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    The ADA Companion Guide

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    Applying the ADA

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    Designing for The 2010 ADA for Accessible Design in Multiple Building Types.

     

    ADA

    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.
    Click here to see the memo

    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

    December 2018: Drinking Fountains for children with disabilities

    Tuesday, December 4th, 2018

    Drinking Fountains-overview

     Most of the dimensions found in the ADA are for adults.  There are a few technical requirements that are for children.  One of them is for drinking fountains.  What gets confusing is that the requirements listed are for adults.  So how do we incorporate the children’s drinking fountains in our design?

    Scoping:

    The requirement for drinking fountains are found in the ADA section 211.  They pertain to drinking fountains located on the exterior as well as the interior of the facilities

    The minimum number of drinking fountains that must be provided are two.  One of them must be for a person in a wheelchair and one must be for a standing person, or a person that cannot bend down.

    these two drinking fountains are located so that the spout of one is at the height for wheelchairs and the spout of the other is for standing persons

    There is an exception that allows us to use a single drinking fountain that has a low spout and a high spout can be used instead of two separate ones.

    This clarification tells us that the two drinking fountains required to be provided do not have to be in the same location.  So as long as you have the proper number in the facility, you are compliant.

    Approach

    Drinking fountains are required to have a  30″x48″ clear floor space with a forward approach knee space and centered on the unit.

     

    The 30″ width must be centered on the drinking fountain

    the clear floor space must be provided as a forward approach and the drinking fountain should have a knee and toe clearance so that the clear floor space can be located under the unit

    There is one exception for children.   A parallel approach is permitted at units for children’s use where the spout is 30 inches  maximum above the finish floor or ground and is 3½ inches  maximum from the front edge of the unit, including bumpers.

    a 30 inch x 48 inch clear floor space positioned for a parallel approach as long as the spout is no farther than 3 1/2 inches from the front of the unit and the spout is no higher than 30 inches a.f.f.

    This exception gives us guidance that it is allowed to use a children’s height drinking fountain instead of an adult height wheelchair drinking fountain.  So if you are providing the two minimum number of wheelchairs required in the scoping, one must be for an adult standing and one can be for a child.  You are not required to provide a third drinking fountain for an adult in a wheelchair.

    These drinking fountains would be acceptable for both children and for standing people. The spouts would have to be at the proper heights, but no additional adult wheelchair accessible drinking fountain would be required

    It is recommended that you do provide an adult wheelchair drinking fountain if your facility will have both adults and children as the primary users.  But if you have a pre-school with drinking fountains for children in the classrooms, these can be counted as your 50% of the required drinking fountains.

     

    Polling and Voting Places

    Thursday, November 1st, 2018

    Polling and Voting Places
    The mid-term elections are being held this month. Because voting happens every few years, the places where people vote are only temporary. Even though the polling centers are only temporary, they are providing a “government program” which has to be made accessible under Title II of the ADA. When someone votes, the service that the government is providing must be equal and available to everyone, including persons with disabilities. The voter who is disabled must be able to have the same privacy as everyone else. The voter who is disabled must have access to the same ballot and the same method of voting as everyone else. So how does a polling place provide this access?

    The ADA website has a pamphlet that they put out in 2004 that explains how to provide access even when the polling place is only temporary. The Election Assistance Commission has a video that is also helpful for polling places to provide access.

    In a nutshell, the following items need to be provided to the best of their ability, unless it is not feasible and then other accommodations should be provided to ensure that all voters, disabled or not, can cast their ballot:

    1. Accessible parking or passenger drop off should be available

    2. An Accessible route to the entrance

     

    3. An accessible entrance to the voting site

     

    4. A route free from hazards

    5. Counter or table where the voting is taking place should be between  in height and a forward approach knee space should be provided

     

    Everyone should go to their polling places and make sure there are facilities that are accessible for voters in wheelchairs, voters who are visually impaired as well as hearing impaired. Let’s try and make this election an accessible one.

    Door Maneuvering Clearances

    Wednesday, August 1st, 2018

     
    In order for a person with disabilities to enter a building on their own, there needs to be enough room for them to get through the door and into the spaces.  This newsletter will explain what the requirements are for doors so that a person can easily open the door and go through it.
    What types of doors need to comply?
    In the 2010 ADA standards for accessible design the only doors that require compliance with doors that people will pass through:
    ADA Section 404.2 Manual Doors, Doorways, and Manual Gates. Manual doors and doorways and manual gates intended for user passage shall comply with 404.2.
     That means that if a door is located in a shallow closet, for example, that door is not technically intended for a person to pass through and therefore it does not have to comply
     

     
    Why do we need so much room in front of the door?
    The amount of maneuvering clearances at the door depends on the approach to the door.  Section 404 shows you the different ways that a person could approach the door and gives you guidance for the amount of clearance a person will need to reach for the door handle, open the door and go through.
    The most well-known requirements are the forward approach pull and push.
    But why do we need so much room?  The rectangle shown in the figure provides the proper amount of space for a person with disabilities to reach the door handle, open the door and go through. Below are four images depicting the amount of space required for a forward approach pull side maneuvering of the door.
    Interestingly enough, a door might be located in a thicker wall, or an object might be located on the same wall as the maneuvering clearance.  As long as the object is no more than 8” deep, or as long as the door is not located more than 8” from the face of the wall, it will be compliant for maneuvering for forward approach pull or push side.  Below are some examples:

    This door is located in a recess that is less than 8” deep. The 18” on the pull side maneuvering can include the wall that is in front of the door.

    This door has a paper towel dispenser next to the 18” maneuvering clearance at the latch side of the door

    Since the paper towel dispenser is less than 8” deep, it can be part of the maneuvering clearance

    But there are other ways one can approach the door, and the requirements for the amount of maneuvering clearance will change.  The table in section 404 shows the different approaches and the amount of space required for each.
    The US Access Board created instructional videos to explain the standards. Here is the one about maneuvering clearances
    Other types of doors
    The requirements for doors also applies to toilet compartment doors. Except for the latch side approach which requires only 42″ of clearance, all other approaches will require the space per section 404
    The requirements so far dealt with swinging doors and gates.  But besides the swing doors, there are also maneuvering requirements for sliding doors. These also require maneuvering and these are found in section 404.
    this is a barn door that will require maneuvering clearance to open

    Accessible operable parts and mechanisms

    Tuesday, July 3rd, 2018
    One of the guidelines that seem to be misunderstood is for operable parts.  This guideline requires that an accessible operable part have a mechanism that allows for operating or use without tight grasping or pinching, twisting of the wrist, with less than 5 lbs of force and to operate using only one hand.
    ADA section 309.4 Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.
     
    Why this is required?
    There are persons that don’t have proper use of their hands.  People with rheumatoid arthritis for example, or cerebral palsy, have a hard time grasping elements.  Also, there are people, like amputees, or people that were born without hands or fingers that cannot operate elements which require tight pinching.  In addition, some people with disabilities or older people may not have the amount of strength required to operate an element or activate an operable part if the force required is more than 5 lbs.  Therefore, the ADA design guidelines provides rules to assist those people to navigate their environment in an equal manner.

    Scoping:

    Operable parts on accessible elements, accessible routes, and in accessible rooms
    and spaces shall comply with with the standards.  There are some exceptions which explain that certain operable parts do not have to comply:
    1. Operable parts that are intended for use only by service or maintenance personnel
    2. Electrical or communication receptacles serving a dedicated use (like a refrigerator)
    3. Where two or more outlets are provided in a kitchen above a length of counter top that is uninterrupted by a sink or appliance, one  outlet shall not be required to comply
    4. Floor electrical receptacles
    5. HVAC diffusers
    6. Except for light switches, where redundant controls are provided for a single element, one control in each space  shall not be required to comply 
    7. Cleats and other boat securement devices
    8. Exercise machines and exercise equipment
    9. Operable windows that are only operated by staff and not occupants
    There is an advisory  that gives us more guidance and explanation;
    205.1 General. Controls covered by 205.1 include, but are not limited to, light switches, circuit breakers, duplexes and other convenience receptacles, environmental and appliance controls, plumbing fixture controls, and security and intercom systems.
     
    Section 309 
    Operable parts have three requirements:
    1) They must be within reach ranges as spelled out in the Section 308
    the operable part of the coffee maker must be no higher than 48″ a.f.f.
    2) They must have a 30″x 48″ clear floor space to reach the operable part as specified on 305.  The clear floor space should have a slope no steeper than 1:48 (2%) in all directions.
    the slope at the push button door opener was steeper
    than 2%
    3) and the operable part should be the type that will not require tight grasping and twisting of the wrist and no more than 5 lbs, like explained before.
    this feminine napkin dispenser operable part requires tight grasping and pulling to operate
    this faucet has an operable part that requires graping and twisting to activate
    Below are some more examples.

    Fire Extinguisher cabinet

    I get this question a lot about fire extinguisher cabinets:
    “Do we mount the cabinet so that the top of the fire extinguisher is between 15″-48″ a.f.f.?”
    The answer is no.  The reach range is for “operable parts” of fixed elements.  So a fire extinguisher would not be the operable part, but the handle to open the cabinet would be.  So one should locate the fire extinguisher cabinet door handle between 15″-48″ a.f.f.
    the operable part is the handle to open the cabinet door

    Emergency Nurse calling

    Another operating mechanism that is confusing is the emergency call button located in medical care facilities and long term care facilities. They are used when a patient or resident needs a nurse.  They are typically located next to the toilet and in the shower and they are required to have a string that reaches the floor.  The string is used if a patient or resident falls and they need to pull the string if they can’t get up.
    this call button has a red lever that can be pushed down with a closed fist which has a compliant operable part
    this call button also has a lever that can be pushed down with a closed fist which is a compliant operable part
    this call button is only able to be activated by grasping and pulling the string. This would not meet the requirements for accessible operable parts
    In order for the call button to be compliant, it must not only have the string, but it should have a second way of calling the nurse which will not require tight grasping and pulling.

    Adjustable mechanism at the hand held shower

    One of the operating mechanism that is forgotten is the one required to adjust a hand held shower unit.
    the hand held unit height can be adjusted using the wheel next to the vertical bar.  The wheel requires tight grasping and twisting to
    operate it and therefore not a compliant operating mechanism.
    Once the height is adjusted, the mechanism to loosen or tighten the adjustable part is not always used again.  But the initial action to adjust must meet the requirements.  So the adjustable mechanism must also comply.
    this mechanism does not require tight grasping to loosen or tighten
    this adjustable mechanism requires pinching to loosen

    Need Barrier Free CEUs?

    We are giving classes in the following locations:
    Metrocon18-Dallas Texas
     
    Online courses:
    Green CE On Demand webinar “How Accessible is Your work place?”
    Green CE On Demand webinar “ADA and Residential Facilities”
    or
    If you want to learn more about these standards, be sure to check out my books:

    Accessible Telephones and Emergency Calling Devices

    Tuesday, April 3rd, 2018

    Accessible Telephones

    The 2010 ADA Standards for Accessible Design has a section 217 which tells us which telephones are required to comply with the standards.  The ones listed are coin-operated public pay telephones, coinless public pay telephones, public closed-circuit telephones, public courtesy phones, or other types of public telephones.
    Most people assume the ones that are required to comply are “pay” telephones
    But there are many others that are required to comply that we don’t always think about.  As the list above explains, not just pay telephones, but also courtesy phones, and “other types”.  Other types will also include emergency calling devices.
    this is a courtesy phone that is required to be mounted within reach. This one is higher than 48″ a.f.f.
    This is an emergency calling device that will require compliance

    Requirements for Accessible Telephones

    The ADA section 217 states that the telephones and calling devices that are required to comply should follow section 704
    Section 704 tells us the following:
    1) At least one of the telephones must be designed for the use by people who are in wheelchairs.
    a) A 30″x48″ clear floor space must be provided.  The clear floor or ground space shall not be obstructed by bases, enclosures, or seats
    the clear floor space to approach this phone is less than 36″ wide
    There is a fixed seat in front of this telephone
    The emergency phone was located over the landscaping next to the concrete pad. This is not considered having a “clear floor space”
    This phone is located behind the planter. Even though the planter is not fixed, technically the phone does not have a clear floor space to approach it.
    The phone is located behind a table
    b) If the clear floor space is positioned for a parallel approach, it should be located as shown in the figure below
    c) If the clear floor space is positioned for a forward approach, it should be located as shown in the figure below
    c) Operable parts shall comply with 308 and  309. Telephones shall have push-button controls where such service is available.
    The operable part on this phone (the push buttons) were mounted higher than 48″ a.f.f.
    The button to call the police was mounted higher than 48″  a.f.f.

     
    d) The cord from the telephone to the handset shall be 29 inches (735 mm) long minimum.
    This phone had a cord that was 26″ long
    2. The telephones should also be designed for the hearing impaired to have the ability to use it.  Some telephones are required to provide volume control and TTY (An abbreviation for teletypewriter)
    a) All public telephones are required to have volume controls.  Volume controls shall be equipped with a receive volume control that provides a gain adjustable up to 20 dB minimum. For incremental volume control, provide at least one intermediate step of 12 dB of gain minimum. An automatic reset shall be provided.
    This phone had a volume control device built in on the handset

     
    Most pay phones have volume controls on the cabinet
    b) TTYs required at a public pay telephone and shall be permanently affixed within, or adjacent to, the telephone enclosure. Where an acoustic coupler is used, the telephone cord shall be sufficiently long to allow connection of the TTY and the telephone receiver.
    some TTY phones are placed on a shelf that is provided on the phone cabinet
    Sometimes the TTY is a permanent part of the cabinet

    Emergency Calling Devices

    Emergency calling devices are not specifically scoped in the 2010 ADA Standards.  Some have considered these emergency calling devices to be subject as a two-way communication element if they only allow communication between the called and one party. The standards only address two-way communication systems under 230 and 708 where admittance to a building or restricted space is dependent on the two-way communication system.  The closest similar device for these emergency calling devices is a “closed circuit telephone” per the definition section of the standards.
    Closed circuit telephones must also comply with the requirements listed above and in section 704.  But volume control is not a common feature for these devices.  The use of the variance process in Texas is the only way you can achieve compliance.  In the ADA there is no variance process and therefore when providing devices that are not fully compliant, you can use “equivalent facilitiation” to achieve compliance and documenting this within the owner’s organization.

    Summary

    The telephones that are required to comply are not just the public pay phones that we are used to seeing in public buildings.  There are many more types of telephones that are provided in different facilities that require compliance.  Airports, Hotels, schools and other places of public accommodations will provide a “courtesy” or “emergency” phones and will also require compliance with the ADA Standards so that persons with different disabilities can also communicate.

    Revisiting Shower Seats

    Thursday, March 1st, 2018

    Shower seat installation, location and the effects of shower controls and other elements

    Seats are not always required at bathing facilities, but there are some situations that will require showers seats to be added.  For instance, a transfer shower always requires a seat. Also, in transient lodging facilities (hotels, halfway houses, dorms), a seat is required not only in transfer showers but also in roll-in showers.

    The shower must be permanently attached to the shower and not be movable.  The one exception will be at residential facilities which require blocking for future seats.

    This article will explain how the seat should be installed and how it affects the location of controls and other elements.

    Shower Seat: Scoping

    There are two types of showers: Transfer showers and roll in showers.  Transfer showers are one’s people with mobility impairment will “transfer” onto.  Roll-in showers are the ones that a person in a wheelchair will roll their wheelchair into.

    ADA Section 608.4 requires permanent shower seats in transfer showers.

    1. These must be either folding or not folding seat.
    2. The only exception is for residential dwelling units required to comply with ADA (not Fair Housing). Reinforcement in the wall for the future installation shall be provided instead.

    Roll-in showers are not required to provide a shower seat per section 608.4.  There are two exceptions where seats are required to be provided in roll-in showers:

    1. In social service establishments (i.e. homeless shelters) with more than 50 beds. (per DOJ’s Subpart D of 28 CFR Part 36) AND
    2. In transient lodging guest rooms with mobility features
    3. If a seat is provided in a roll in shower, either by choice or because it is required as stated above, the seat must be permanent and folding.  This allows a person to either use the shower as a transfer type with the seat or as a true roll-in-shower without the seat in the way.
    4. The same technical requirements must be provided as in a transfer shower with a seat (see next entry)

    This photo shows a folding seat mounted on a roll in shower.  The controls are located in the correct location, but there is a grab bar above it.  A grab bar should not be provided where the seat is located.

    This shower was intended as a roll in shower, but the seat provided is not “folding”, therefore a person in a wheelchair could not roll in and use it easily.

    Shower Seats: Technical

    ​Sections  610.3 describes the types of seats allowed at showers.  There can be a rectangular seat or an “L-shape” seat:

    1) Where a seat is provided, the seat shall extend from the back wall to a point within 3″ of the compartment entry.

    This seat did not extend from the back wall to 3″ of the entry

    The seat is 9″ away from the entry

    Sometimes, the seat is located around a gyp wall and the shower sits back a few inches.  So do we consider the wing wall part of the shower when measuring the location of the seat?  According to the Texas Department of Licensing, the shower begins at the shower pan and therefore the wing wall is not counted as part of the shower.
    This shower seat is located 3″ away from the shower pan which is technically where the shower entry begins.  The gyp wall extension is not technically part of the shower.  We recommend that if at all possible, you make the shower pan flush with the wall.

    2) The top of the seat shall be 17″-19″ above the bathroom finish floor.

    3)They can be rectangular meeting figure 610.3.1

    This seat is 4″ away from the end wall rather than 1 1/2″ max

    4) Or they can be “L-shape” meeting figure 610.3.2

    5) The structural strength should be able to sustain 250 lbs of applied force on the seat, fastener, mounting device or support structure.

     

    Roll-in Showers

     There are two types of roll in shower configurations allowed by the ADA.  The shower seat location in these showers will dictate where the controls and grab bars will be located.

    The Standard Roll-in shower with seat:

    The alternate shower with a seat.  An alternate shower is a combination of a transfer shower and roll in shower, so it is larger in depth than a standard roll-in shower.

    The photo above shows an alternate roll-in shower

     

    Depending on where the seat is located, the controls must be located no farther than 27″ away from the seat.

     

    Clear Floor Space

    In order to transfer onto the seat, there should be a clear floor space that meets the requirements at 305 parallel to the shower seat.  The requirements include the size to be 30″x48″ and that the slope is not steeper than 1:48.
    This shower has a ramp transition up to the entry which creates a slope steeper than 1:48 at the clear floor space of the seat
    This shower entry into a transfer shower has a sloped entry which would have been acceptable if the clear floor space would have been 30″ deep. The slope begins with that 30″ making the slope steeper than 1:48.

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    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