through the front door, and the front door is not accessible, we are not allowed to make someone in a wheelchair go to the back door to enter the building.
 
This photo shows two entrances: one up some stair (not accessible) and one on the ground (accessible) and both are located in the same location.  This is a good solution to the location of the accessible route coinciding with the general route.

 

Accessible route in a multi-tenant space

The second part of the statement tells us that if the general route is on the interior, the accessible route must also be on the interior.  This means that if we have a two-story space with an interior stair, the accessible route should also be on the interior of the space.    The ADA has a requirement when providing a new stair in a space:
206.2.3.1 Stairs and Escalators in Existing Buildings. In alterations and additions, where an escalator or stair is provided where none existed previously and major structural modifications are necessary for the installation, an accessible route shall be provided between the levels served by the escalator or stair unless exempted by 206.2.3 Exceptions 1 through 7.
 
This means that if you have two levels that were not connected together at the time of new construction, but they will be connecting by adding a stair as part of an alteration, then an accessible route connecting the two floors (and located in the same area) will have to be provided.

this is a two-story store with an interior stair. An elevator would be required inside the store as well
So If there is an office building with a tenant that would like to lease two floors and connect them with an internal stair, they would be required to also provide an elevator or a ramp connecting the stories.  If the building already had an elevator in the core, this would not be able to be used since the elevator is outside the tenant space.  The new elevator would have to be located within the tenant space.

this office building has an internal ramp that connects two stories
The exception mentioned in the last sentence of the standard describes some buildings that are not required to connect the floors together even if there is a new stair provided.  Read my past newsletter about the elevator exception here

TDLR Technical Memo

The Texas Department of Licensing and regulation issued a technical memo that explains their position on this issue.

What if we can’t make a building comply?

#ADAfact
If it is technically infeasible or not readily achievable to provide access to persons who use wheelchairs, we are still required to provide accessible elements to people with other disabilities such as persons who are visually impaired, or hearing impaired or other mobility challenged who use a walker, crutches and other devices

ADA Accessible Stairs

Thursday, February 1st, 2018
The 2010 ADA Standards states that only stairs that are part of a means of egress must comply with the ADA sections 504 and 505.  That means that grand stairs that are typically found in a lobby of an office building, for example, will not have to comply because typically are not part of a means of egress according to the building code.
ADA 210.1 General. Interior and exterior stairs that are part of a means of egress shall comply with 504
This stair is not part of a means of egress and therefore the requirements for nosings, closed risers, handrail shape and extensions do not apply.
What happens when a stair that is part of a means of egress is getting modified or altered?
According to ADA Section 210 Exception #2, in alterations, existing stairs between levels that are already connected by an accessible route (like an elevator or ramp) is not required to comply with 504, except for the handrails.  The handrails will have to be brought up to compliance with ADA section 505.
top of stair
What if you add a new adjoining stair between floors?
A typical scenario that has been occurring in office buildings is that a tenant will take two floors and create a connection within their suite with an adjoining stair.
If the stair did not exist in the space before, and even if the building core has an elevator, an accessible route will be required in the same area.   That means that an elevator or wheelchair lift would also would have to be installed in the suite.
It would not be acceptable to make a person in a wheelchair exit the space and find the elevator in the core and then re-enter the space on the upper floor.
The Texas Department of Licensing and regulation wrote a technical memo to explain their position.  Click here for the memo