There is a lot of confusion in the ADA on what clearances and elements are allowed to overlap each other. The main idea for restrictions to having elements overlap is the inability for a person in a wheelchair to use the element or the space efficiently. The amount of clearance that we design by translates to the amount of space that should be provided for one wheelchair. Floor clearances are not fixed elements and if they overlap each other it does not impede the usage of the clearance. But if a fixed element overlaps the clearance, that might reduce the clearance and prevents a person from using the element.
This newsletter will explain which elements can overlap since they don’t impede the usage of the space or element, and which ones may not overlap. All the rulings are taken from the 2010 ADA Standards
Door Swings
The ADA allows a door to swing into the turning space.
304.4 Door Swing. Doors shall be permitted to swing into turning spaces.
The turning space is not a fixed object. It essentially can move anywhere in a space. Therefore the door swing is not required to avoid it. It can swing into it as much as it needs to.
The ADA The plan of the restroom shows a door swinging into the turning space.
and TAS allows this.
But a door may not swing into the clearance of a plumbing fixture or any fixture within the toilet room. This ensures that if a person in a wheelchair is washing their hands at a lavatory near the door that swings into the toilet room, that person will not get hit by the door.
603.2.3 Door Swing. Doors shall not swing into the clear floor space or clearance required for any fixture. Doors shall be permitted to swing into the required turning space.
There are a couple of exceptions. If the the toilet room is a private office or a single user restroom, it is assumed that the person inside will lock the door behind them and therefore the chances of getting hit by a door while using a fixture that is located within the door swing is unlikely.
EXCEPTIONS:
1. Doors to a toilet room or bathing room for a single occupant accessed only through a private office and not for common use or public use shall be permitted to swing into the clear floor space or clearance provided the swing of the door can be reversed to comply with 603.2.3.
2. Where the toilet room or bathing room is for individual use and a clear floor space complying with 305.3 is provided within the room beyond the arc of the door swing, doors shall be permitted to swing into the clear floor space or clearance required for any fixture.
In addition, there might be two doors within a restroom. It could be a second entry door, but also a toilet compartment door. The clearances for each door may overlap each other, but also they may overlap the turning space. As long as they meet the maneuvering requirements, they may also overlap fixtures.
The plan above shows a swing door and a sliding door in the same restroom. The rules for sliding doors are the same as a swing door.
In a toilet compartment, the door swing cannot overlap the floor clearance of the water closet. If the door swings into the clearance of a water closet inside the compartment will impede maneuvering inside the compartment.
604.8.1.1 Size. Wheelchair accessible compartments shall be 60 inches (1525 mm) wide minimum measured perpendicular to the side wall, and 56 inches (1420 mm) deep minimum for wall hung water closets and 59 inches (1500 mm) deep minimum for floor mounted water closets measured perpendicular to the rear wall
604.8.1.2 Doors. …….Toilet compartment doors shall not swing into the minimum required compartment area
The clearance of the water closet in a compartment should be either 56″ for a wall hung or 59″ if it’s floor mounted. The door can swing out and can also swing in, but the door may not swing into that minimum clearance.
The toilet compartment door shown in the drawing above is swinging into the clearance of the lavatory. Toilet compartment doors must also meet the requirements for section 404 for maneuvering, but there is no restriction to swinging the door into the facing fixtures. That requirements is for the entry door to the toilet room.
What is allowed to overlap in a restroom?
In a toilet room, the floor space and other clearances including the turning space can overlap each other.
603.2.2 Overlap. Required clear floor spaces, clearance at fixtures, and turning space shall be permitted to overlap.
604.3.2 Overlap.
The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space.
No other fixtures or obstructions shall be located within the required water closet clearance.
The photo above shows a floor clearance of 60″ at the water closet, but there is a paper towel dispenser that is within. That dispenser is not allowed to overlap the clearance.
The photo above shows the lavatory within the clearance of the water closet, but in addition there is a fixed trash can and paper towel dispensers within the floor clearance. This is not acceptable.
There is one exception, and that is in residential dwelling units. But this is not for a Fair Housing or ANSI Residential unit. This is the residential dwellings that are scoped in the ADA such as faculty and director apartments in places of education and sleeping quarters in emergency personnel faciliities.
EXCEPTION: In residential dwelling units, a lavatory complying with 606 shall be permitted on the rear wall 18 inches (455 mm) minimum from the water closet centerline where the clearance at the water closet is 66 inches (1675 mm) minimum measured perpendicular from the rear wall.
In the 2010 ADA Standards and the 2012 TAS, certain elements that are associated with fitness centers and recreation centers were added to the requirements for accessibility. Some of these elements were exercise equipment, saunas, swimming pools, and even team player seating.
Most of the time when I am inspecting the project, the owners will inquire the reasons why their facility must be accessible since fitness centers typically for able bodied patrons. What they sometimes don’t understand is that there are different levels of ability that persons with disabilities possess. There are some very active people that use wheelchairs, walkers, crutches or canes. Just because they are in a wheelchair or may have other mobility issues does not mean that they also should not enjoy going to a rec center or fitness center.
This newsletter will explain a few of the requirements and attempt to clarify some of the misconceptions.
Exercise equipment
ADA 1004.1 Clear Floor Space. Exercise machines and equipment shall have a clear floor space complying with 305 [30″x48″ and no changes in level] positioned for transfer or for use by an individual seated in a wheelchair. Clear floor or ground spaces required at exercise machines and equipment shall be permitted to overlap.
Each type of equipment must have the clear floor space next to it, but two pieces of equipment can share the space.
It is not necessary for the clear floor space to be located adjacent each piece of equipment. One of each type is all that is required. The photo above shows several tread mills but only one is required to have the clear floor space, and it is also being shared with the stationary bike.
The clear floor space of this treadmill was narrower than 30″. This is a simple fix of just moving over the equipment to achieve compliance.
Amenities
Rec Centers and fitness centers typically have a reception desk where they will check people in. This is considered a “service counter” and therefore must meet the requirements for ADA Section 904. A portion of the counter must be at 36″ a.f.f. maximum and be no shorter than 36″ wide.
This reception counter does not have an accessible portion at the public side. The lower counter where the attendant is seated is part of the work area, and could possibly be used as the accessible counter if it was 36″ long.
5% of lockers that are provided must have the proper hardware that does not require tight grasping and twisting of the wrist to operate. In addition, those accessible lockers must be within reach range.
This locker is mounted higher than the required 48″ a.f.f. and the operable part (the key) is the type that requires tight grasping and twisting of the wrist to open.
Fitness Centers also have locker rooms and toilet/shower rooms that are provided. The locker rooms must have accessible lockers (within reach range and type of operation) as well as an accessible bench per section 903
Showers and other restroom facilities will also require access. I did a newsletter about this shower seats. Click here for the archive.
Swimming pools and spas are also sometimes provided at rec centers/fitness centers. I discussed swimming pools in a separate newsletter. Click here for the archive
No Limits!
So when they ask you, why are you designing golf courses, tennis courts, rec centers and swimming pools for the disabled, remind them that there are some awesome athletes that do things just a little differently!
The ADA and TAS have requirements for building entrances. The building code also has requirements for means of egress. Both ADA and the building code connect entrances and means of egress to either a public way or a public street. This newsletter will explain the difference between a public way and a public street and will give examples of how these can be applied to our accessible designs.
Definition of Public Way
The ADA defines a “Public way” as follows:
Public Way. Any street, alley or other parcel of land open to the outside air leading to a public street, which has been deeded, dedicated or otherwise permanently appropriated to the public for public use and which has a clear width and height of not less than 10 feet (3050 mm).
If you notice the definition, in addition to the public way being a street or alley, it also speaks about “other parcel of land open to the outside air leading to a public street” .
But what does that mean? My very smart client Josh Williams from D2 Architecture pointed out to me that “other parcel of land” could be a parking lot that is located within the property line as long as it is open to the outside air and connected to a public street. A parking garage would not meet that definition.
Public Way and Accessible Means of Egress
When designing an accessible means of egress, you are required to create a continuous and unobstructed path of travel to a safe area for a person with disabilities to reach in case of an emergency.
The definition of this path of travel is:
Accessible Means of Egress. A continuous and unobstructed way of egress travel from any point in a building or facility that provides an accessible route to an area of refuge, a horizontal exit, or a public way.
An accessible means of egress can terminate at a public way. As we saw on the previous section, the public way can be a parking lot.
This parking lot is an acceptable “public way” for the purposes of providing a route for an accessible means of egress from the shopping center to the right.
Public Way and Accessible Route
Although, as we read in the previous section, an accessible means of egress is only required up to the “public way”, an accessible route has to connect the buildings or facility to a site arrival. A site arrival would also include public sidewalks and public transportation stops even if they are outside the property line.
206.2.1 Site Arrival Points. At least one accessible route shall be provided within the site from accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; and public transportation stops to the accessible building or facility entrance they serve.
Even though this bus stop is not within the property line of the shopping mall that we see behind it, it must have an accessible route from the bus stop to the mall entrance.
EXCEPTION:
1. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, no more than one accessible route from a site arrival point to an accessible entrance shall be required.
2. An accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing pedestrian access.
This photo shows a building but no pedestrian access. This would not require an accessible route all the way to the street.
They are available for sale now. (also available as an e-book)
If you have any questions about these or any other topics, please feel free to contact me anytime.
My family and I just finished our first vacation to Disney World! We had such an incredible time riding all the rides, eating all the junk food and navigating our way around the various theme parks. My children did have to endure a few embarrassing “mom” moments, however — more than most kids usually have to put up with on a family vacation. In addition to enjoying our first Disney adventure, I made it my mission to document some of the new amusement park requirements in the 2010 ADA, which meant standing in line a few extra minutes to wait for any accessible seats, photographing complete strangers without their knowledge, and a few other tasks that completely shamed my children. Isn’t that what most parents do when they take their family to the happiest place on earth?
The Results Are In
The results of my undercover mission were quite impressive. It was truly amazing to me how accessible the entire Disney system was. There were so many people using wheelchairs and other mobility aids, not to mention people who had temporary mobility issues and even baby strollers. I was very impressed with Disney for how sensitive and accommodating their parks were for persons with disabilities.
Common Areas
As with any public accommodation, an amusement park has common areas that are open to the everyone and therefore must be in compliance. Disney succeeded in all areas, from the transportation system to restrooms to accessible ramps throughout every park. Take a look for yourself:
Designated loading areas at every bus stop and on every bus.
Accessible restrooms throughout every park.
Ramps along all routes.
Lifts and other means of entry in the swimming pool areas at each of the resorts.
Accessible dining surfaces and seating at the attractions in abundance.
Accessible Rides
The 2010 ADA devotes an entire section to creating accessible amusement park rides. With special spaces designated for people in wheelchairs, companion seats, accessible loading areas and ramps, Disney passed with flying colors.
Dreams Come True…For Everyone
I’m pleased to share that our first family trip to Disney World was a rousing success. Disney has created an accessible place where everyone can enjoy a magical experience, including my family, who, I’m proud to say, survived the entire vacation with their “crazy mom on a mission.”
Because the standard requirements for amusement parks are very detailed, I encourage you to study the 2010 ADA. You may also read more in my books:
July 26th, 2015 was the 25th anniversary of the ADA. On July 23rd the AIA Dallas organized an awareness day exercise called “Wheelchair in A Day” where we asked 10 architects to sit in a wheelchair and record their experiences throughout the day. The day was a huge success and the stories they retold were so important. This newsletter will give you a few examples of the participants.
Thank you to Bob Bullis, AIA; Beth Brandt, AIA; Daivd Dillard, FAIA; Bob Borson, AIA; Peter Darby AIA, Laurel Stone, Amanda Adler, Jason Dugas, AIA for participating and for sharing your experience with the rest of us!
Traveling by Airplane on a wheelchair
AIA Dallas President Bob Bullis, AIA participated in the “Wheelchair for a Day” event. He had a meeting in Houston which he decided to keep. So he flew in his wheelchair and tweeted about his experience. We asked him what was his biggest challenge. He told us about his trials with TSA….and I will not get into the “search” pat down he received…Southwest Airlines was very accommodating, and allowed him to remain in the chair so he could experience what it was like. He got to go to the front of the line and board first.
He liked the feel of the Terrazzo flooring the best….easier to push on. But noticed that even the slightest slope was hard to navigate
Being in the office and going out to lunch
Two architects experienced their day in a wheelchair: Bob Borson, AIA and David Dillard, FAIA
Bob Borson, AIA experienced his day in the office doing his typical duties: making copies, taking drawings from his car to his desk, and even going out to lunch. All a very eye opening experiences….read his blog post for a more detailed account
I bet Bob was glad that the doors of his office had the proper widths and maneuvering clearances
When Bob wen out to lunch here is what he experienced
“Next challenge? Going out to lunch. Again, long arms to the rescue, but I am acutely aware of how freakishly long my arms are and as a result, I am acutely aware of how difficult going through a cafeteria line would be for people who don’t have the physical proportions of a simian. “
Taking the tray back to his table was a big challenge…glad he didn’t drop his food!
when he got to his table he noticed that there was no place for a wheelchair except at the end….he made everyone move and find a better table (It’s good to be the boss)
David Dillard, FAIA also stayed in his office and also experienced his daily routine in a wheelchair. Meetings are easier when you are the designer of the office and make accommodations…Good job David!
David also had doors he had to maneuver…although his experience was different since he had an electric wheelchair
The City of Dallas didn’t plan properly the locations of stop signs and fire hydrants. David found them right in the middle of his accessible route. I bet those were fun to maneuver.
At lunch they found a restaurant with a wheelchair lift that accommodated him so he could dine with his colleagues
Experiences like these makes architects and designers more sensitive to the people they are designing for.
Taking public transportation
The last example was of our friend Peter Darby, AIA who decided to spend his day in a wheelchair navigating the public transportation system in the City of Dallas
Peter rode in buses, light rail, taxis and even Uber
“Quite a few impediments today. Blocked, Crooked pavements or sidewalks to nowhere! “
He experienced getting onto light rail via ramps
And buses
Getting assistance from rail operators
It takes so much longer to get from point A to point B when you are in a wheelchair taking public transportation, but most people with disabilities, especially visually impaired people use public transportation to get around. It is so important that we have these accommodations to enable them to be independent and as sense of dignity and empowerment.
Upcoming Continuing Education Opportunities
August 7, 2015 Accessibility Professionals Association Regional training Plano, Texas
8:00 – 10:00 am- Difference between TAS and ADA Standards- 2 CE/LU/HSW
10:15 am -11:15 pm- Retail Stores and Spaces- TDLR 1 CE #13464, AIA #155 1 LU/HSW- Detail Review of Retail Spaces Barrier Removal;Common errors; Path of Travel Requirements; Retail Accessible Parking and Accessible Routes,
There is a misconception that a private bathroom is exempted from having to comply with the 2010 ADA Guidelines and the 2012 TAS. In reality, even private bathrooms must comply, although there are some exceptions they can take. In order to take the exceptions, a bathroom is deemed “private” if the bathroom is accessed from a private office and not for public or common use. This newsletter will discuss what items are required to be provided at private bathrooms, and which one’s can be left out. There is a summary from TDLR on TM 2013-19 which we will discuss in detail.
Toilets
At a private bathroom that is accessed through a private office and not for common use, the toilets must comply with all the requirements except for:
The height of the toilet does not have to be 17″-19″ a.f.f. It can be higher or lower than the minimum required heights.
Grab bars are not required to be installed, but blocking must be provided within the wall for future installation
In the Toilet and Bathing rooms the door shall swing into the clear floor space of the fixtures in a private office
So a private toilet must still have the clearances required at the floor area distance from the side wall, flush control and toilet paper dispenser must comply with 604
The photo above shows the proper floor clearance, but the flush control and the toilet paper dispenser were not correctly located
The toilet in this photo does not have the proper floor clearance per 604 nor is the toilet paper dispenser mounted at the proper location
Sinks
At a private bathroom accessed from a private office and not for public use must have a sink that complies with everything in section 606 except:
The sink does not have to have a knee space complying with 306 for forward approach. A parallel approach is allowed to be provided.
The height of the sink does not have to be a 34″ a.f.f. maximum. It can be higher or lower than what the Standards require.
The sink is required to have the proper faucet mechanism, the mirror at the correct height, and floor area for parallel approach.
Because a private bathroom does not require a knee space at the sink, a pedestal sink can be used. The mirror on the other hand must be mounted at 40″ a.f.f. to the bottom of the reflective surface.
Showers and Tubs
At a private bathroom accessed by a private office and not for public or common use, the showers and tubs have to comply with all the requirements of section 607 and 608 except for:
Grab bars do not have to be installed, but blocking within the walls for future installation must be provided.
Otherwise, a shower must have the controls installed at the proper reach range, a hand held shower unit must be provided, the threshold at the entry must not be higher than 1/2″, the size of the shower must comply, and at a transfer shower a seat must also be provided.
This shower doesn’t have a seat or a handheld shower unit. In addition there is a door which doesn’t have clearance on the interior of the shower
Sit in a wheelchair for a Day! Join several of your fellow architects in Dallas and experience what a person who uses a wheelchair experiences. For more information contact Marcela Rhoads at marhoads@abadiaccess.com
Friday July 24th ALL DAY! Join Us!!!
Marking the 25th anniversary of the ADA, July 24th will be ADA Awareness day in Dallas Texas. The AIA Dallas’s Codes and Standards committee is planning a day full of great programs. Stay tuned. If you want to be a sponsor, let me know.
Thank you to our Sponsors: Andres Construction, Access by Design and
Abadi Accessibility
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:
They are available for sale now. (also available as an e-book)
If you have any questions about these or any other topics, please feel free to contact me anytime.
Baby changing stations have become a part of every restroom design. But often times, they are not thought about when designing for accessibility. What happens if a person in a wheelchair needs to change their baby’s diaper? What if the location of the baby changing station will be in the way of the restroom door or the toilet stall door? What if the only diaper changing station is in the accessible stall?
This newsletter will shed some lights on the nuances of the requirements
Scoping and Technical criteria for Diaper Changing Stations
According the the ADA, ANSI and TAS a baby changing station is considered a “non-employee work surface” and therefore must follow the scoping requirements of ADA/TAS section 226 which requires that 5% (but no less than one) should be accessible and meet section 902 requirements.
Section 1109.2 of the IBC also states:
“at least one of each type of fixture, element, control or dispenser in each accessible toilet room and bathing room shall be accessible”.
And even though it does not mention diaper changing stations, the 2009 ANSI has section 603.5 that specifically discusses Diaper changing tables, and it requires that it should follow section 309 and 902.
Section 309 of both ADA and ANSI requires that the height of the operating mechanism (handle to open and close) be located no higher than 48″ a.f.f.
The diaper changing station shown above was mounted so that the opening mechanism was mounted at 51″ a.f.f.
Section 902 requires that once open, the table/counter be no higher than 34″ a.f.f.
This diaper changing station was mounted so that the top of the table higher than 34″ a.f.f.
Section 902 also requires that,once open, the table/counter have a forward approach knee clearance that is 27″ a.f.f. min.
This diaper changing station was mounted incorrectly and only provided 24″ a.f.f. of knee clearance
Proper and improper locations
Now that we know how to make diaper changing stations/tables accessible, we need to explore the location within the restroom which will allow the technical requirements to be met without creating any other accessibility issues.
One of the requirements is for the diaper changing station to have a forward approach knee space. The location of the table or counter must not have anything in front of it which will impede the forward approach.
This baby changing station does not have a clear forward approach because the toilet is in the way
Can the diaper changing station be inside a toilet compartment? Yes as long as there is enough room for a forward approach. Even though it is not a violation to have the only diaper changing station in the accessible stall, it would be recommended that it be located so that most of the public can use it without having to wait for the stall to be freed up.
The diaper changing station in the photo above is located in the toilet compartment, but it has plenty of room after entering to have a forward approach
When locating the diaper changing station on a wall within a single user restroom, it is important to locate it so that it is not in the way of the door maneuvering clearance. The door should be able to swing clear of the diaper changing station like it is shown on the drawing below
Not only do we have to be concerned about the diaper changing station when it is closed, but also when it is open. If the diaper changing station is left open and a person in a wheelchair wants to come into the restroom, they would have a hard time maneuvering through the door since there is not a clear 60″ of floor space.
The red rectangle in the drawing above represents the open baby changing station which is in the way of the door clearance on the pull side.
Upcoming Continuing Education Opportunities
We will be presenting at the 2015 National AIA convention in Atlanta. Our class will be “Applying the ADA in Existing and altered facilities: TH118 on May 14th
Save the Date:
July 24th will be ADA Awareness day in Dallas Texas. The AIA Dallas’s Codes and Standards committee is planning a day full of great programs. Stay tuned. If you want to be a sponsor, let me know.
If you are interested in getting a Barrier Free/ADA CEU online, I partnered with Green CE. We will be presenting live webinars this year. We will post details as they become available
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:
The 1991 ADAAG required that all exits that served as a means of egress as defined in the IBC be accessible. the 2010 ADA Standards no longer scopes how many means of egress must be accessible, but it refers to the 2003 IBC edition or 2000 IBC edition with 2001 supplement for the accessible means of egress requirements. Typically, the IBC requires, if there is one means of egress it must be accessible. If there are two or more means of egress, then two accessible means of egress are required.
Although the ADA Standards do not have specific requirements for accessible means of egress, it references the IBC and adopts their requirements. This newsletter will explain where the IBC ends and the ADA begins when determining the means of egress requirements.
Accessible Means of Egress
An accessible means of egress, according to the IBC, is a “continuous and unobstructed way of egress travel from any point in a building or facility that provides an accessible route to an area of refuge, a horizontal exit, or a public way.
Exit access is any path from any location in a building to an exit. Although we must follow what the IBC dictates on the means of egress requirements, an exit access in the ADA cannot be less than 36″ wide. The IBC typically requires it to be wider (48″ min).
Exits include doors to the outside, enclosed exit stairways or horizontal exits. The ADA requires that doors used to pass through a space to the exit meet the guidelines of section 404. Those guidelines require maneuvering clearances, door hardware, opening force and closing speed to comply. Means of egress doors could include doors into exit stairwell, doors leading to exterior exits or doors leading to exit corridors just to name a few.
This exit door had a push side approach with both a closer and a latch. The maneuvering was a forward approach, and the door was recessed more than 8″, therefore it required a 12″ additional space on the latch side (even though it was a means of egress door).
An exit discharge is the path from an exit to a public way (i.e. street or alley). The ADA does not have guidelines directly relating to an exit discharge. Exit discharged are scoped by reference. Assisted rescue including area of refuge are not scoped in the ADA, but may be in the IBC depending on whether the building is sprinklered or not.
Means of Egress Stairs
If there are any new stairs on the exterior or interior that are part of the means of egress, they must follow the guidelines on section 504 and 505.
Whereas the IBC will focus on the number of stairs required, including the width etc, the ADA focuses on the walking surface inclusing the depth of threads and height of risers, and whether the stair treads have nosings. The ADA will also give guidelines on the handrails heights, size, shape and continuity.
Existing stairs are excempted
Signage
The ADA section 216.4 sets guidelines for exit doors, area of refuge, and directional signs that provide directions to accessible means of egress. These signs must not only comply with the ADA sections 703 but also the IBC sections specified in the Standards.
Means of egress signs should have raised characters and visual characters with a certain size, depth, case, style and proportions all found in ADA section 703.2 and 703.5 If the visual characters are accompanied by braille that complies with ADA 703.3, then the visual characters provided do not have to have a specific case, style, height, proportions, height, or spacing.
We will be presenting at the 2015 National AIA convention in Atlanta. Our class will be “Applying the ADA in Existing and altered facilities: TH118 on May 14th
If you are interested in getting a Barrier Free/ADA CEU online, I partnered with Green CE. We will be presenting live webinars this year. We will post details as they become available
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:
They are available for sale now. (also available as an e-book)
If you have any questions about these or any other topics, please feel free to contact me anytime.
Americans love to travel. Travelling gives us the freedom to go to different destinations and experience different places. People with disabilities also travel, and as such, the airports must be accessible. For designers and airport operators, it is sometimes confusing what accessibility guidelines should be followed.
Under Part 382 of the Air Carrier Access Act (ACAA), air carriers are responsible for airport facilities or services that they “own, lease, operate, or otherwise control. The facilities, according the ACAA should follow the ADA Title III in those areas that are considered public accommodations and commercial areas.
Although the ADA’s statutory language exempts transportation “by aircraft:, airport terminals owned and operated by government entities are covered by Title II of the ADA which requires that the services are made available, and airport terminals open to the public are “public accommodation” covered by Title III of the ADA which requires building access. Both are subject to ADA access requirements of the Americans with Disabilities Act Accessibility Guidelines (ADAAG).
Additionally, airports that receive federal financial assistance are subject to Section 504 of the Rehabilitation Act. According to the U.S. Department of Transportation (DOT), “in order to be in compliance with Section 504, recipients must also be in compliance with all applicable regulations under the ADA.”
This newsletter will try to explain what those regulations.
Ticket Counters and Information Desks
Ticket counters and information desks outside the secured area fall under the ADA section 904 and possibly 902 since they are a public accommodation. Section 904 discusses service and sales counters. If the ticket counters are used for selling tickets or to provide some type of service, such as information, getting boarding passes, or checking in bags, those counters will require that a portion of the public side of the counter be no higher than 36″ a.f.f., and no shorter than 36″ in length. A parallel or forward approach is allowed.
This ticket counter does not have a portion at 36″ a.f.f. , although the area where the baggage is turned in is open and lower. It could be argued that the entire counter is part of the work area for the ticket agent, but in reality it is also where a customer approaches the ticket counter to receive their boarding pass or baggage claim stubs. This is not a compliant service counter.
This ticket counter has a shallow counter that is at 36″ a.f.f. which was allowed by the 1991 ADAAG and it is a safe harbor, but a person with disabilities will have difficulty communicating with the ticket agent since the ticket counter is higher than 36″ a.f.f.
More and more you find that self service check in are being offered. A passenger will not approach a ticket counter but a self service kiosk. These should be within reach range per section 308 of the ADA. There are other requirements that these might need for people that are visually impaired.
Self-service kiosk systems clearly fall within the ACAA encompassing language, which incorporates the Americans with Disabilities Act (ADA) Title III standard for accessible design. This means that these kiosks should meet the reach ranges specified by the ADA but in addition it should have similar privacy requirements as the ATMs do. The kiosks should have the ability to communicate with the visually impaired as well s the hearing impaired patrons. This is not yet happening, but the industry is aware of the deficiency and will hopefully act on that in the near future.
In the same area as the ticket counter there might be counters for filling out baggage tags. These would fall under the ADA Section 902. 5% of the counters must be accessible and have a forward approach. They should be no higher than 34″ a.f.f and they should have a knee space complying with ADA section 306
Other areas of the airport might have information counters. Those will fall under the service counters of ADA Section 904. They should also have a portion at 36″ a.f.f. so that a passenger can communicate with the person behind the counter. According to 904.4 the accessible portion of the counter top shall extend the same depth as the sales or service counter top. Therefore a separate counter attached to the front of the service counter may not be used.
Car rental counters are also considered a service counter and are required to be accessible and follow ADA Standards section 904
Terminal Gates
Once a passenger passes through security and is at their gate, the counters at the gate are also required to follow ADA section 904. The counter shown on the picture below followed the 1991 ADAAG which allowed a separate counter to be used which was not the same depth as the service counter itself. Like we explained above, these separate counters are difficult for persons with disabilities because they cannot easily community with the agent behind the taller counter. That is why the 2010 ADA Standards requires that a lower counter which is the same depth as the main counter be provided.
At the gate, sometimes the air carriers offer tables for people to use which they wait for their plane to board. These would fall under ADA Section 902 as a non-employee work surface. These should have a portion of the counter at 34″ a.f.f. maximum and have a knee space per section 306.
If there are power outlets located at the counter, those should be within reach range.
Jet Bridge and Airplanes
At the terminal gate, passengers go through a door and enter the Jet bridge. This is essentially a movable piece of equipment which allows passenger to board the plane. This is technically not part of the airport and will not fall under the ADA. The requirements for the jet bridge, the slope, handrails etc. will be found in the ACAA. Same with the requirements for inside the airplane. People with disabilities do not enter the plane on their own. There are procedures that air carriers follow with all their passengers with disabilities.
Upcoming CEU opportunities
Note: We will be closed on September 25 and 26
September 4- How to Make Interior Spaces Accessible TAID 1-3 p.m.
We are celebrating our 10th year of service to the building industry as a Registered Accessibility Specialist! Mention this newsletter and receive 10% off your next review or inspection.
If you want to learn more about these standards, be sure to check out my books:
My family and I just finished our first family vacation to Disney World! It was amazing to me how accessible it was. There were so many people using wheelchairs and other mobility aids, not to mention people that had temporary mobility issues and even baby strollers. I decided to document some of the new requirements in the 2010 ADA for amusement parks. I was very impressed with Disney for how sensitive and accommodating their parks were for persons with disabilities.
In this newsletter we will discuss the basic requirements that the 2010 ADA Standards require when building a new amusement park or renovating an existing. An existing amusement park rides are exempted from having to comply. If you want further information, refer to “Applying the ADA” chapter 7 which is an entire chapter on accessible amusement parks.
Common use areas at the Park
As any public accommodation, an amusement park has common areas that are open to the public which will have to comply. At Disney World, this was achieved beginning with their transportation and throughout the park. They had accessible bus stops, restrooms, accessible ramps throughout the park as well as accommodation at restaurants and other public areas.
Designated bus stop loading areas are available at every bus stop
Every bus is equipped with areas designated for wheelchairs
Accessible restrooms were located everywhere in the park
Ramps were located along all routes, making them all accessible
Pool lifts and other means of entry were located in swimming pool areas at their resorts
Accessible dining surfaces were available throughout the park
Several of the attractions in Disney World are shows. They also had accessible seating and companion seating available at almost every show.
Accessible Amusement Rides
The 2010 ADA has an entire section devoted on creating accessible amusement rides. The scoping states:
234.2 Load and Unload Areas. Load and unload areas serving amusement rides shall comply with 1002.3.
234.3 Minimum Number.
– Amusement rides shall provide at least one wheelchair space complying with 1002.4
This ride had a space designated for people with wheelchairs. A companion seat was also provided alongside it.
This ride has a ramp that deploys and allows a person in a wheelchair to enter the ride.
This photo shows an accessible loading area onto a boat ride
This photo shows the person in a wheelchair in the designated seat for persons with disabilities.
This is a train ride with a space for the wheelchair
Companion seats are provided for the designated wheelchair spaces
– or at least one amusement ride seat designed for transfer complying with 1002.5,
– or at least one transfer device complying with 1002.6.
EXCEPTIONS:
Amusement rides that are controlled or operated by the rider shall not be required to comply with 234.3.
Amusement rides designed primarily for children, where children are assisted on and off the ride by an adult, shall not be required to comply with 234.3.
Amusement rides that do not provide amusement ride seats shall not be required to comply with 234.3.
The technical Standards have requirements for the following elements of the amusement rides. They are very detailed and we encourage you to read up on them if you are designing amusement rides.
1002.2 Accessible Routes. An Accessible route will have to be provided to the loading and unloading area
We are celebrating our 10th year of service to the building industry as a Registered Accessibility Specialist! Mention this newsletter and receive 10% off your next review or inspection.
If you want to learn more about these standards, be sure to check out my books:
Abadi 
