Regulatory Assessment of the Final Revised Accessibility Guidelines for the Americans with Disabilities Act and Architectural Barriers Act

July 2004

This assessment has been developed and reviewed in accordance with the Access Board’s information quality guidelines (www.access-board.gov/infoquality.htm).

 

CONTENTS

• EXECUTIVE SUMMARY

• CHAPTER 1: BACKGROUND

• CHAPTER 2: METHODOLOGY

• CHAPTER 3: HARMONIZATION BENEFITS

• CHAPTER 4 ALTERNATIVES THAT ELIMINATE IMPACTS ESTIMATED FOR THE PROPOSED RULE

• CHAPTER 5 REVISIONS THAT REDUCE IMPACTS

• CHAPTER 6 REVISIONS THAT HAVE MINIMAL IMPACTS

• CHAPTER 7 REVISIONS THAT HAVE MONETARY IMPACTS

• CHAPTER 8:  NATIONAL COSTS FOR OFFICE BUILDINGS, HOTELS, HOSPITALS AND NURSING HOMES, AND GOVERMENT HOUSING

• CHAPTER 9 LEASED POSTAL FACILITIES

• CHAPTER 10 SMALL ENTITIES

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EXECUTIVE SUMMARY

The Access Board prepared this assessment of the final revised accessibility guidelines for the Americans with Disabilities Act and Architectural Barriers Act pursuant to Executive Order 12866.  The Americans with Disabilities Act requires newly constructed and altered State and local government facilities, places of public accommodation, and commercial facilities to be accessible to individuals with disabilities.  The Architectural Barriers Act requires federally financed facilities to be accessible, including facilities leased by Federal agencies. 

 

The Access Board is required to establish and maintain accessibility guidelines for facilities covered by the Americans with Disabilities Act and Architectural Barriers Act.  The guidelines serve as the basis for enforceable standards issued by other agencies under the Americans with Disabilities Act and Architectural Barriers Act.  The Access Board initially issued the Minimum Guidelines and Requirements for Accessible Design (MGRAD) for the Architectural Barriers Act in 1982, and the Americans with Disabilities Act Accessibility Guidelines (ADAAG) in 1991. 

 

Since the enactment of the Americans with Disabilities Act, accessibility requirements have been increasingly incorporated in the model codes.  The Access Board worked collaboratively with the International Code Council (ICC) and the ANSI A117 Committee to harmonize the final revised guidelines with the International Building Code, which was first published in 2000, and the ICC/ANSI A117.1 Standard on Accessible and Usable Buildings and Facilities, which is referenced in the International Building Code.  The International Building Code has been adopted statewide by 28 States and by local governments in another 15 States. 

 

Harmonizing the accessibility guidelines for the Americans with Disabilities Act and Architectural Barriers Act with the International Building Code and the ICC/ANSI A117.1 standard promotes increased compliance, efficiency, and economic growth.  It is difficult and time consuming for business owners, builders, developers, and architects to deal with different accessibility requirements at the Federal, State, and local government levels.  Differing requirements can contribute to mistakes resulting in litigation and costly retrofitting of facilities after they are constructed.  The Americans with Disabilities Act authorizes the Department of Justice to certify State or local codes that meet or exceed Federal accessibility requirements.  State and local governments that adopt the International Building Code will find it easier to have their codes certified, and more State and local governments are expected to submit their codes to the Department of Justice for certification.  In jurisdictions where codes have been certified by the Department of Justice, business owners, builders, developers, and architects can rely on their State or local government building plan approval and inspection processes as a “check-point” for ensuring that their facilities comply with Federal accessibility requirements.  Potential mistakes can be corrected early in the construction process when adjustments can be made easily and inexpensively compared to costly retrofitting after a facility is constructed.  Compliance with a certified code is also evidence of compliance with Federal accessibility requirements in litigation to enforce the Americans with Disabilities Act.

 

The Access Board also revised some requirements in the current guidelines for the Americans with Disabilities Act and Architectural Barriers Act to reduce the impacts on facilities, including lowering the number of wheelchair spaces and assistive listening systems required in large sports facilities; exempting small raised press boxes in sports facilities from the accessible route requirements; exempting parking lots with a few parking spaces from signage requirements for accessible parking spaces; and reducing the number of toilet rooms required to be accessible where multiple single user toilet rooms are clustered at the same location.

 

The regulatory assessment for the proposed rule estimated that the national costs of the rule would be $87.5 million annually for newly constructed office buildings, hotels, and sports stadiums and arenas.  The Board adopted alternatives in the final revised guidelines that eliminate these costs as shown in Table ES.1.

 

Table ES.1 – Alternatives That Eliminate Costs Estimated for the Proposed Rule (text version)

 

This assessment compares the final revised guidelines to the current guidelines and the International Building Code in order to evaluate the potential impacts of the revisions.  In the absence of the final revised guidelines, newly constructed and altered facilities covered by the Americans with Disabilities Act would have to comply with ADAAG as initially issued in 1991, which has been adopted as enforceable standards by the Department of Justice and Department of Transportation.  Many newly constructed and altered facilities covered by the Architectural Barriers Act are also required to comply with ADAAG when it provides a greater level of accessibility compared to the Uniform Federal Accessibility Standards (UFAS).  Comparing the final revised guidelines to the current guidelines is the upper bound of the range of potential impacts.  The International Building Code has been adopted statewide by 28 States and by local governments in another 15 States.  In the absence of the final revised guidelines, newly constructed and altered facilities are required to comply with the International Building Code in jurisdictions that have adopted the model code.  Comparing the final revised guidelines to the International Building Code is the lower bound of the range of potential impacts, and assumes that facilities covered by the Americans with Disabilities Act and Architectural Barriers Act are also required to comply with equivalent requirements in the International Building Code.  The actual impacts will be between the lower and upper bound of the range.

 

The final revised guidelines reorganize and renumber ADAAG, and rewrite the text to be clearer and easier to understand.  Most of the scoping and technical requirements in ADAAG have not been changed.  An independent codes expert compared the final revised guidelines and ADAAG to identify revisions that add new features or space to a facility, or present design challenges compared to ADAAG.  The codes expert identified 27 revisions that are expected to have minimal impacts on the new construction and alterations of facilities, including adding scoping requirements and exceptions for  common use circulation paths in employee work areas; revising scoping requirements for public entrances; referencing the International Building Code for accessible means of egress; adding scoping requirements for dwelling units with mobility features in Federal, State, and local government housing; lowering the high side reach; and adding technical requirements for automated teller machines and fare machines.

 

The codes expert also identified 14 revisions that are expected to have monetary impacts on the new construction and alterations of facilities.  An independent cost estimator prepared cost estimates for these revisions using standard industry procedures.  The revisions that are expected to have monetary impacts on the new construction and alterations of facilities are summarized in Table ES.2. 

 

Table ES.2 - Revisions with Monetary Impacts on

New Construction and Alterations (text version)

 

Office buildings, hotels, hospitals and nursing homes, and Federal, State, and local government housing will be affected by many of the revisions in Table ES.2, and are likely to experience relatively higher costs than other facilities.  The assessment estimates the national costs of the revisions for the construction of these facilities. The national costs are summarized in Table ES.3.   

 

Table ES.3 – National Costs for Facilities Likely

to Experience Relatively Higher Costs (text version)

 

The assessment also estimates the additional costs of the revisions for individual facilities as a percentage of total construction costs as shown in Table ES.4.

 

Table ES.4 – Additional Costs for Individual Facilities (text version)

 

The final revised guidelines will affect the new construction and alterations of other types of facilities.  Industry reports estimate $152 billion of non-residential building construction projects were started in 2002; and government reports estimate $264 billion of non-residential building construction work and $6 billion of Federal, State and local government housing construction work was installed in 2002.  In order to be considered an economically significant regulatory action with an annual effect on the economy of $100 million or more, the final revised guidelines would need to have impacts ranging from 0.04 percent to 0.07 percent of industry and government construction estimates.  The final revised guidelines will have impacts within or above this range on office buildings and hotels, and it is likely that the impacts on some other facilities will be within or above this range.   Although the impacts are not significant for an individual facility, when added together across the economy the impacts can be economically significant.  Because an extremely low threshold of impacts on individual facilities can render the final revised guidelines economically significant, and because the benefits of the final revised guidelines are unquantifiable but substantial, the Board has classified the final revised guidelines as an economically significant regulatory action.

 

The final revised guidelines will also affect leased postal facilities. When the United States Postal Service enters into a new lease for a postal facility, including previously occupied space, it will have to comply with the accessibility requirements in the final revised guidelines for facilities leased by Federal agencies, including providing accessible customer service counters and van accessible parking spaces.  The United States Postal Service leases 27,000 postal facilities, and estimates that it will cost $9,234 per facility to comply with the final revised guidelines.  The United States Postal Service enters into an average of 1,661 new leases per year for postal facilities, and estimates it will cost $15.3 million annually for leased postal facilities to comply with the final revised guidelines.

 

On the basis of this assessment, the Access Board certifies that the final revised guidelines are not expected to have a significant economic impact on the new construction and alterations of facilities by a substantial number of small entities for purposes of the Regulatory Flexibility Act.  The final revised guidelines will add 0.01 to 0.5 percent to the total construction costs of facilities compared to the current guidelines; and 0.00 to 0.3 percent to the total construction costs of facilities compared to the International Building Code.  These impacts are not significant for an individual facility.

 

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CHAPTER 1:  BACKGROUND

1.0  Introduction

 

Executive Order 12866 requires Federal agencies to submit certain regulatory actions to the Office of Management and Budget for review.  The agency must provide the Office of Management and Budget the text of the regulatory action, together with an assessment of the impacts of the regulatory action.  The assessment must describe the need for the regulatory action and how the regulatory action will meet that need.  The assessment must also explain how the regulatory action is consistent with statutory mandates, promotes the President’s priorities, and avoids undue interference with State, local, and tribal governments in the exercise of their governmental functions.   The Access Board prepared this assessment of the final revised accessibility guidelines for the Americans with Disabilities Act and Architectural Barriers Act to meet the requirements of Executive Order 12866.

1.1  Statutory Authority

 

The Access Board is required by statute to establish and maintain minimum guidelines to ensure that facilities covered by the Americans with Disabilities Act and Architectural Barriers Act are accessible, in terms of architecture and design and communication, to individuals with disabilities.[1]  These guidelines serve as the basis for enforceable standards issued by other agencies under the Americans with Disabilities Act and Architectural Barriers Act.  The requirements of the Americans with Disabilities Act and Architectural Barriers Act with respect to facilities are explained below.

 

Americans with Disabilities Act

 

The Americans with Disabilities Act was enacted in 1990 based upon the Congress finding that:

 

“individuals with disabilities continually encounter various forms of discrimination, including . . . the discriminatory effects of architectural, transportation, and communication barriers.”[2] 

 

The purpose of the Americans with Disabilities Act is:

 

“to provide clear, strong, consistent, and enforceable standards addressing

discrimination against individuals with disabilities [and] to ensure that the

Federal government plays a central role in enforcing the standards.”[3] 

 

The Americans with Disabilities Act requires newly constructed State and local government facilities, places of public accommodation, and commercial facilities to be accessible to individuals with disabilities.[4]  The Americans with Disabilities Act also requires parts of existing facilities that are altered to be accessible.[5] 

 

Two agencies are responsible for issuing enforceable standards for facilities covered by the Americans with Disabilities Act. 

 

• The Department of Transportation issues enforceable standards for public transportation facilities owned or operated by State and local governments, and the National Railroad Passenger Corporation.[6] 

 

• The Department of Justice issues enforceable standards for all other types of facilities.[7]

 

Architectural Barriers Act

 

The Architectural Barriers Act was enacted in 1968 to provide individuals with disabilities access to facilities financed by the Federal government.  The Architectural Barriers Act covers facilities constructed, altered, or leased by the Federal government.[8]  The Architectural Barriers Act also covers facilities constructed or altered with a Federal grant or loan, where the law authorizing the grant or loan authorizes the administering agency to issue design or construction standards; and facilities constructed by the Washington Metropolitan Area Transit Authority.[9] 

 

Four agencies are responsible for issuing enforceable standards for facilities covered by the Architectural Barriers Act. 

 

• The Department of Housing and Urban Development issues enforceable standards for federally financed residential facilities.[10] 

• The Department of Defense issues enforceable standards for military facilities.[11] 

• The United States Postal Service issues enforceable standards for postal facilities.[12]

• The General Services Administration issues enforceable standards for all other federally financed facilities.[13]

 

1.2  Current Guidelines and Standards

 

MGRAD and UFAS

 

In 1982, the Access Board issued the Minimum Guidelines and Requirements for Accessible Design (MGRAD) to assist the Department of Housing and Urban Development, Department of Defense, United States Postal Service, and General Services Administration in establishing a consistent set of enforceable standards.[14]  These four agencies in turn issued the Uniform Federal Accessibility Standards (UFAS) in 1984 as the enforceable standards for facilities covered by the Architectural Barriers Act.[15] 

 

ADAAG

 

In 1991, the Access Board issued the Americans with Disabilities Act Accessibility Guidelines (ADAAG) to assist the Department of Justice and Department of Transportation in establishing a consistent set of enforceable standards.[16]  ADAAG is modeled on UFAS.  ADAAG includes provisions for features and facilities that are not addressed in UFAS.  For example, ADAAG has provisions for van accessible parking spaces, public TTYs, automated teller machines, and transportation facilities.  UFAS does not address these features or facilities.  The Access Board prepared a regulatory assessment for ADAAG when the guidelines were initially issued.[17]  The Department of Justice and Department of Transportation adopted ADAAG in 1991 as the enforceable standards for facilities covered by the Americans with Disabilities Act.[18]  The General Services Administration requires Federal agencies to use ADAAG for facilities covered by the Architectural Barriers Act when it provides a greater level of access compared to UFAS.[19] 
 

Children’s Facilities Guidelines

 

In 1998, the Access Board amended ADAAG by adding guidelines for children’s facilities.[20]  These guidelines add child-sized alternatives to the existing adult dimensions that can be used when designing building elements for children.  The Access Board did not prepare a regulatory assessment for the children’s facilities guidelines because they do not establish any new requirements.  The children’s facilities guidelines have not been adopted by the Department of Justice or Department of Transportation. 

 

State and Local Government Facilities Guidelines

 

In 1998, the Access Board also amended ADAAG by adding guidelines for judicial facilities, and detention and correctional facilities.[21]  These guidelines address certain areas within court rooms such as raised judges’ benches, and within jails and prisons such as the number of cells required to provide mobility features.[22]  The Access Board did not prepare a regulatory assessment for the State and local government facilities guidelines because they do not impose any significant impacts on State and local government facilities.[23]  The State and local government facilities guidelines have not been adopted by the Department of Justice or Department of Transportation. 

 

Play Areas Guidelines

 

In 2000, the Access Board amended ADAAG by adding guidelines for play areas used by children.[24]  These guidelines address access to ground level and elevated play components, and ground surfaces.  The Access Board prepared a regulatory assessment for the play areas guidelines.[25]  The play areas guidelines have not been adopted by the Department of Justice or Department of Transportation. 

 

Recreation Facilities Guidelines

 

In 2002, the Access Board amended ADAAG by adding guidelines for recreation facilities.[26]  These guidelines address access to amusement rides, boating and fishing facilities, golf courses, miniature golf courses, exercise equipment, bowling lanes, shooting facilities, and swimming pools and spas.  The Access Board prepared a regulatory assessment for the recreation facilities guidelines.[27]  The recreation facilities guidelines have not been adopted by the Department of Justice or Department of Transportation. 

 

The guidelines for play areas and recreation facilities were developed through separate rulemaking processes that involved advisory committees and regulatory negotiation, and were not part of the present rulemaking to revise the guidelines.  The guidelines for play areas and recreation facilities are incorporated in the final revised guidelines without any substantive changes.

1.3  Need to Revise Guidelines

 

Since the enactment of the Americans with Disabilities Act, accessibility requirements have been increasingly incorporated into the model codes.  State and local governments adopt the model codes to regulate building construction.  The model codes are revised every three years.  The model codes reference the ICC/ANSI A117.1 Standard on Accessible and Usable Buildings and Facilities for technical requirements.  The ICC/ANSI A117.1 standard is revised every five years.

 

Federal accessibility requirements need to keep pace with the model codes and standards as they are revised.  The Access Board has revised the guidelines for the Americans with Disabilities Act and Architectural Barriers Act to harmonize the guidelines with the model codes and standards in order to achieve greater consistency and uniformity in accessibility requirements at the Federal, State, and local government levels.  The Access Board has also revised the guidelines to ensure that Federal facilities provide the same level of accessibility as State and local government facilities, and private facilities.

1.4  Rulemaking History

 

The Access Board established the ADAAG Review Advisory Committee in 1994 to recommend revisions to the guidelines.  The advisory committee consisted of 22 organizations representing model codes and standards groups, State and local governments, the building and construction industry, and individuals with disabilities.[28]  The advisory committee issued its report, “Recommendations for a New ADAAG,” in 1996.  The Access Board used the advisory committee’s report to develop a proposed rule that was published in 1999.[29]  Public hearings were held on the proposed rule in Los Angeles and Washington, DC.  Information meetings were also held in Washington, D.C. to hear from industry and disability groups on issues regarding automated teller machines, reach ranges, and captioning equipment for movie theaters.  Throughout the rulemaking process, the Access Board worked collaboratively with the International Code Council and ANSI A117 Committee to harmonize the guidelines with the new International Building Code, which was first issued in 2000 and revised in 2003; and the ICC/ANSI A117.1 standard, which was revised in 1998 and 2003.  The Access Board released a draft of the final revised guidelines in April 2002 to further promote harmonization with the model codes and standards.[30]

1.5  Final Revised Guidelines   

 

The final revised guidelines consist of three parts which are published as separate appendices to 36 C.F.R. Part 1191.

 

• Appendix B contains ADA Chapters 1 and 2 of the guidelines, which establish application and scoping requirements for facilities covered by the Americans with Disabilities Act.  The scoping requirements specify what features of a newly constructed or altered facility must be accessible.  Where multiple features that serve the same function are provided, such as parking spaces in a garage or seats in an assembly area, the scoping requirements specify how many of the features must be accessible.

 

• Appendix C contains ABA Chapters 1 and 2 of the guidelines, which establish application and scoping requirements for facilities covered by the Architectural Barriers Act.  The scoping requirements in Appendix C are mostly the same as those in Appendix B.  A few requirements are different based on the Architectural Barriers Act.  Appendix C, for example, includes scoping requirements for facilities leased by Federal agencies.

 

• Appendix D contains Chapters 3 through 10 of the guidelines, which establish common technical requirements for facilities covered by the Americans with Disabilities Act and Architectural Barriers Act.  The technical requirements provide dimensions and specifications for making the features of a facility accessible.

 

Appendix A contains the Table of Contents, and Appendix E contains the List of Figures and Index for the final revised guidelines.

1.6  President’s Priorities

 

On July 26, 2002, President George W. Bush issued a Proclamation on the twelfth anniversary of the Americans with Disabilities Act calling the statute “one of the most compassionate and successful civil rights laws in American history.”  The President committed his Administration to implementing the Americans with Disabilities Act and “removing the barriers that prevent people with disabilities from realizing their full potential and achieving their dreams.”  The final revised guidelines will promote the President’s priorities by improving implementation of the Americans with Disabilities Act’s accessibility requirements.

1.7  Federalism

 

The Americans with Disabilities Act was enacted “to provide clear, strong, consistent, and enforceable standards addressing discrimination against individuals with disabilities [and] to ensure that the Federal Government plays a central role in enforcing the standards.”[31]  The Architectural Barriers Act was enacted to provide individuals with disabilities access to federally financed facilities.  Ensuring the civil rights of groups who have experienced discrimination has long been recognized as a national issue and a proper function of the Federal government. 

The Americans with Disabilities Act recognizes the authority of State and local governments to enact and enforce laws that “provide greater or equal protection for the rights of individuals with disabilities than are afforded by this chapter.”[32] 

 

The final revised guidelines serve as the basis for enforceable standards issued by other Federal agencies under the Americans with Disabilities Act and Architectural Barriers Act. 

The final revised guidelines adhere to the fundamental federalism principles and policy making criteria in Executive Order 13132.  The Access Board consulted with State and local governments throughout the rulemaking process.  State and local governments were represented on the ADAAG Review Advisory Committee, participated in public hearings, and submitted comments on the proposed rule.  The final revised guidelines are harmonized with model codes that are adopted by State and local governments to regulate building construction.

 

Regulations that implement statutory rights that prohibit discrimination on the basis of disability are exempt from the Unfunded Mandates Reform Act, which requires agencies to assess the effects of regulatory actions on State and local governments.[33]
 

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CHAPTER 2:  METHODOLOGY

2.0  Baseline

 

Regulatory actions are compared to a baseline to evaluate their potential impacts.  The baseline is a reasonable forecast of what would happen in the absence of the regulatory action.  As explained below, the final revised guidelines are compared to the current guidelines and the International Building Code.  In addition, the final revised guidelines concerning common use circulation paths in employee work areas, accessible means of egress, and visible alarms in hotel guest rooms with communication features are compared to the model fire and life safety codes.

 

Current Guidelines

 

 In the absence of the final revised guidelines, newly constructed and altered facilities covered by the Americans with Disabilities Act would have to comply with ADAAG as initially issued in 1991, which has been adopted as enforceable standards by the Department of Justice and Department of Transportation.[34]  Newly constructed, altered, and leased facilities covered by the Architectural Barriers Act that are subject to standards issued by the General Services Administration are also required to comply with ADAAG, where it provides a greater level of access compared to UFAS. [35] 

 

The final revised guidelines reorganize and renumber ADAAG, and rewrite the text to be clearer and easier to understand.  Most of the scoping and technical requirements in ADAAG have not been changed.  An independent codes expert compared the final revised guidelines and ADAAG to identify revisions that add new features or space to facilities, or present design challenges compared to ADAAG.[36]  The codes expert identified 27 revisions that are expected to have minimal impacts on the new construction and alterations of facilities, which are discussed in Chapter 6; and 14 revisions that are expected to have monetary impacts on the new construction and alterations of facilities, which are discussed in Chapter 7. 

 

Comparing the final revised guidelines to the current guidelines represents the upper bound of the range of potential impacts, and assumes that facilities covered by the Americans with Disabilities Act or Architectural Barriers Act are not required to also comply with equivalent requirements in the International Building Code. 

 

International Building Code

 

The International Building Code was first issued in 2000 and revised in 2003.  The 2000 and 2003 editions of the International Building Code reference the 1998 edition of the ICC/ANSI A117.1 Standard on Accessible and Usable Buildings and Facilities for technical requirements. 

 

In the absence of the final revised guidelines, newly constructed and altered facilities would have to comply with the International Building Code in jurisdictions where the code has been adopted.  As shown in Table 2.1, the International Building Code has been adopted statewide in 28 States and by local governments in 15 States.[37]  The District of Columbia, the Department of Defense, and the National Park Service have also adopted the International Building Code.  

 

Table 2.1 – State and Local Government Adoption of International Building Code (text version)

* Number of local governments that have adopted the International Building Code is shown in parenthesis

 

The final revised guidelines are compared to the 2000 and 2003 editions of the International Building Code to identify whether the codes contain equivalent requirements.  Comparing the final revised guidelines to the International Building Code represents the lower bound of the range of potential impacts, and assumes that facilities covered by the Americans with Disabilities Act or Architectural Barriers Act are required to also comply with equivalent requirements in the International Building Code.  The actual impacts will be between the lower and upper bound of the range.

 

Model Fire and Life Safety Codes

 

The final revised guidelines concerning common use circulation paths in employee work areas, accessible means of egress, and visible alarms in hotel guest rooms with communication features are also compared to relevant requirements in the 2003 editions of the NFPA 101, Life Safety Code; NFPA 1, Uniform Fire Code; and International Fire Code.  As shown in Table 2.2, these model codes have been adopted statewide by 48 States.[38]  The other two States, New Jersey and Ohio, have adopted the International Building Code, which contains equivalent requirements to the International Fire Code for means of egress and visible alarms.

 

Table 2.2 - Statewide Adoption of Model Fire and Life Safety Codes (text version)

2.1  Timing of Impacts

 

The final revised guidelines are not enforceable and will not have any impacts until they are adopted as enforceable standards by the following agencies:

 

• Department of Justice for State and local government facilities, places of public accommodation, and commercial facilities.

 

• Department of Transportation for public transportation facilities owned or operated by State and local governments, and the National Railroad Passenger Corporation.

 

• Department of Housing and Urban Development for federally financed residential facilities.

 

• Department of Defense for military facilities.

 

• United States Postal Service for postal facilities.

 

• General Services Administration for all other federally financed facilities.

 

The Department of Justice, Department of Transportation, Department of Housing and Urban Development, and General Services Administration will have to conduct notice and comment rulemaking to adopt the final revised guidelines as enforceable standards.[39]  More State and local governments are expected to adopt the International Building Code by the time the final revised guidelines are adopted as enforceable standards by the above agencies, which will further reduce the potential impacts toward the lower bound of the range.

 

2.2  Benefits

 

The Access Board worked collaboratively with the International Code Council and the ANSI A117 Committee to harmonize the final revised guidelines with the 2000 and 2003 editions of the International Building Code and the 1998 and 2003 editions of the ICC/ANSI A117.1 Standard for Accessible and Usable Buildings and Facilities.  Harmonization will benefit State and local governments, businesses, architects, and individuals with disabilities.  These benefits are discussed in Chapter 3.  The Access Board also revised some of the scoping and technical requirements in ADAAG to reduce the impacts on facilities.  These revisions are discussed in Chapter 5.

 

2.3  Alternatives

 

The regulatory assessment for the proposed rule estimated that the national costs of the rule would be $87.5 million annually for newly constructed office buildings, hotels, and sports stadiums and arenas.  The Access Board adopted alternatives in the final revised guidelines that eliminate these costs.  These alternatives are discussed in Chapter 4.

2.4  New Construction

 

Designing facilities to be accessible from the beginning generally has minimal impacts on the total construction costs.  Most of the scoping and technical requirements do not add new features or space to facilities, but rather require that features commonly provided meet certain specifications so individuals with disabilities are included.  Most designs are produced today with the assistance of computers.  Designers can simply incorporate the specifications into their computer assisted design (CAD) programs.  This assessment focuses on revisions in the final revised guidelines that either add new features or space to facilities, or present design challenges.

 

2.5  Alterations to Existing Facilities

 

There are two general requirements and an exception that apply to alterations to existing facilities:

 

Element or Space Altered – When an element or space is altered, the altered element or space is required to meet the requirements for new construction.[40]  If the circulation path to the altered element or space is not altered, an accessible route is not required to the altered element or space, unless the altered area contains a primary function.

 

Alterations Affecting Primary Function Areas – If the alterations affect or could affect the usability of or access to an area containing a primary function, the Department of Justice and Department of Transportation regulations implementing the Americans with Disabilities Act require the “path of travel” serving the altered area to be made accessible to the extent that the costs do not exceed 20 percent of the costs of the alterations to the primary function area.[41]  A primary function is a major activity for which the facility is intended.[42]  The “path of travel” includes an accessible route that connects the altered area with an exterior approach, and the toilet rooms, public telephones, and drinking fountains serving the altered primary function area.[43]  When the Department of Justice and Department of Transportation adopt the final revised guidelines as enforceable standards, they will address what an entity’s obligations are when elements that are part of the “path of travel” serving an altered primary function area meet earlier standards, and the revised standards change the requirements for the elements.

 

Technical Infeasibility – If it is not technically feasible to comply with a requirement because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame or because of other existing physical or site constraints, the alteration is required to meet the requirement to the maximum extent feasible.[44]

 

The impacts of the revisions on alterations to existing facilities will be facility specific, and will depend on the elements and spaces that are altered.  For revisions that have monetary impacts, this assessment examines the impacts of the revisions on alterations to existing facilities by answering three questions:

 

• Is the element or space typically altered?

 

• Is the element or space part of the “path of travel” serving a primary function area?[45]

 

• Does alteration of the element or space involve technical infeasibility?

 

This assessment also includes alterations projects when estimating the national costs of the final revised guidelines for office buildings, hotels, hospitals and nursing homes, and Federal, State, and local government housing.  

 

2.6  Readily Achievable Barrier Removal

 

The Americans with Disabilities Act requires places of public accommodation to remove architectural and communication barriers that are structural in nature in existing facilities, where it is readily achievable.[46]  Readily achievable is defined as actions that are “easily accomplishable and able to be carried out without much difficulty or expense.”[47]  The Department of Justice is responsible for issuing regulations to implement the readily achievable “barrier removal” requirement.  When the Department of Justice adopts the final revised guidelines as enforceable standards, it will address what an entity’s obligations are when an element in an existing facility meets earlier standards, and the revised standards change the requirements for the element.  This assessment does not address the impacts of the final revised guidelines on readily achievable “barrier removal” in existing facilities since the Department of Justice will address this issue when it adopts the final revised guidelines as enforceable standards. 

 

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CHAPTER 3:  HARMONIZATION BENEFITS

3.0  Introduction

 

The Access Board worked collaboratively with the International Code Council and the ANSI A117 Committee to harmonize the final revised guidelines with the new International Building Code, which was first issued in 2000 and revised in 2003, and the ICC/ANSA A117.1 Standard on Accessible and Usable Buildings and Facilities, which was revised in 1998 and 2003.  The 2000 and 2003 editions of the International Building Code reference the 1998 edition of the ICC/ANSI A117.1 standard for technical requirements.  As discussed below, harmonization benefits State and local governments, businesses, architects, and individuals with disabilities.   

3.1  State and Local Governments

State and local governments that adopt the model codes and standards want accessibility requirements in the model codes and standards and at the Federal level to be harmonized.  The Americans with Disabilities Act authorizes the Department of Justice to certify State or local codes that meet or exceed Federal accessibility requirements.[48]  State and local governments that adopt the International Building Code will find it easier to have their codes certified, and more State and local governments are expected to submit their codes to the Department of Justice for certification.[49]  In jurisdictions where codes have been certified by the Department of Justice, business owners, builders, developers, and architects can rely on their State or local government building plan approval and inspection processes as a “check-point” for ensuring that their facilities comply with Federal accessibility requirements.  Potential mistakes can be corrected early in the construction process when adjustments can be made easily and inexpensively compared to costly retrofitting after a facility is constructed.  Compliance with a certified code is also evidence of compliance with Federal accessibility requirements in litigation to enforce the Americans with Disabilities Act.[50] 

3.2  Businesses

 

Business owners, builders, and developers want consistent and uniform accessibility requirements adopted by the Federal, State, and local governments.  It is difficult and time consuming for them to deal with different accessibility requirements at each layer of government.  Dealing with different accessibility requirements at the Federal, State, and local levels can also contribute to mistakes requiring costly corrections after the facilities are constructed.    Harmonization of accessibility requirements at the Federal, State, and local levels promotes efficiency and economic growth for businesses.

3.3  Architects

 

Architects who design buildings also want consistent and uniform accessibility requirements adopted by the Federal, State, and local governments.  Architects bear the primary responsibility for designing facilities that meet accessibility requirements and are potentially liable for any mistakes that could result in litigation.  Harmonization of accessibility requirements at the Federal, State, and local levels makes it easier for architects to design accessible facilities and reduces the potential for mistakes and litigation.

3.4  Individuals with Disabilities

 

Individuals with disabilities are the ultimate beneficiaries of harmonization.  The U.S. Census Bureau reports that there are 52.5 million Americans with disabilities in the civilian non-institutionalized population age 5 and over.[51]  Almost one in five individuals has some type of disability.  Among individuals 15 years old and over, 25 million have difficulty walking or using stairs.  Harmonization will result in increased compliance with Federal accessibility requirements in jurisdictions that adopt the model codes and standards, and use their plan approval and inspection processes to check for compliance.  Increased compliance will result in more accessible facilities for individuals with disabilities.

 

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CHAPTER 4:  ALTERNATIVES THAT ELIMINATE COSTS ESTIMATED FOR THE PROPOSED RULE
 

4.0  Introduction

 

The regulatory assessment for the proposed rule estimated that the national costs of the rule would be $87.5 million annually for newly constructed office buildings, hotels, and sports stadiums and arenas.[52]  The Access Board adopted alternatives in the final revised guidelines that eliminate these costs.  This chapter discusses the alternatives that were adopted.  The relevant text of the current guidelines, the proposed rule, and the final revised guidelines is presented in tables.  Unless otherwise noted, the current guidelines refer to ADAAG.  Scoping and technical requirements are presented together, where appropriate.  The text of the proposed rule that imposed the cost and the text of the final revised guidelines that eliminates the cost are underlined.  Where a new requirement was included in the proposed rule, but is not included in the final revised guidelines, there is no underlined text in the final revised guidelines.  Equivalent requirements in the International Building Code and the ICC/ANSI A117.1 Standard on Accessible and Usable Buildings and Facilities are also noted in the tables.[53]

4.1  Office Buildings

 

The proposed rule added a new scoping requirement for visible alarms in employee work areas. The regulatory assessment for the proposed rule estimated the national costs of the revision for newly constructed office buildings would be $16 million annually.  As discussed below, the final revised guidelines eliminate these costs.

 

Visible Alarms in Employee Work Areas

 

Table 4.1 shows the relevant text of the current guidelines, the proposed rule, and the final revised guidelines with respect to the scoping requirement for visible alarms in employee work areas.

 

Table 4.1 - Visible Alarms in Employee Work Areas (text version)

Current Guidelines	Proposed Rule	Final Revised Guidelines
4.1.1(3)  Areas Used Only by Employees as Work Areas.  Areas that are used only as work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas.  These guidelines do not require that any areas used only as work areas be constructed to permit maneuvering within the work area or be constructed or equipped (i.e., with racks or shelves) to be accessible.   4.1.3  Accessible Buildings: New Construction.  Accessible buildings and facilities shall meet the following minimum requirements: . . .   (14)  If emergency warning systems are provided, then they shall include both audible alarms and visual alarms complying with 4.28. . . .	203.3  Employee Work Areas.  Employee work areas shall be designed and constructed so that individuals with disabilities can approach enter, and exit the employee work areas.  In addition, visual alarm coverage shall be provided where audible alarm coverage is provided in employee work areas.  This part does not require that employee work areas be constructed to permit maneuvering with the employee work area or be constructed or equipped to be accessible.   215.1  Fire Alarms.  Where fire alarm systems are provided in public use or common use areas, the alarm shall provide a system with both audible and visual signals complying with 702. . . .	203.9  Employee Work Areas.  Spaces and elements within employee work areas shall only be required to comply with 206.2.8, 207.1, and 215.3 and shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area. . . .   215.1  General.  Where fire alarm systems provide audible alarm coverage, alarms shall comply with 215. . . .   215.2  Public and Common Use Areas.  Alarms in public and common use areas shall comply with 702.   215.3  Employee Work Areas.  Where employee work areas have audible alarm coverage, the wiring system shall be designed so that visible alarms complying with 702 can be integrated into the alarm system.
Model Codes & Standards
IBC 2000:  No requirement for visible alarms in employee work areas.   IBC 2003:  Section 907.9.1.2 has an equivalent requirement for visible alarms in employee work areas.

 

The current guidelines require visible alarms to be provided where fire alarm systems are provided, but do not require areas used only by employees as work areas to be equipped with accessibility features.  As applied to office buildings, the current guidelines require visible alarms to be provided in public and common use areas such as conference rooms, break rooms, and restrooms, where fire alarm systems are provided. 

 

The proposed rule required visible alarm coverage to be provided in employee work areas where audible alarm coverage is provided.  Since building codes and fire and life safety codes generally require visible alarms in open-plan office areas, the regulatory assessment for the proposed rule estimated the impact of extending visible alarm coverage to individual offices.  The cost of installing a single 15 candela visible alarm appliance in an individual office was estimated at $270.[54]  A newly constructed office building with 200,000 square feet in area was estimated to require an additional 250 visible alarm appliances, plus additional power supply and circuits for the alarm system, which would increase the construction cost by $65,375.[55]  The regulatory assessment for the proposed rule estimated the national costs of requiring visible alarms in employee work areas would be $16 million annually for 250 newly constructed office buildings.[56]

 

The final revised guidelines eliminate these costs by requiring the alarm wiring system to be designed so that visible alarms can be added when needed to serve employees who are deaf or hard of hearing.  In new construction, alarm systems are typically designed with circuits at 80 percent of their capacity and the alarm wiring is run through the spaces that are provided with alarm coverage.  In typical configurations with offices along both sides of a corridor, or with offices on one side and open-plan work areas on the other side, the alarm wiring is commonly run in line with the corridor.  This design allows for short wiring “runs” to provide audible and visible alarm appliances in the public and common use areas, and open-plan work areas.  This design also places the alarm wiring in a location where it is relatively easy to extend the wiring into an individual office and install a visible alarm appliance when needed.

4.2  Hotels

 

The proposed rule revised the scoping requirement for guest rooms with communication features.  The regulatory assessment for the proposed rule estimated the national costs of the revision for newly constructed hotels would be $31 million annually.  As discussed below, the final revised guidelines eliminate these costs.

 

Guest Rooms with Communication Features

 

Table 4.2 shows the relevant text of the current guidelines, the proposed rule, and the final revised guidelines with respect to the scoping requirement for guest rooms with communications features.[57]

 

Table 4.2 – Guest Rooms with Communication Features (text version)

 

The current guidelines require hotels to provide a minimum number of guest rooms with mobility features based on the total number of guest rooms in the facility.  The current guidelines require an additional minimum number of guest rooms to provide roll-in showers.  All the guest rooms that are required to provide mobility features and roll-in showers are also required to provide communication features for individuals who are deaf or hard of hearing.  The current guidelines also require hotels to provide an additional minimum number of guest rooms with communication features for individuals who are deaf or hard of hearing.

 

The proposed rule required a minimum of 50 percent of the total number of guest rooms to provide communication features.  The regulatory assessment for the proposed rule estimated the cost of providing communication features in a guest room at $556, including $293 for a 110 candela visible alarm appliance and $263 for a notification device.[58]  The proposed rule required a newly constructed hotel with 150 guest rooms to provide a minimum of 75 guest rooms with communication features, compared to a minimum of 12 guest rooms under the current guidelines, which would increase the construction cost by $35,028.[59]  The regulatory assessment for the proposed rule estimated the national costs of increasing the number of guest rooms required to provide communication features to a minimum of 50 percent of the total number of guest rooms would be $31 million annually for 890 newly constructed hotels.[60]

 

The final revised guidelines make no change from the current guidelines with respect to the number of guest rooms required to provide communication features.  The scoping requirement is consolidated into a single table in the final revised guidelines, instead of appearing in three sections as in the current guidelines.  The final revised guidelines also limit the overlap between guest rooms required to provide mobility features and guest rooms required to provide communication features.  At least one, but not more than 10 percent, of the guest rooms required to provide mobility features can also provide communication features.

4.3  Sports Stadiums and Arenas

 

The proposed rule revised the scoping requirements for vertical access, vertical dispersion of wheelchair spaces, companion seats, and designated aisle seats in assembly areas. The regulatory assessment for the proposed rule estimated the national costs of the revisions for newly constructed sports stadiums and arenas would be $40.5 million.  As discussed below, the final revised guidelines eliminate these costs.

 

Vertical Access

 

Table 4.3 shows the relevant text of the current guidelines, the proposed rule, and the final revised guidelines with respect to the scoping requirement for vertical access.

 

Table 4.3 - Vertical Access (text version)

 

The current guidelines require one accessible passenger elevator to serve each level in multi-story facilities, unless an exception applies.  If more than one elevator is provided, each elevator is required to be accessible. 

 

The proposed rule required elevators or platform lifts to be provided to wheelchair spaces and designated aisle seats in sports stadiums and arenas in sufficient number, capacity, and speed so as to provide a level of service equivalent to that provided in the same seating area to patrons who can use stairs.  The regulatory assessment for the proposed rule assumed large sports facilities with 50,000 seats would add 3 more elevators to provide equivalent vertical access to wheelchair spaces and designated aisle seats; medium sports facilities with 20,000 seats would add 2 more elevators; and small sports facilities with 11,000 seats would add 1 more elevator.[61]  The cost of installing a 3-stop hydraulic elevator was estimated at $61,794.[62]  The regulatory assessment for the proposed rule estimated the national costs of requiring equivalent vertical access to wheelchair spaces and designated aisle seats would be $1.5 million annually for 3 large, 5 medium, and 5 small newly constructed sports facilities.[63]

 

The final revised guidelines make no change from the current guidelines with respect to accessible routes in multi-story facilities.

 

Vertical Dispersion of Wheelchair Spaces[64]

 

Table 4.4 shows the relevant text of the current guidelines, the proposed rule, and the final revised guidelines with respect to the scoping requirement for vertical dispersion of wheelchair spaces in assembly areas.
 

Table 4.4 – Vertical Dispersion of Wheelchair Spaces (text version)

 

The current guidelines require wheelchair spaces to be located in more than one area where the seating capacity exceeds 300 and to provide a choice of admission prices.  Under the current guidelines, sports facilities typically locate some wheelchair spaces on each accessible level of the facilities.

 

The proposed rule required wheelchair spaces and designated aisle seats to be provided in each price level distinguishable by location, and to be located at varying distances from the performance area on each accessible level and in each balcony or mezzanine that is located along an accessible route.  The regulatory assessment for the proposed rule assumed large sports facilities with 50,000 seats would add an additional upper deck concourse to achieve this level of dispersion, which would increase the construction cost by $11 million, and estimated the national costs would be $33 million annually for 3 newly constructed large sports facilities.[65]  The regulatory assessment for the proposed rule further assumed medium sports facilities with 20,000 seats would add 4 lifts, and small sports facilities with 11,000 seats would add 2 lifts.[66]  The cost of installing a lift was estimated at $14,213, and the national costs would be $0.5 million annually for 5 medium and 5 small newly constructed sports facilities.[67]

 

The final revised guidelines do not require wheelchair spaces to be dispersed based on admission prices because pricing is not always established at the design phase and may vary by event.  Instead of requiring wheelchair spaces to be vertically dispersed on each accessible level, the final revised guidelines require wheelchair spaces to be vertically dispersed at varying distances from the screen, performance area, or playing field.  The final revised guidelines also require wheelchair spaces to be located in each balcony or mezzanine served by an accessible route.  Sports facilities can meet the requirements by locating some wheelchair spaces on each accessible level of the facilities, which is consistent with the current guidelines.

Companion Seats

 

Table 4.5 shows the relevant text of the current guidelines, the proposed rule, and the final revised guidelines with respect to the scoping and technical requirements for companion seats in assembly areas.

 

Table 4.5 - Companion Seats (text version)

 

The current guidelines require at least one fixed companion seat to be provided next to each wheelchair space. 

 

The proposed rule required companion seats to be designed so the seat can be readily removed and serve as a wheelchair space.  The regulatory assessment for the proposed rule estimated 6 square feet must be added to the companion seat space to make it serve as a wheelchair space; and an anchoring system must be provided to make the seat removable.  These requirements would add $1,315 per seat to the construction cost.[68]  A newly constructed large sports facility with 50,000 seats must provide 501 companion seats, which would add $661,320 to the construction cost.[69]  A newly constructed medium sports facility with 20,000 seats must provide 201 companion seats, which would add $265,320 to the construction cost.[70]  A newly constructed small sports facility with 11,000 seats must provide 111 companion seats, which would add $146,520 to the construction cost.[71]  The regulatory assessment for the proposed rule estimated the national costs for requiring removable companion seats that can also serve as wheelchair spaces would be $4 million annually for 3 large, 5 medium, and 5 small newly constructed sports facilities.

 

The final revised guidelines permit companion seats to be readily removable, but do not require the seats to be designed so they can also serve as wheelchair spaces when removed. 

 

Designated Aisle Seats

 

Table 4.6 shows the relevant text of the current guidelines, the proposed rule, and the final revised guidelines with respect to the scoping and technical requirements for designated aisle seats in assembly areas.

 

Table 4.6 - Designated Aisle Seats (text version)

 

The current guidelines require 1 percent of fixed seats in assembly areas to be designated aisle seats.  Designated aisle seats must have either no armrests or folding or retractable armrests on the aisle side of the seat.

 

The proposed rule required at least 25 percent of the designated aisle seats to be located on an accessible route, and the rest to be located no more than two rows from an accessible route.  The regulatory assessment for the proposed rule assumed large and medium sports facilities would add accessible routes to comply with this requirement.[72]  The upper deck concourses added to large sports facilities to comply with the proposed rule’s vertical dispersion requirements for wheelchair spaces were assumed to also provide the accessible routes needed to comply with the proposed rule’s designated aisle seat requirements.[73]  The regulatory assessment for the proposed rule further assumed medium sports facilities with 20,000 seats would add 1,500 square feet to provide accessible routes to the designated aisle seats, and would increase the construction cost by $306,000.[74]  The regulatory assessment for the proposed rule estimated the national costs would be $1.5 million annually for 5 medium newly constructed sports facilities.[75]

 

The final revised guidelines base the number of required designated aisle seats on the number of aisle seats, instead of all the seats in a sports facility as the current guidelines do.  At least 5 percent of the aisle seats are required to be designated aisle seats and to be located closest to accessible routes.  This revision will almost always result in fewer aisle seats being designated aisle seats compared to the current guidelines.  Sports facilities typically locate designated aisle seats on, or as near to, accessible routes as permitted by the configuration of the facilities. 

 

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CHAPTER 5:  REVISIONS THAT REDUCE IMPACTS 

5.0  Introduction

 

This chapter discusses revisions to the scoping and technical requirements that will reduce impacts on the new construction and alterations of facilities.  Some of the revisions will significantly reduce impacts, such as the revised scoping requirements for wheelchair spaces and assistive listening systems in large assembly areas, and the exceptions for accessible routes to small press boxes.  The relevant text of the current guidelines and the final revised guidelines is presented in tables.  Unless otherwise noted, the current guidelines refer to ADAAG.  The requirements are presented in the order in which they appear in the final revised guidelines.  Scoping and technical requirements are presented together, where appropriate.  The text of the final revised guidelines that will reduce the impacts is underlined.  Where the current guidelines contain related text, it is also underlined.  Equivalent requirements in the International Building Code and the ICC/ANSI A117.1 Standard on Accessible and Usable Buildings and Facilities are also noted in the tables.[76]

5.1  Limited Access Spaces and Machinery Spaces

 

Table 5.1 shows the relevant text of the current guidelines and the final revised guidelines with respect to the exceptions for limited access spaces and machinery spaces.

 

Table 5.1 – Limited Access Spaces and Machinery Spaces (text version)

 

The current guidelines contain an exception that exempts “non-occupiable” spaces that have limited means of access, such as ladders or very narrow passageways, and that are visited only by service personnel for maintenance, repair, or occasional monitoring of equipment from all accessibility requirements.  The final revised guidelines expand this exception by removing the condition that the exempt spaces be “non-occupiable,” and by separating the other conditions into two independent exceptions: one for spaces with limited means of access, and the other for machinery spaces.  More spaces are exempted by these exceptions to the final revised guidelines.

 

5.2  Operable Parts[77]

 

Table 5.2 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for operable parts.

 

Table 5.2 – Operable Parts (text version)

 

The current guidelines and the final revised guidelines require operable parts on accessible elements, along accessible routes, and in accessible rooms and spaces to comply with the technical requirements for operable parts, including height and operation.  The current guidelines contain an exception that exempts “special equipment [that] dictates otherwise,” and electrical and communications systems receptacles not intended for use by building occupants from the technical requirement for height.  The final revised guidelines divide this exception into three new exceptions covering operable parts intended only for use by service or maintenance personnel; electrical or communication receptacles serving a dedicated use; and floor electrical receptacles.  Operable parts covered by these new exceptions are exempt from all the technical requirements for operable parts.  The final revised guidelines add new exceptions that exempt certain outlets at kitchen counters; HVAC diffusers; and redundant controls provided for a single element, other than light switches, from the technical requirements for operable parts.  The final revised guidelines also exempt gas pump nozzles from the technical requirement for activating force.

 

5.3  Accessible Routes from Site Arrival Points and Within Sites

 

Table 5.3 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for accessible routes from site arrival points and within sites.

 

Table 5.3 – Accessible Routes from Site Arrival Points and Within Sites (text version)

 

The current guidelines and the final revised guidelines require at least one accessible route to be provided from site arrival points to an accessible building entrance, and at least one accessible route to connect accessible facilities on the same site.  The final revised guidelines add two new exceptions that exempt site arrival points and accessible facilities within a site from the accessible route requirements where the only means of access between them is a vehicular way that does not provide pedestrian access.

5.4  Accessible Routes to Tiered Dining Areas in Sports Facilities

 

Table 5.4 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for accessible routes to dining areas.

 

Table 5.4 – Accessible Routes to Dining Areas (text version)

 

The current guidelines and the final revised guidelines require an accessible route to be provided to all dining areas, including raised or sunken dining areas.  The final revised guidelines add a new exception for tiered dining areas in sports facilities.  Dining areas in sports facilities are typically integrated into the seating bowl and are tiered to provide adequate lines of sight.  The new exception requires an accessible route to be provided to at least 25 percent of the tiered dining areas in sports facilities.  Each tier must have the same services and the accessible route must serve the accessible seating.

5.5  Accessible Routes to Press Boxes

 

Table 5.5 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for accessible routes to press boxes.

 

Table 5.5 – Accessible Routes to Press Boxes (text version)

 

The current guidelines require all areas of newly constructed facilities to be accessible, and an accessible route to connect accessible entrances with all accessible spaces and elements within the facility.  The final revised guidelines add two new exceptions that exempt small press boxes that are located on bleachers with entrances on only one level, and small press boxes that are free-standing structures elevated more than 12 feet, from the accessible route requirement when the aggregate area of all press boxes in a sports facility does not exceed 500 square feet.  These new exceptions significantly reduce the impacts on high school sports facilities.

5.6  Shower and Sauna Doors in Hotel Guest Rooms

 

Table 5.6 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for doors in hotel guest rooms.

 

Table 5.6 – Shower and Sauna Doors in Hotel Guest Rooms (text version)

 

The current guidelines and the final revised guidelines require doors in hotel guest rooms that do not provide mobility features to have at least 32 inches clear width.[78]  The final revised guidelines add a new exception that exempts shower and sauna doors from the requirement.

5.7  Limited-Use/Limited-Application Elevators and Private Residence Elevators

 

Table 5.7 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for elevators.

 

Table 5.7 – Limited-Use/Limited-Application Elevators and Private Residence Elevators (text version)

 

The current guidelines and the final revised guidelines include exceptions to the scoping requirement for accessible routes that exempt certain facilities from connecting each story with an elevator.  If a facility is exempt from the scoping requirement, but nonetheless installs an elevator, the current guidelines require the elevator to comply with the technical requirements for passenger elevators.  The final revised guidelines add a new exception that allows a facility that is exempt from the scoping requirement to install a limited-use/limited-application (LULA) elevator.  LULA elevators are typically less expensive than passenger elevators, and are suitable for low-traffic, low-rise facilities.  LULA elevators are also permitted as an alternative to platform lifts.  The final revised guidelines also add a new exception that permits private residence elevators in multi-story dwelling units.  The final revised guidelines contain technical requirements for LULA elevators and private residence elevators.

 

5.8  Platform Lifts in Hotel Guest Rooms and Dwelling Units

 

Table 5.8 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for platform lifts.

 

Table 5.8 – Platform Lifts in Hotel Guest Rooms and Dwelling Units (text version)

 

The current guidelines and the final revised guidelines limit the places where platform lifts are permitted to be used as part of an accessible route in new construction.  The final revised guidelines add a new scoping requirement that permits platform lifts to be used in hotel guest rooms and dwelling units with mobility features.

5.9  Parking Spaces[79]

 

Table 5.9 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for parking spaces.

 

Table 5.9 – Parking Spaces (text version)

 

Where parking spaces are provided, the current guidelines and the final revised guidelines require a certain number of the parking spaces to be accessible.  The final revised guidelines add a new exception that exempts parking spaces used exclusively for buses, trucks, delivery vehicles, law enforcement vehicles, or for purposes of vehicular impound from the scoping requirement for parking spaces.  If a lot containing parking spaces for these vehicles is used by the public, the lot is required to have an accessible passenger loading zone. 

 

The current guidelines and the final revised guidelines require accessible parking spaces to be identified by signs that display the International Symbol of Accessibility.  The final revised guidelines add two new exceptions that exempt accessible parking spaces from the signage requirement.  The first exception exempts sites that have four or less parking spaces from the signage requirement.  This exception will reduce the impacts on small businesses.  The second exception exempts residential facilities where parking spaces are assigned to specific dwelling units from the signage requirement.

5.10     Passenger Loading Zones at Medical Care and Long-Term Care Facilities[80]

 

Table 5.10 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for passenger loading zones at medical care and long-term care facilities.

 

Table 5.10 – Passenger Loading Zones at Medical Care and Long-Term Care Facilities (text version)

 

The current guidelines and the final revised guidelines require medical care and long-term care facilities, where the period of stay exceeds 24 hours, to provide at least one passenger loading zone at an accessible entrance.  The current guidelines also require a canopy or roof overhang at the passenger loading zone.  The final revised guidelines do not require a canopy or roof overhang.

 

5.11     Aisle Stairs and Ramps in Assembly Areas

 

Table 5.11 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for aisle stairs and ramps in assembly areas.

 

Table 5.11 – Aisle Stairs and Ramps in Assembly Areas (text version)

 

The current guidelines require stairs that connect levels not served by an elevator, ramp, or platform lift to comply with the technical requirements for stairs.  The final revised guidelines require stairs that are part of a means of egress to comply with the technical requirements for stairs.  The current guidelines do not contain any exceptions for aisle stairs in assembly areas.  The final revised guidelines add a new exception that exempts aisle stairs in assembly areas from the technical requirements for stairs, including handrails.

 

The current guidelines exempt aisle ramps adjacent to seating in assembly areas only from providing handrails.  The final revised guidelines exempt aisle ramps adjacent to seating in assembly areas, which do not serve accessible elements, from all the technical requirements for ramps.  Where aisle ramps in assembly areas serve accessible elements, the final revised guidelines exempt the aisle ramps from providing:

 

§    Handrails on both sides of an aisle ramp, where a handrail is provided at one side of the aisle ramp or within the aisle ramp.

 

§    Continuous handrails for the full length of an aisle ramp run.

 

§    Handrail extensions beyond an aisle ramp run, where there are breaks in the handrail to provide access to seating and to permit crossovers within the aisle.

 

5.12     Multiple Single User Toilet Rooms[81]

 

Table 5.12 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for toilet rooms.

 

Table 5.12 – Multiple Single User Toilet Rooms (text version)

 

The current guidelines and the final revised guidelines require each toilet room to be accessible.  The final revised guidelines add a new exception for multiple single user toilet rooms clustered at a single location.  The exception requires at least 50 percent of these toilet rooms to be accessible.  This exception will reduce the impacts on medical facilities where multiple single user toilet rooms are provided for specimen collection.

 

5.13     Urinals

 

Table 5.13 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for urinals.

 

Table 5.13 – Urinals (text version)

 

Where urinals are provided, the current guidelines require at least one to be accessible.  The final revised guidelines require at least one urinal to be accessible, where more than one is provided.  If a toilet room has only one urinal, an accessible urinal is not required.

 

5.14     Visible Alarms in Alterations to Existing Facilities

 

Table 5.14 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for visible alarms in alterations to existing facilities.

 

Table 5.14 – Visible Alarms and Alterations to Existing Facilities (text version)

 

The current guidelines and the final revised guidelines require that when existing elements and spaces of a facility are altered, the alterations must comply with new construction requirements.  The final revised guidelines add a new exception to the scoping requirement for visible alarms in alterations to existing facilities.  Visible alarms are required only when an existing fire alarm system is upgraded or replaced, or a new fire alarm system is installed. 

5.15     Signs

 

Table 5.15 shows the relevant text of the current guidelines and the final revised guidelines with respect to scoping and technical requirements for signs.

 

Table 5.15 – Signs (text version)

 

The current guidelines and the final revised guidelines have scoping and technical requirements for certain signs.  The current guidelines contain an exception that exempts building directories, menus, and temporary signs from the requirements.  The final revised guidelines expand this exception to include seat and row designations in assembly areas, occupant names, building addresses, and company names and logos.  The final revised guidelines also exempt signs in parking facilities, other than signs identifying accessible parking spaces and means of egress. The final revised guidelines clarify that the exception for temporary signs applies to signs used for 7 days or less.  The final revised guidelines add a new exception that exempts exterior signs identifying permanent rooms and spaces from providing tactile characters, where the exterior signs are not located at the door to the space they serve. 

 

The current guidelines require signs with tactile characters identifying permanent rooms to be located 60 inches above the finish floor along the latch side of the door, measured to the centerline of the sign.  The final revised guidelines provide greater flexibility, and require the signs be located between 48 inches above the finish floor, measured from the baseline of the lowest tactile character, and 60 inches above the finish floor, measured from the baseline of the highest tactile character.  The final revised guidelines also permit signs with tactile characters to be located on the push side of doors with closers that do not have hold-open devices.

 

5.16     Drive-Up Public Telephones

 

Table 5.16 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for wheelchair accessible public telephones.

 

Table 5.16 – Public Telephones (text version)

 

Where public telephones are provided, the current guidelines and the final revised guidelines require a certain number of telephones to be wheelchair accessible.  The final revised guidelines add a new exception that exempts drive-up public telephones.

 

5.17     Assistive Listening Systems[82]

 

Table 5.17.1 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for assistive listening systems.

 

Table 5.17.1 – Assistive Listening Systems (text version)

 

The current guidelines require assembly areas where audible communication is integral to the use of the space to provide an assistive listening system if they have an audio amplification system or an occupant load of 50 or more persons.  The final revised guidelines exempt assembly areas, other than court rooms, that do not have audio amplification systems from providing assistive listening systems. 

 

The current guidelines require receivers to be provided for at least 4 percent of the seats or room occupant load.  The final revised guidelines revise the percentage of receivers required.  As Table 5.17.2 shows, the number of receivers is significantly reduced for larger assembly areas.

 

Table 5.17.2 – Number of Receivers Required (text version)

 

The final revised guidelines add a new exception that allows multiple assembly areas that are in the same building and under the same management, such as theaters in a multiplex cinema and lecture halls in a college building, to calculate the number of receivers required based on the total number of seats in all the assembly areas, instead of each assembly area separately, where the receivers are compatible with the assistive listening systems used in each of the assembly areas.

 

The final revised guidelines also require at least 25 percent, but no fewer than two, of the receivers to be hearing-aid compatible.  Assembly areas served by an induction loop assistive listening system do not have to provide hearing-aid compatible receivers.

 

5.18     Wheelchair Spaces in Assembly Areas[83]

 

Table 5.18.1 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for wheelchair spaces in assembly areas.

 

Table 5.18.1 – Wheelchair Spaces in Assembly Areas (text version)

 

The current guidelines and the final revised guidelines require assembly areas with fixed seating to provide wheelchair spaces based on seating capacity.  The final revised guidelines revise the number of wheelchair spaces required in assembly areas with more than 500 seats.  As Table 5.18.2 shows, the number of wheelchair spaces is significantly reduced for larger assembly areas.

 

Table 5.18.2 – Number of Wheelchair Spaces Required (text version)

 

The final revised guidelines clarify that the scoping requirements are to be applied separately to general seating areas, and to each luxury box, club box, and suite in stadiums and arenas.  In performing arts facilities with tiered boxes, the scoping requirement is applied to the total number of seats in the tiered boxes, and the wheelchair spaces are required to be dispersed among at least 20 percent of the tiered boxes.  For example, if a performing arts facility has 20 tiered boxes with 5 fixed seats in each box, at least 4 wheelchair spaces must be provided in the boxes, and they must be dispersed among at least 4 of the 20 boxes.

 

5.19     Patient Toilet Rooms[84]

 

Table 5.19 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for patient toilet rooms. 

 

Table 5.19 – Patient Toilet Rooms (text version)

 

The current guidelines and the final revised guidelines require a percentage of patient sleeping rooms to provide mobility features, including accessible toilet rooms. The final revised guidelines add a new exception that exempts toilet rooms serving critical or intensive care patient sleeping rooms.

5.20     Self-Service Storage Facilities

 

Table 5.20 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for self-service storage facilities.

 

Table 5.20 – Self-Service Storage Facilities (text version)

 

The current guidelines require all areas of newly constructed facilities to be accessible.  The final revised guidelines add a new scoping requirement for self-storage facilities.  Facilities with 200 or fewer storage spaces are required to make at least 5 percent of the storage spaces accessible.  Facilities with more than 200 storage spaces are required to provide 10 accessible storage spaces, plus make at least 2 percent of the storage spaces over 200 accessible. 

5.21     Washing Machines and Clothes Dryers

 

Table 5.21 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for washing machines and clothes dryers.

 

Table 5.21 Washing Machines and Clothes Dryers (text version)

 

The current guidelines do not contain a specific scoping requirement for washing machines and clothes dryers.[85]  The final revised guidelines require at least one of each machine to be accessible, where three or fewer of each machine are provided; and at least two of each machine to be accessible, where more than three of each machine are provided.  The current guidelines and the final revised guidelines require the operable parts of accessible equipment to be placed within a forward or side reach; and specify a 34 inch maximum height for an obstruction for a high side reach.  The final revised guidelines add a new exception for a high side reach over washing machines and clothes dryers that permit the tops of the machines to be 36 inches maximum above the finish floor to accommodate currently available machines.

 

5.22     Handrails[86]

 

Table 5.22 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirements for handrails.

 

Table 5.22 – Handrails (text version)

 

The current guidelines and the final revised guidelines contain technical requirements for handrails.  The final revised guidelines provide more flexibility than the current guidelines as follows:

 

§    The current guidelines require the clearance between handrail gripping surfaces and adjacent surfaces to be exactly 1½ inches.  The final revised guidelines require the clearance to be 1½ inches minimum.

 

§    The current guidelines require handrail gripping surfaces to have edges with a minimum radius of ⅛ inch.  The final revised guidelines require handrail gripping surfaces to have rounded edges.

 

§    The current guidelines require handrail gripping surfaces to have a diameter of 1¼ inches to 1½ inches, or to provide an equivalent gripping surface.  The final revised guidelines require handrail gripping surfaces with a circular cross section to have an outside diameter of 1¼ inches to 2 inches.  Handrail gripping surfaces with a non-circular cross section must have a perimeter dimension of 4 inches to 6¼ inches, and a cross section dimension of 2¼ inches maximum.

 

§    The current guidelines require handrail gripping surfaces to be continuous, and to be uninterrupted by newel posts, other construction elements, or obstructions.  The final revised guidelines require handrail gripping surfaces to be continuous along their length and not to be obstructed along their tops or sides.  The bottoms of handrail gripping surfaces must not be obstructed more than 20 percent of their length.  Where provided, horizontal projections must occur at least 1½ inches below the bottom of the handrail gripping surface.  An exception permits the distance between the horizontal projections and the bottom of the gripping surface to be reduced by ⅛ inch for each ½ inch of additional handrail perimeter dimension that exceeds 4 inches.

 

§    The current guidelines require handrails at the bottom of stairs to extend at least 12 inches plus the width of one tread beyond the bottom riser.  The final revised guidelines require handrails at the bottom of stairs to extend a horizontal distance at least equal to one tread depth beyond the last riser nosing.  The final revised guidelines add a new exception for alterations to existing facilities that exempts handrails at the top and bottom of ramps and stairs from providing full extensions where it would be hazardous due to plan configuration.

 

5.23     Toilet Room Doors[87]

 

Table 5.23 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirement for toilet room doors.

 

Table 5.23 – Toilet Room Doors (text version)

 

The current guidelines and the final revised guidelines prohibit doors from swinging into the clear floor space or clearance required for any fixture in toilet rooms.  The final revised guidelines add a new exception for single-user toilet rooms that permits the door to swing into the clear floor space or clearance required for any fixture, where a clear floor space is provided within the room beyond the arc of the door swing.  This exception results in at least a 7 square feet reduction in the required size of an accessible single-user toilet room.

 

5.24     Water Closet Location and Rear Wall Grab Bar[88]

 

Table 5.24 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirements for the water closet location and rear grab bar. 

 

Table 5.24 – Water Closet Location and Rear Wall Grab Bar (text version)

 

The current guidelines and the final revised guidelines contain technical requirements for the location of water closets and the rear wall grab bar.  The current guidelines require the centerline of the water closet in accessible toilet rooms and compartments to be located exactly 18 inches from the side wall, and the rear wall grab bar to be at least 36 inches long.  The final revised guidelines require the centerline of the water closet to be located between 16 inches and 18 inches from the side wall.  The final revised guidelines add a new exception that permits the rear wall grab bar to be at least 24 inches long, where there is not enough wall space for a 36 inch long grab bar because a lavatory is located adjacent to the water closet and the wall behind the lavatory is recessed so that the lavatory does not overlap the clear floor space at the water closet.

 

5.25     Shower Compartments[89]

 

Table 5.25 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirements for shower compartments.

 

Table 5.25 – Shower Compartments (text version)

 

The current guidelines and the final revised guidelines contain technical requirements for transfer-type and roll-in shower compartments.  The final revised guidelines provide more flexibility than the current guidelines as follows:

 

§    Transfer-type showers are 36 inches by 36 inches and have a folding or non-folding seat.  The final revised guidelines specify that these dimensions are measured at the center point of opposing sides to accommodate molded compartments with rounded bottom edges. 

 

§    The current guidelines and the final revised guidelines permit a ½ inch maximum curb in transfer-type showers.  The final revised guidelines add a new exception that permits a 2 inch maximum curb in transfer-type showers in alterations to existing facilities, where recessing the compartment to achieve a ½ inch curb would disturb the structural reinforcement of the floor slab.

 

§    Roll-in showers are 30 inches minimum by 60 inches minimum.  Alternate roll-in showers are 36 inches by 60 inches minimum, and have a 36 inch minimum opening on the long side of the compartment.  The current guidelines permit alternate roll-in showers to be used only in hotel guest rooms; require a seat to be provided on the side with the opening; and require the controls to be located on the side adjacent to the seat.  The final revised guidelines permit alternate roll-in showers to be used in any facility; only require a seat in hotel guest rooms; and provide more locations for the controls. 

 

§    The current guidelines prohibit curbs in roll-in showers.  The final revised guidelines permit a ½ inch maximum curb. 

5.26     Sales and Service Counters

 

Table 5.26 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirements for sales and service counters.

 

Table 5.26 – Sales and Service Counters (text version)

 

The current guidelines and the final revised guidelines contain technical requirements for sales and service counters.  The current guidelines generally require counters to have an accessible portion at least 36 inches long and no higher than 36 inches.  The current guidelines provide some flexibility for counters that do not have cash registers.  The final revised guidelines specify different lengths for the accessible portion of counters based on the type of approach.  Where a forward approach is provided, the accessible portion of the counter must be at least 30 inches long and no higher than 36 inches, and knee and toe space must be provided under the counter.  Where a parallel approach is provided, the accessible portion of the counter must be at least 36 inches long and no higher than 36 inches.  The final revised guidelines add a new exception for alterations to counters in existing facilities that permits the accessible portion of the counter to be at least 24 inches long, where providing a longer accessible counter would result in a reduction in the number of existing counters or existing mailboxes.

 

The final revised guidelines clarify that the accessible portion of the counter must extend the same depth as the sales or service counter top.  Where the counter is a single-height counter, this requirement applies across the entire depth of the counter top.  Where the counter is a split-height counter, this requirement applies only to the customer side of the counter top.  The employee-side of the counter top may be higher or lower than the customer-side of the counter top.

5.27     Detectable Warnings

 

Table 5.27 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for detectable warnings.

 

Table 5.27 – Detectable Warnings (text version)

 

Detectable warnings are a distinctively textured surface of truncated domes that is identifiable by cane and underfoot.  The current guidelines require detectable warnings at curb ramps, hazardous vehicular areas, reflecting pools, and transit platform edges.[90]  The final revised guidelines only require detectable warnings at transit platform edges.[91]  The final revised guidelines change the specifications for the diameter and spacing of the truncated domes to permit a range of dimensions.  The final revised guidelines also delete the requirements for the material used to provide contrast to be an integral part of the truncated domes, and for the truncated domes to contrast in resiliency or sound-on-cane contact from adjoining walking surfaces at interior locations.
 

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CHAPTER 6:  REVISIONS THAT HAVE MINIMAL IMPACTS

6.0  Introduction

 

This chapter discusses revisions to the scoping and technical requirements that will have minimal impacts on the new construction and alteration of facilities.  The relevant text of the current guidelines and the final revised guidelines is presented in tables.  Unless otherwise noted, the current guidelines refer to ADAAG.  The requirements are presented in the order in which they appear in the final revised guidelines.  Scoping and technical requirements are presented together, where appropriate.  The text of the current guidelines and the final revised guidelines is underlined to highlight the revisions in the scoping and technical requirements.  Equivalent requirements in the International Building Code and the ICC/ANSI A117.1 Standard on Accessible and Usable Buildings and Facilities are also noted in the tables.[92]

6.1  Alterations to Primary Function Areas

 

Table 6.1 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for alterations to primary function areas.  The current guidelines refer to UFAS.   

 

Table 6.1 – Alterations to Primary Function Areas (text version)

 

UFAS requires an accessible route, accessible entrance, and accessible toilets to be provided when alterations amount to 50 percent or more of the value of the facility.  When alterations affect a primary function area containing a major activity for which the facility is intended, the final revised guidelines require the path of travel to the altered area and the toilet rooms, public telephones, and drinking fountains serving the altered area to be made accessible, to the extent that the cost of making these elements accessible does not exceeds 20 percent of the cost of the alterations to the primary function area.[93]

 

The revision affects Federal, State, and local governments.  The impacts are expected to be minimal since federally financed facilities subject to standards issued by the General Services Administration are required to comply with ADAAG when it provides an improved level of access compared to UFAS.[94]  State and local governments are permitted to use either ADAAG or UFAS.[95]  Many State and local governments use ADAAG.  The impacts are further minimized by the fact that State and local governments have made many of their existing facilities accessible to comply with separate program accessibility requirements under the Americans with Disabilities Act and section 504 of the Rehabilitation Act. 

 

6.2  Common Use Circulation Paths in Employee Work Areas

 

Table 6.2.1 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for common use circulation paths in employee work areas. 
 

Table 6.2.1 – Common Use Circulation Paths in Employee Work Areas (text version)

Current Guidelines	Final Revised Guidelines
4.1.1  Application. . .  .   (3)  Areas Used Only by Employees as Work Areas.  Areas that are used only as work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas.  These guidelines do not require that any areas used only as work areas be constructed to permit maneuvering within the work area or be constructed or equipped (i.e., with racks or shelves) to be accessible.	203.9 Employee Work Areas.  Spaces and elements within employee work areas shall only be required to comply with 206.2.8, 207.1, and 215.3 and shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area.  Employee work areas, or portions of employee work areas, that are less than 300 square feet (28 m²) in area and elevated 7 inches (178 mm) or more above the finish floor or ground where the elevation is essential to the function of the space shall not be required to comply with these requirements or to be on an accessible route.   206.2.8 Employee Work Areas.  Common use circulation paths within employee work areas shall comply with 402. Exceptions:  1.  Common use circulation paths located within employee work areas that are less than 1000 square feet (93 m²) and defined by permanently installed partitions, counters, casework, or furnishings shall not be required to comply with 402. 2.  Common use circulation paths located within employee work areas that are an integral component of work area equipment shall not be required to comply with 402. 3.  Common use circulation paths located within exterior employee work areas that are fully exposed to the weather shall not be required to comply with 402.   402.1 General.  Accessible routes shall comply with 402.   402.2  Components.  Accessible routes shall consist of one or more of the following components: walking surfaces with a running slope not steeper than 1:20, doorways, ramps, curb ramps excluding the flared sides, elevators, and platform lifts.  All components of accessible routes shall comply with the applicable requirements of Chapter 4.   403.5 Clearances.  Walking surfaces shall provide clearances complying with 403.5. Exception:  Within employee work areas, clearances on common use circulation paths shall be permitted to be decreased by work area equipment provided that the decrease is essential to the function of the work being performed.   405.5 Clear Width.  The clear width of a ramp run and, where handrails are provided, the clear width between handrails shall be 36 inches (915 mm) minimum.  Exception:  Within employee work areas, the required clear width of ramps that are a part of common use circulation paths shall be permitted to be decreased by work area equipment provided that the decrease is essential to the function of the work being performed.   405.8 Handrails.  Ramp runs with a rise greater than 6 inches (150 mm) shall have handrails complying with 505. Exception:  Within employee work areas, handrails shall not be required where ramps that are part of common use circulation paths are designed to permit the installation of handrails complying with 505.  Ramps not subject to the exception to 405.5 shall be designed to maintain a 36 inch (915 mm) clear width when handrails are installed.
Model Codes & Standards
IBC 2000:  Section 1103.2.3 has similar requirements and exceptions for employee work areas.    IBC 2003:  Section 1104.3.1 has equivalent requirements and similar exceptions for employee work areas.

 

The current guidelines and the final revised guidelines require employee work areas to be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas.  The work areas themselves are not required to be accessible.  The Americans with Disabilities Act requires employers to make reasonable accommodations in the workplace for individuals with disabilities, which may include modifications to work areas when needed.[96]

 

The final revised guidelines require common use circulation paths within employee works areas to comply with the technical requirements for accessible routes.  Individual employee work stations, such as a grocery checkout counter or an automobile service bay designed for use by one person, do not contain common use circulation paths and are not required to comply.[97]

 

The final revised guidelines contain several exceptions that exempt common use circulation paths in employee work areas where it may be difficult to comply with the technical requirements for accessible routes due to the size or function of the area.

 

• Employee work areas, or portions of employee work areas, that are less than 300 square feet and are elevated 7 inches or more above the ground or finish floor, where elevation is essential to the function of the space, are exempt.  Small work stations in factories are covered by this exception.

 

• Common use circulation paths within employee work areas that are less than 1,000 square feet and are defined by permanently installed partitions, counters, casework, or furnishings are exempt.  Fast food kitchens, cocktail bars, and the employee side of service counters are covered by this exception.

 

• Common use circulation paths within employee work areas that are an integral component of equipment are exempt.  Common use circulation paths within large pieces of equipment in factories, electric power plants, and amusement rides are covered by this exception.

 

• Common use circulation paths within exterior employee work areas that are fully exposed to the weather are exempt.  Farms, ranches, and outdoor maintenance facilities are covered by this exception.

 

The final revised guidelines also contain exceptions to the technical requirements for accessible routes:

 

• Machinery and equipment are permitted to reduce the clear width of common use circulation paths where it is essential to the function of the work performed.  Machinery and equipment that must be placed a certain way to work properly, or for ergonomics or to prevent workplace injuries are covered by this exception.

 

• Handrails are not required on ramps, provided they can be added in the future.

 

The model building codes and fire and life safety codes, which are adopted by all the States, require circulation paths in facilities, including employee work areas, to be at least 36 inches wide for purposes of emergency egress.[98]  Accessible routes are generally at least 36 inches wide. 

 

Because of the exceptions that exempt common use circulation paths in employee work areas where it may be difficult to comply with the technical requirements for accessible routes due to the size or function of the area, and because the model building codes and fire and life safety codes, which are adopted by all the States, require circulation paths in facilities, including employee work areas, to be at least 36 inches wide for purposes of emergency egress, the revision is expected to have minimal impacts.

 

6.3  Location of Accessible Routes

 

Table 6.3 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for the location of accessible routes. 

 

Table 6.3 – Interior Accessible Routes (text version)

Current Guidelines	Final Revised Guidelines
4.3.2  Location.   (1) At least one accessible route within the boundary of the site shall be provided from public transportation stops, accessible parking and accessible passenger loading zones, and public streets or sidewalks to the accessible building entrance they serve.  The accessible route shall, to the maximum extent feasible, coincide with the route for the general public.	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.
Model Codes & Standards
IBC 2000:  Section 1104.5 has an equivalent requirement for location of accessible routes.   IBC 2003:  Section 1104.5 has an equivalent requirement for location of accessible routes.

 

The current guidelines require accessible routes connecting site arrival points and accessible building entrances to coincide with general circulation paths, to the maximum extent feasible.  The final revised guidelines require all accessible routes to coincide with or be located in the same general area as general circulation paths.  The revision will have no impacts on exterior accessible routes since the requirements in the current guidelines and the final revised guidelines are basically the same.  Designing interior accessible routes to coincide with or to be located in the same area as general circulation path will not typically present a difficult design challenge and is expected to have minimal impacts.

 

The final revised guidelines also require accessible routes to be located in the interior of the facility, where general circulation paths are located in the interior of the facility.  The revision affects a limited number of buildings.  For example, under the current guidelines, a two-story building that is constructed into a hill, has an interior stairway connecting the stories, and is not exempt from providing an accessible route between the stories could provide entrances to each story of the building and connect the entrances with an exterior accessible route.[99] The final revised guidelines would require an elevator to be provided since there is an interior stairway.  The revision is expected to have minimal impacts since the cost of providing an elevator would be about the same as constructing an exterior accessible route around the building. 

6.4  Public Entrances

 

Table 6.4 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for public entrances. 

 

Table 6.4 – Public Entrances (text version)

Current Guidelines	Final Revised Guidelines
4.1.3  Accessible Buildings: New Construction.  Accessible buildings and facilities shall meet the following minimum requirements: . . .   (8)  The requirements in (a) and (b) below shall be satisfied independently:   (a)(i) At least 50 percent of all public entrances (excluding those in (b) below)  shall comply with 4.14. . . .   (ii)  Accessible public entrances must be provided in a number at least equivalent to the number of exits required by the applicable building or fire codes.  (This paragraph does not require an increase in the total number of public entrances planned for a facility.) . . .   4.1.6 Accessible Buildings: Alterations.   (1) General.  Alterations to existing buildings and facilities shall comply with the following: . . .   (h)  Entrances.  If a planned alteration entails alterations to an entrance, and the building has an accessible entrance, the entrance being altered is not required to comply with  4.1.3(8), except to the extent required by 4.1.6(2). . . .	206.4 Entrances.  Entrances shall be provided in accordance with 206.4. . . . Exceptions:  1.  Where an alteration includes alterations to an entrance, and the building or facility has another entrance complying with 404 that is on an accessible route, the altered entrance shall not be required to comply with 206.4 unless required by 202.4. . . .   206.4.1 Public Entrances.  In addition to entrances required by 206.4.2 through 206.4.9, at least 60 percent of all public entrances shall comply with 404.
Model Codes & Standards
IBC 2000:  Section 1105.1 has a similar requirement for the number of accessible public entrances.    IBC 2003:  Section 1105.1 has a similar requirement for the number of accessible public entrances.

 

The current guidelines require at least 50 percent of public entrances to be accessible.  In addition, the current guidelines require the number of accessible public entrances to be equivalent to the number of exits required by applicable building and fire codes.  Building and fire codes typically require at least two exits to be provided from a facility.  Thus, under the current guidelines where two public entrances are planned in a newly constructed facility, both entrances must be accessible. 

 

Instead of requiring at least 50 percent of public entrances plus a number equal to the number of required exits to be made accessible, the final revised guidelines require at least 60 percent of public entrances to be made accessible.[100]  The revision is intended to achieve the same result as the current guidelines.  Thus, under the final revised guidelines where two public entrances are planned in a newly constructed facility, both entrances must be accessible.

 

Where multiple public entrances are planned to serve different site arrival points, the current guidelines and the final revised guidelines require at least one accessible route to be provided from each site arrival point, including accessible parking spaces, accessible passenger loading zones, public streets and sidewalks, and public transportation stops, to an accessible public entrance that serves the site arrival point.[101]  Thus, the accessible route requirements will typically result in more than 50 percent of the public entrances being accessible.  Requiring at least 60 percent of public entrances to be accessible is not expected to result in a substantial increase in the number of accessible entrances compared to the current guidelines. 

 

On a site with little change in elevation, providing an accessible route to an accessible entrance requires providing a walking surface with a running slope not steeper than 1:20.[102]  On a site with a moderate change in elevation, providing an accessible route to an accessible entrance requires providing a ramp with a running slope not steeper than 1:12 along all or part of the accessible route.[103]  On a site with extreme changes in elevation, providing an accessible route to an accessible entrance may require adjusting the planned location of an accessible entrance to minimize the amount of ramping, or an elevator or platform lift may be a design solution in rare cases.  Where extreme changes in elevation or other site constraints make it too difficult or too costly to make additional public entrances accessible, the likely design solution will be to eliminate redundant public entrances.

 

The current guidelines and the final revised guidelines contain exceptions that limit the number of accessible entrances required in alterations to existing facilities.  When entrances in an existing facility are altered and the facility has an accessible entrance, the entrance being altered is not required to be accessible, unless a primary function area is also altered and then an accessible path of travel must be provided to the primary function area to the extent the cost is not disproportionate.[104]

6.5  Direct Access Entrances from Parking Structures

 

Table 6.5 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for direct access entrances from parking structures. 

 

Table 6.5 – Direct Access Entrances From Parking Structures (text version)

Current Guidelines	Final Revised Guidelines
4.1.3  Accessible Buildings: New Construction.  Accessible buildings and facilities shall meet the following minimum requirements: . . .   (8)(b)(i)  In addition, if direct access is provided for pedestrians from an enclosed parking garage to the building, at least one direct entrance from the garage to the building must be accessible. . . .	206.4.2 Parking Structure Entrances.  Where direct access is provided for pedestrians from a parking structure to a building or facility entrance, each direct access to the building or facility entrance shall comply with 404.
Model Codes & Standards
IBC 2000:  Section 1105.2 has a similar requirement for the number of accessible direct access entrances from parking structures.   IBC 2003:  Section 1105.1.1 has an equivalent requirement for the number of accessible direct access entrances from parking structures.

 

Where levels in a parking garage have direct connections for pedestrians to another facility, the current guidelines require at least one of the direct connections to be accessible.  The final revised guidelines require all of the direct connections to be accessible.  The vertical distances between the levels in a parking garage are typically less than the vertical distances between the stories in the facility to which it is connected so that not every level of the parking garage has a direct connection to a story in the facility.  For example, a parking garage with five levels may have direct connections to only two or three stories of another facility.  Making the direct connections between the parking garage and another facility accessible will not typically present a difficult design challenge and is expected to have minimal impacts.

6.6  Alterations to Existing Elevators

 

Table 6.6 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for alterations to existing elevators. 

 

Table 6.6 – Alterations to Existing Elevators (text version)

Current Guidelines	Final Revised Guidelines
4.1.6  Accessible Buildings: Alterations.   (1)  General.  Alterations to existing buildings and facilities shall comply with the following: . . .   (b)  If existing elements, spaces, or common areas are altered, then each such altered element, space, feature, or area shall comply with the applicable provisions of 4.1.1 to 4.1.3 Minimum Requirements (for New Construction). . . .	206.6.1 Existing Elevators.  Where elements of existing elevators are altered, the same element shall also be altered in all elevators that are programmed to respond to the same hall call control as the altered elevator and shall comply with the requirements of 407 for the altered element.
Model Codes & Standards
IBC 2000:  Section 3408.7.1 has an equivalent requirement for alterations to existing elevators.   IBC 2003:  Section 3409.7.2 has an equivalent requirement for alterations to existing elevators.

 

When a single space or element is altered, the current guidelines require the space or element to be made accessible.  When an element in one elevator is altered, the final revised guidelines require the same element to be altered in all elevators that are programmed to respond to the same call button as the altered elevator to ensure that when an individual with a disability presses a call button, an accessible elevator will arrive, and not an inaccessible one. 

 

The revision is expected to have minimal impacts since all the elevators in a bank are typically upgraded at the same time when elevators are altered as part of a planned modernization project.  The final revised guidelines also contain exceptions to the technical requirements for elevators when existing elevators are altered that further minimize the impacts of the revision:

 

• Existing elevators are permitted to have recessed call buttons.[105]

 

• Existing call buttons and keypads are permitted to be located at 54 inches above the finish floor, measured to the centerline of the highest operable part.[106]

 

• Existing call buttons are not required to be ¾ inch minimum in the smallest dimension.[107]

 

• Existing call buttons are not required to have visible signals to indicate when each call is registered and when each call is answered.[108]

 

• A visible and audible hall signal is not required to be provided at the hoistway entrance of existing elevators to indicate the direction of car travel.[109]

 

• Existing visible hall signals are not required to be centered at 72 inches minimum above the finish floor and 2 ½ inches minimum measured along the centerline of the element.[110]

 

• Existing hall signals are not required to meet the requirements for frequency and range of audible signals.[111]

 

• Existing manually operated hoistway swing doors are permitted if the door opening provides a clear width of 32 inches minimum, and the force for pushing or pulling open the door is 5 pounds maximum.[112]

 

• Existing manually operated doors are not required to provide a reopening device that automatically stops and reopens the car door and hoistway door if the doors are obstructed by an object or a person.[113]

 

• A power operated car door with a door opening that provides a clear width of 32 inches minimum is permitted in an existing elevator.[114]

 

• Existing elevator car configurations that provide a clear floor area of 16 square feet, and provide 54 inches minimum inside clear depth and 36 inches minimum clear width are permitted.[115]

 

• Where a new car operating panel with accessible elevator car controls and tactile markings is provided in an existing elevator, existing car operating panels are not required to be made accessible.[116]

 

• Existing car control buttons with floor designations are permitted to be located 54 inches maximum above the finish floor where a parallel approach is provided.[117]

 

• Existing car control buttons with floor designations are permitted to be recessed.[118]

 

• Where space on an existing car operating panel precludes the placement of tactile markings immediately to the left of the control button, the markings are permitted to placed as near to the control button as possible.[119]

 

6.7  Accessible Means of Egress

 

Table 6.7 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for accessible means of egress. 

 

Table 6.7 – Accessible Means of Egress (text version)

Current Guidelines	Final Revised Guidelines
4.1.3  Accessible Buildings: New Construction.  Accessible buildings and facilities shall meet the following minimum requirements: . . .   (9)  In buildings or facilities, or portions of buildings or facilities, required to be accessible, accessible means of egress shall be provided in the same number as required for exits by local building/life safety regulations.  Where a required exit from an occupiable level above or below a level of accessible exit discharge is not accessible, an area of rescue assistance shall be provided on each such level (in a number equal to that of inaccessible required exits).  Areas of rescue assistance shall comply with 4.3.11.  A horizontal exit meeting the requirements of local building/life safety regulations, shall satisfy the requirement for an area of rescue assistance. Exception: Areas of rescue assistance are not required in buildings or facilities having a supervised automatic sprinkler system.   (16)  Building Signage. . . .   (b)  Other signs which provide direction to or information about functional spaces of the building shall comply with 4.30.1, 4.30.4, 4.30.5, and 4.30.6. . . .   4.1.6  Accessible Buildings: Alterations.   (1)  General.  Alterations to existing buildings and facilities shall comply with the following: . . .   (g)  In alterations, the requirements of 4.1.3(9) . . . do not apply.   4.3.10  Egress.  Accessible routes serving any accessible space or element shall also serve as a means of egress for emergencies or connect to an accessible area of rescue assistance.	207.1  General.  Means of egress shall comply with section 1003.2.13 of the International Building Code (2000 edition and 2001 Supplement) or section 1007 of the International Building Code (2003 edition)  (incorporated by reference, see “Referenced Standards” in Chapter 1). Exceptions:  1.  Where means of egress are permitted by local building or life safety codes to share a common path of egress travel, accessible means of egress shall be permitted to share a common path of egress travel. . . .   216.4  Means of Egress.  Signs for means of egress shall comply with 216.4.   216.4.1  Exit Doors.  Doors at exit passageways, exit discharge, and exit stairways shall be identified by tactile signs complying with 703.1, 703.2, and 703.5.   216.4.2  Areas of Refuge.  Signs required by section 1003.2.13.5.4 of the International Building Code (2000 edition) or section 1007.6.4 of the International Building Code (2003 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1) to provide instructions in areas of refuge shall comply with 703.5.   216.4.3  Directional Signs.  Signs required by section 1003.2.13.6 of the International Building Code (2000 edition) or section 1007.7 of the International Building Code (2003 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1) to provide directions to accessible means of egress shall comply with 703.5
Model Codes & Standards
IBC 2000:  Section 1003.2.13 has equivalent requirements for accessible means of egress.   IBC 2003:  Section 1007 has equivalent requirements for accessible means of egress.

 

The current guidelines establish scoping and technical requirements for accessible means of egress.  The final revised guidelines reference the International Building Code for scoping and technical requirements for accessible means of egress. 

 

The current guidelines require the same number of accessible means of egress to be provided as the number of exits required by applicable building and fire codes.  The International Building Code requires at least one accessible means of egress; and at least two accessible means of egress, where more than one means of egress is required by other sections of the code.  The revision is expected to have minimal impacts since the model fire and life safety codes, which are adopted by all the States, contain equivalent requirements with respect to the number of accessible means of egress.[120]

 

The current guidelines require areas of rescue assistance or horizontal exits in facilities with stories above or below the exit discharge level.  Areas of rescue assistance are spaces, which have direct access to an exit, where individuals who are unable to use stairs can go to register a call for assistance and wait for evacuation.  The International Building Code requires an evacuation elevator designed with standby power and other safety features that can be used for emergency evacuation of individuals with disabilities in facilities with four or more stories above or below the exit discharge level, and allows exit stairways and evacuation elevators to be used as an accessible means of egress in conjunction with areas of refuge or horizontal exits.  The revision is expected to have minimal impacts since the model fire and life safety codes contain equivalent requirements with respect to evacuation elevators.[121]

 

The current guidelines exempt facilities equipped with a supervised automatic sprinkler system from providing areas of rescue assistance, and also exempt alterations to existing facilities from providing an accessible means of egress.  The International Building Code exempts buildings equipped with a supervised automatic sprinkler system from certain technical requirements for areas of refuge, and also exempts alterations to existing facilities from providing an accessible means of egress. 

 

The current guidelines require signs which provide direction to or information about functional spaces to meet certain technical requirements.  Signs used for means of egress are covered by this scoping requirement.  The final revised guidelines specifically identify signs used for means of egress and require the signs to meet certain technical requirements. 

 

6.8  Passenger Loading Zones

 

Table 6.8 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for passenger loading zones. 

 

Table 6.8 – Passenger Loading Zones (text version)

Current Guidelines	Final Revised Guidelines
4.1.2  Accessible Sites and Exterior Facilities:  New Construction.  An accessible site shall meet the following minimum requirements: . . .   (5) . . . (c)  If passenger loading zones are provided, then at least one passenger loading zone shall comply with 4.6.   4.6.6  Passenger Loading Zones.  Passenger loading zones shall provide an access aisle at least 60 in (1525 mm) wide and 20 ft (240 in) (6100 mm) long adjacent and parallel to the vehicle pull-up space (see Fig. 10).  If there are curbs between the access aisle and the vehicle pull-up space, then a curb ramp complying with 4.7 shall be provided.  Vehicle standing spaces and access aisles shall be level with surface slopes not exceeding 1:50 (2%) in all directions.	209.2.1 Passenger Loading Zones.  Passenger loading zones, except those required to comply with 209.2.2 and 209.2.3, shall provide at least one passenger loading zone complying with 503 in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof.   503.2  Vehicle Pull-Up Space.  Passenger loading zones shall provide a vehicular pull-up space 96 inches (2440 mm) wide minimum and 20 feet (6100 mm) long minimum.   503.3  Access Aisle.  Passenger loading zones shall provide access aisles complying with 503.3 adjacent to the vehicle pull-up space.  Access aisles shall adjoin an accessible route and shall not overlap the vehicular way.   503.3.1  Width.  Access aisles serving vehicle pull-up spaces shall be 60 inches (1525 mm) wide minimum.   503.3.2  Length.  Access aisles shall extend the full length of the vehicle pull-up spaces they serve.   503.3.3 Marking.  Access aisles shall be marked so as to discourage parking in them.   503.4  Floor and Ground Surfaces.  Vehicle pull-up spaces and access aisles serving them shall comply with 302.  Access aisles shall be at the same level as the vehicle pull-up space they serve.  Changes in level are not permitted. Exception: Slopes not steeper than 1:48 shall be permitted.
Model Codes & Standards
IBC 2000:  Section 1106.6 has a similar requirement for passenger loading zones.   IBC 2003:  Sections 1106.7.1 and 1106.7.2 have equivalent requirements for passenger loading zones.   ICC/ANSI A117.1-1998:  Sections 503.3 and 503.4 have equivalent requirements for vehicle pull-up spaces, access aisles, and floor and ground surfaces.

 

Where passenger loading zones are provided, the current guidelines require at least one passenger loading zone to be accessible.  The final revised guidelines require facilities such as airport passenger terminals that have long, continuous passenger loading zones to provide one accessible passenger loading zone in every continuous 100 linear feet of loading zone space.  The final revised guidelines include technical requirements for the vehicle pull-up space (96 inches wide minimum and 20 feet long minimum).  Accessible passenger loading zones must have an access aisle that is 60 inches wide minimum and extends the full length of the vehicle pull-up space.  Under the current guidelines, the access aisle may be on the same level as the vehicle pull-up space, or on the sidewalk with a curb ramp.  The final revised guidelines require the access aisle to be on the same level as the vehicle pull-up space and to be marked so as to discourage parking in the access aisle.

 

The revision is expected to have minimal impacts since the overall width of the vehicular way or the pedestrian way does not have to be increased to provide an access aisle.  If the sidewalk is wide, the sidewalk can be narrowed 5 feet where the access aisle is provided.  If the sidewalk is narrow, the sidewalk can be depressed where the access aisle is provided.

 

6.9  Valet Parking and Mechanical Access Parking Garages

 

Table 6.9 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for parking facilities that provide valet parking services and for mechanical access parking garages. 

 

Table 6.9 – Valet Parking and Mechanical Access Parking Garages (text version)

Current Guidelines	Final Revised Guidelines
4.1.2  Accessible Sites and Exterior Facilities: New Construction.  An accessible site shall meet the following minimum requirements: . . .   (5)(a)  If parking spaces are provided for self-parking by employees or visitors, or both, then accessible parking spaces complying with 4.6 shall be provided in each such parking area in conformance with the table below.  . . .   (e)  Valet Parking.  Valet parking facilities shall provide a passenger loading zone complying with 4.6 located on an accessible route to the entrance of the facility.  Paragraphs 5(a), 5(b), and  5(d) of this section do not apply to valet parking facilities.	208.2  Minimum Number.  Parking spaces complying with 502 shall be provided in accordance with Table 208.2, except as required by 208.2.1, 208.2.2, and 208.2.3. . . .   209.4  Valet Parking.  Parking facilities that provide valet parking services shall provide at least one passenger loading zone complying with 503.   209.5  Mechanical Access Parking Garages.  Mechanical access parking garages shall provide at least one passenger loading zone complying with 503 at vehicle drop-off and vehicle pick-up areas.
Model Codes & Standards
IBC 2000:  Sections 1106.1 and 1106.6.2 have equivalent requirements for valet parking facilities.   IBC 2003:  Sections 1106.1 and 1106.7.3 have equivalent requirements for valet parking facilities.

 

The current guidelines and the final revised guidelines require parking facilities that provide valet parking services to have an accessible passenger loading zone.  The final revised guidelines also require mechanical access parking garages to have an accessible passenger loading zone.[122]  The current guidelines contain an exception that exempts valet parking facilities from providing accessible parking spaces.  The final revised guidelines do not include the exception.  The revision is expected to have minimal impacts since the exception in the current guidelines applies to facilities that provide valet parking services exclusively and is rarely used. 

 

6.10     Stairs

 

Table 6.10 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for stairs. 

 

Table 6.10 – Stairs (text version)

Current Guidelines	Final Revised Guidelines
4.1.3  Accessible Buildings: New Construction.  Accessible buildings and facilities shall meet the following minimum requirements: . . .    (4)  Interior and exterior stairs connecting levels that are not connected by an elevator, ramp, or other accessible means of vertical access shall comply with 4.9.   4.9.2  Treads and Risers.  On any given flight of stairs, all steps shall have uniform riser heights and uniform tread widths.  Stair treads shall be no less than 11 in (280 mm) wide, measured from riser to riser (see Fig. 18(a)).  . . .	210.1 General.  Interior and exterior stairs that are part of a means of egress shall comply with 504. Exceptions: . . . 2.  In alterations, stairs between levels that are connected by an accessible route shall not be required to comply with 504 except that handrails complying with 505 shall be provided when the stairs are altered. . . .   504.2 Treads and Risers.  All steps on a flight of stairs shall have uniform riser heights and uniform tread depths.  Risers shall be 4 inches (100 mm) high minimum and 7 inches (180 mm) high maximum.  Treads shall be 11 inches (280 mm) deep minimum.
Model Codes & Standards
IBC 2000:  Sections 1003.3.3.3 and 1003.3.3.3.1 have equivalent requirements for stairs that are part of a means of egress.    IBC 2003:  Sections 1009.3 and 1009.3.1 have equivalent requirements for stairs that are part of a means of egress.   ICC/ANSI A117.1-1998:  Section 504.2 has equivalent requirements for treads and risers.

 

The current guidelines require stairs serving levels that are not connected by an accessible route to comply with the technical requirements for stairs.  The final revised guidelines require stairs that are part of a means of egress to comply with the technical requirements for stairs, including treads and risers.  The current guidelines and the final revised guidelines require uniform riser heights and tread depths.  The current guidelines do not specify a riser height.  The final revised guidelines specify a riser height of 4 inches minimum and 7 inches maximum.  Both the current guidelines and the final revised guidelines specify a tread depth of 11 inches minimum.  The revision is expected to have minimal impacts since 7 inch maximum risers and 11 inch minimum treads (“7/11” stairs) are widely accepted as the standard for stairs.[123]   

 

The final revised guidelines include an exception for alterations to existing facilities that exempt stairs serving levels that are connected by an accessible route from the requirements for uniform treads and risers.

6.11     Drinking Fountains

 

Table 6.11 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for drinking fountains. 

 

Table 6.11 – Drinking Fountains (text version)

Current Guidelines	Final Revised Guidelines
4.1.3  Accessible Buildings:  New Construction.  Accessible buildings and facilities shall meet the following minimum requirements: . . .    (10)  Drinking Fountains.   (a)  Where only one drinking fountain is provided on a floor there shall be a drinking fountain that is accessible to individuals who use wheelchairs in accordance with 4.15 and one accessible to those who have difficulty bending or stooping. . . .   (b)  Where more than one drinking fountain or water cooler is provided on a floor, 50 percent of those provided shall comply with 4.15 . . . .   4.15.2  Spout Height.  Spouts shall be no higher than 36 in (915 mm), measured from the floor or ground surfaces to the spout outlet (see Fig. 27 (a)).   4.15.5  Clearances.   (1)  Wall and post-mounted cantilevered units shall have a clear knee space between the bottom of the apron and the floor or ground at least 27 in (685 mm) high, 30 in (760 mm) wide, and 17 in to 19 in (430 mm to 485 mm) deep (see Fig. 27 (a) and (b)).  Such units shall also have a minimum clear floor space 30 in by 48 in (760 mm by 1220 mm) to allow a person in a wheelchair to approach the unit facing forward. Exception:  These clearances shall not be required at units used primarily by children ages 12 and younger where clear floor space for a parallel approach complying with 4.2.4 is provided and where the spout is no higher than 30 in (760 mm), measured from the floor or ground surface to the spout outlet.   (2)  Free-standing or built-in units not having a clear  space under them shall have a clear floor space at least 30 in by 48 in (760 mm by 1220 mm) that allows a person in a wheelchair to make a parallel approach to the unit (see Fig. 27 (c) and (d)).  This clear floor space shall comply with 4.2.4.	211.1 General.  Where drinking fountains are provided on an exterior site, on a floor, or within a secured area they shall be provided in accordance with 211. . . .   211.2 Minimum Number.  No fewer than two drinking fountains shall be provided.  One drinking fountain shall comply with 602.1 through 602.6 and one drinking fountain shall comply with 602.7. Exception:  Where a single drinking fountain complies with 602.1 through 602.6 and 602.7, it shall be permitted to be substituted for two separate drinking fountains.   211.3 More Than Minimum Number.  Where more than the minimum number of drinking fountains specified in 211.2 are provided, 50 percent of the total number of drinking fountains provided shall comply with 602.1 through 602.6, and 50 percent of the total number of drinking fountains provided shall comply with 602.7. Exception:  Where 50 percent of the drinking fountains yields a fraction, 50 percent shall be permitted to be rounded up or down provided that the total number of drinking fountains complying with 211 equals 100 percent of drinking fountains.   602.2 Clear Floor Space.  Units shall have a clear floor or ground clearance complying with 305 positioned for a forward approach and centered on the unit.  Knee and toe clearance complying with 306 shall be provided. Exception:  A parallel approach complying with 305 shall be permitted at units for children's use where the spout is 30 inches (760 mm) maximum above the finish floor or ground and is 3½ inches (90 mm) maximum from the front edge of the unit, including bumpers.   602.4  Spout Height.  Spout outlets shall be 36 inches (915 mm) maximum above the finish floor or ground.   602.7  Drinking Fountains for Standing Persons.  Spout outlets for drinking fountains for standing persons shall be 38 inches (965 mm) minimum and 43 inches (1090 m) maximum above the finish floor or ground.
Model Codes & Standards
IBC 2000:  Section 1108.5 has a similar requirement for the number of accessible drinking fountains.   IBC 2003:  Section 1109.5 has a similar requirement for the number of accessible drinking fountains.   ICC/ANSI A117.1-1998:  Section 602.2 has a similar requirement for clear floor space at drinking fountains.

 

The current guidelines and the final revised guidelines require drinking fountains to be provided at a wheelchair height and at a standing height.  The current guidelines require wall and post-mounted cantilevered drinking fountains mounted at a wheelchair height to provide clear floor space for a forward approach with knee and toe clearance, and free-standing or built-in drinking fountains to provide clear floor space for a parallel approach.  The final revised guidelines require drinking fountains mounted at a wheelchair height to provide clear floor space for a forward approach with knee and toe clearance, and include an exception for a parallel approach for drinking fountains used by children. The final revised guidelines also include a technical requirement for drinking fountains for standing persons.  The revision is expected to have minimal impacts since drinking fountains mounted at a wheelchair height that provide clear floor space for a forward approach with knee and toe clearance are common in new construction, and generally cost less than other types of drinking fountains. 

6.12     Sinks

 

Table 6.12 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for sinks.

 

Table 6.12 – Sinks (text version)

Current Guidelines	Final Revised Guidelines
4.1.1  Application.   (1)  General.  All areas of newly designed or newly constructed buildings and facilities and altered portions of existing buildings and facilities shall comply with section 4, unless otherwise provided in this section or as modified in a special application section.   4.24.1  General.  Sinks required to be accessible by 4.1 shall comply with 4.24.   4.24.3  Knee Clearance.  Knee clearance that is at least 27 in (685 mm) high, 30 in (760 mm) wide, and 19 in (485 mm) deep shall be provided underneath sinks.   4.24.5 Clear Floor Space.  A clear floor space at least 30 in by 48 in (760 mm by 1220 mm) complying with 4.2.4 shall be provided in front of a sink to allow forward approach.  The clear floor space shall be on an accessible route and shall extend a maximum of 19 in (485 mm) underneath the sink (see Fig. 32).   9.2.2  Minimum Requirements.  An accessible unit, sleeping room or suite shall be on an accessible route complying with 4.3 and have the following accessible elements and spaces. . . .   (7)  Kitchens, Kitchenettes, or Wet Bars.  When provided as an accessory to a sleeping room or suite, kitchens, kitchenettes, wet bars, or similar amenities shall be accessible. Clear floor space for a front or parallel approach to cabinets, counters, sinks, and appliances shall be provided to comply with 4.2.4. . . .	212.3 Sinks.  Where sinks are provided, at least 5 percent, but no fewer than one, of each type provided in each accessible room or space shall comply with 606. Exception:  Mop or service sinks shall not be required to comply with 212.3.   606.2 Clear Floor Space.  A clear floor space complying with 305, positioned for a forward approach, and knee and toe clearance complying with 306 shall be provided. Exceptions:  1.  A parallel approach complying with 305 shall be permitted to a kitchen sink in a space where a cook top or conventional range is not provided and to wet bars.  . . .
Model Codes & Standards
IBC 2000:  Section 1108.3 has an equivalent requirement for sinks.   IBC 2003:  Section 1109.3 has an equivalent requirement for sinks.   ICC/ANSI A117.1-1998:  Section 606.2 has an equivalent requirement for clear floor space at sinks and an equivalent exception for sinks without a cook top or conventional range.

 

 

The current guidelines contain technical requirements for sinks, but do not have specific scoping requirements for sinks in all accessible spaces.[124]  The final revised guidelines require at least 5 percent of sinks in each accessible space to comply with the technical requirements for sinks.  The technical requirements address clear floor space, height, faucets, and exposed pipes and surfaces.  The current guidelines and the final revised guidelines require the clear floor space at sinks to be positioned for a forward approach, and knee and toe clearance to be provided under the sink.  The current guidelines allow the clear floor space at kitchen sinks and wet bars in hotel guest rooms with mobility features to be positioned for either a forward approach with knee and toe clearance, or for a parallel approach because the rooms usually do not have cooking facilities.  The final revised guidelines include a broader exception that permits the clear floor space to be positioned for a parallel approach at kitchen sinks in any space where a cook top or conventional range is not provided, and at a wet bar.

 

The revision is expected to have minimal impacts since the base cabinet under kitchen sinks is usually eliminated to provide knee and toe clearance under the sink when the clear floor space is positioned for a forward approach, which offsets the cost for the lowered sink counter height and the pipe insulation. 

6.13     Public Telephone Volume Controls[125]

 

Table 6.13 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for public telephone volume controls. 

 

Table 6.13 – Public Telephone Volume Controls (text version)

Current Guidelines	Final Revised Guidelines
4.1.3  Accessible Buildings: New Construction.  Accessible buildings and facilities shall meet the following minimum requirements: . . .    (17)  Public Telephones. . . .   (b)  All telephones required to be accessible and complying with 4.31.2 through 4.32.8 shall be equipped with a volume control.  In addition, 25 percent, but never less than one, of all other public telephones provided shall be equipped with a volume control . . . .   4.30.7 Symbols of Accessibility. . . .   (2)  Volume Control Telephones.  Telephones required to have a volume control by 4.1.3 (17) (b) shall be identified by a sign containing a depiction of a telephone handset with radiating sound waves.   4.31.5  Hearing Aid Compatible and Volume Control Telephones Required by 4.1. . . .   (2)  Volume controls capable of a minimum of 12 dba and a maximum of 18 dba above normal, shall be provided in accordance with 4.1.3.  If an automatic reset is provided then 18 dba may be exceeded.	217.3  Volume Controls.  All public telephones shall have volume controls complying with 704.3.   704.3  Volume Control Telephones.  Public telephones required to have 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.
Model Codes & Standards
IBC 2000:  Section E1106.3 of Appendix E has a similar requirement for public telephones with volume controls.   IBC 2003:  Section E106.3 of Appendix E has an equivalent requirement for public telephones with volume controls.   ICC/ANSI A117.1-1998:  Section 704.3 has an equivalent requirement for level of volume control.

 

The current guidelines require all wheelchair accessible public telephones and 25 percent of all other public telephones to have volume controls, and to be identified by signs.  The final revised guidelines require all public telephones to have volume controls, and delete the requirement for identifying signs.  The current guidelines require volume control telephones to provide a minimum gain of 12 dB and a maximum gain of 18 dB.  The final revised guidelines require a gain up to 20 dB minimum and an automatic reset. 

 

The revision is expected to have minimal impacts since the scoping and technical requirements in the final revised guidelines are consistent with guidelines and standards issued by the Access Board under section 255 of the Telecommunications Act of 1998 and section 508 of the Rehabilitation Act, which require all new telephones to have volume controls.[126] 

6.14     Dispersion of Wheelchair Spaces and Lines of Sight in Assembly Areas[127]

 

Table 6.14 shows the relevant text of the current guidelines and the final revisions to the guidelines with respect to the scoping and technical requirements for dispersion of wheelchair spaces and lines of sight in assembly areas. 

 

Table 6.14 – Dispersion of Wheelchair Spaces and Lines of Sight in Assembly Areas (text version)

Current Guidelines	Final Revised Guidelines
4.33.3  Placement of Wheelchair Locations.  Wheelchair areas shall be an integral part of any fixed seating plan and shall be provided so as to provide people with physical disabilities a choice of admission prices and lines of sight comparable to those for members of the general public.  They shall adjoin an accessible route that also serves as a means of egress in case of emergency. . . When the seating capacity exceeds 300, wheelchair spaces shall be provided in more than one location. . . . Exception:  Accessible viewing positions may  be clustered for bleachers, balconies, and other areas having sight lines that require slopes greater than 5 percent.  Equivalent accessible viewing positions may be located on levels having accessible egress.	221.2.2  Integration.  Wheelchair spaces shall be an integral part of the seating plan.   221.2.3  Lines of Sight and Dispersion.  Wheelchair spaces shall provide lines of sight complying with 802.2 and shall comply with 221.2.3.  In providing lines of sight, wheelchair spaces shall be dispersed.  Wheelchair spaces shall provide spectators with choices of seating locations and viewing angles that are substantially equivalent to, or better than, the choices of seating locations and viewing angles available to all other spectators.  When the number of wheelchair spaces required by 221.2.1 has been meet, further dispersion shall not be required. . . .   221.2.3.1  Horizontal Dispersion.  Wheelchair spaces shall be dispersed horizontally.  Exceptions:  1.  Horizontal dispersion shall not be required in assembly areas with 300 or fewer seats if  companion seats required by 221.3 and wheelchair spaces are located within the 2nd or 3rd quartile of the total row length.  Intermediate aisles shall be included in determining the total row length.  If the row length in the 2nd and 3rd quartile of a row is insufficient to accommodate the required number of companion seats and wheelchair spaces, the additional companion seats and wheelchair spaces shall be permitted to be located in the 1st and 4th quartile of the row. 2.  In row seating, two wheelchair spaces shall be permitted to be located side-by-side.   221.2.3.2  Vertical Dispersion.  Wheelchair spaces shall be dispersed vertically at varying distances from the screen, performance area, or playing field.  In addition, wheelchair spaces shall be located in each balcony or mezzanine that is located on an accessible route. Exceptions:  1.  Vertical dispersion shall not be required in assembly areas with 300 or fewer seats if wheelchair spaces provide viewing angles that are equivalent to, or better than, the average viewing angle provided in the facility. 2.  In bleachers, wheelchair spaces shall not be required to be provided in rows other than rows at points of entry to bleacher seating.   802.2 Lines of Sight.  Lines of sight to the screen, performance area, or playing field for spectators in wheelchair spaces shall comply with 802.2.   802.2.1 Lines of Sight Over Seated Spectators.  Where spectators are expected to remain seated during events, spectators in wheelchair spaces shall be afforded lines of sight complying with 802.2.1.   802.2.1.1 Lines of Sight Over Heads.  Where spectators are provided lines of sight over the heads of spectators seated in the first row in front of their seats, spectators seated in wheelchair spaces shall be afforded lines of sight over the heads of seated spectators in the first row in front of wheelchair spaces.   802.2.1.2 Lines of Sight Between Heads.  Where spectators are provided lines of sight over the shoulders and between the heads of spectators seated in the first row in front of their seats, spectators seated in wheelchair spaces shall be afforded lines of sight over the shoulders and between the heads of seated spectators in the first row in front of wheelchair spaces.   802.2.2 Lines of Sight Over Standing Spectators.  Where spectators are expected to stand during events, spectators in wheelchair spaces shall be afforded lines of sight complying with 802.2.2.   802.2.2.1 Lines of Sight Over Heads.  Where standing spectators are provided lines of sight over the heads of spectators standing in the first row in front of their seats, spectators seated in wheelchair spaces shall be afforded lines of sight over the heads of standing spectators in the first row in front of wheelchair spaces.   802.2.2.2 Lines of Sight Between Heads.  Where standing spectators are provided lines of sight over the shoulders and between the heads of spectators standing in the first row in front of their seats, spectators seated in wheelchair spaces shall be afforded lines of sight over the shoulders and between the heads of standing spectators in the first row in front of wheelchair spaces.
Model Codes & Standards
IBC 2000:  Section 1107.2.3 has similar requirements for dispersion of wheelchair spaces.   IBC 2003:  Section 1108.2.4 has similar requirements for dispersion of wheelchair spaces.   ICC/ANSI A117.1-1998:  Section 802.8 has similar requirements for lines of sight.

 

The current guidelines require wheelchair spaces to be an integral part of any fixed seating plan in assembly areas and to be dispersed, when the seating capacity exceeds 300.  The current guidelines also require wheelchair spaces to provide individuals with disabilities lines of sight comparable to the sightlines available to other spectators in assembly areas.  The Department of Justice, which adopted the current guidelines as enforceable standards, interprets comparable sightlines as requiring wheelchair spaces in sports stadiums and arenas to provide lines of sight over standing spectators to the playing field, where spectators are expected to stand during events.[128]  The Department of Justice also interprets comparable sightlines as requiring wheelchair spaces in stadium-style movie theaters to provide viewing angles comparable to those provided to other spectators.[129] 

 

The final revised guidelines add specific technical requirements for providing sightlines over seated and standing spectators; and require wheelchair spaces to provide individuals with disabilities choices of seating locations and viewing angles that are substantially equivalent to, or better than, the choices of seating locations and viewing angles available to other spectators.  The final revised guidelines also clarify the dispersion requirements.  Wheelchair spaces must be dispersed horizontally and vertically.  The final revised guidelines include exceptions for assembly areas that have 300 or fewer seats, where the wheelchair spaces are located in the 2nd or 3rd quartile of the total row length and provide viewing angles that are equivalent to, or better than, the average viewing angle provided in the facility.  The revisions are expected to have minimal impacts since they are consistent with the Department of Justice’s interpretations of the current guidelines. 

 

The current guidelines contain an exception that permits wheelchair spaces to be clustered in steeply sloped bleachers and balconies.  The final revised guidelines require wheelchair spaces to be located at the entry points to bleachers, and in each balcony or mezzanine that is on an accessible route.

6.15     Lawn Seating in Assembly Areas

 

Table 6.15 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirement for lawn seating in assembly areas. 

 

Table 6.15 – Lawn Seating in Assembly Areas (text version)

Current Guidelines	Final Revised Guidelines
4.1.1  Application.   (1)  General.  All areas of newly designed or newly constructed buildings and facilities and altered portions of existing buildings and facilities shall comply with section 4, unless otherwise provided in this section or as modified in a special application section.	221.5 Lawn Seating.  Lawn seating areas and exterior overflow seating areas, where fixed seats are not provided, shall connect to an accessible route.
Model Codes & Standards
No requirements for lawn seating in assembly areas.

 

The current guidelines require all areas of newly constructed facilities to be accessible, but do not contain a specific scoping requirement for lawn seating in assembly areas.  The final revised guidelines specifically require lawn seating areas and exterior overflow seating areas without fixed seats to connect to an accessible route.  The revision is expected to have minimal impacts since the requirement can be met by locating an accessible route serving the fixed seating areas along a portion of the lawn seating area.  The accessible route does not have to extend through the lawn seating area. 

6.16     New Construction of Federal, State, and Local Government Housing

 

Table 6.16 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for new construction of Federal, State, and local government housing.  The current guidelines refer to UFAS.

 

Table 6.16 – New Construction of Federal, State, and Local Government Housing (text version)

Current Guidelines	Final Revised Guidelines
4.1.4  Occupancy Classifications.  Buildings and facilities shall comply with these standards to the extent noted in this section for various occupancy classifications, unless otherwise noted by a special application section. . . .   (11) Residential.  Residential occupancy includes, among others, the use of a building or structure, or portion thereof, for sleeping accommodations when not classed as an institutional occupancy.  Residential occupancies shall comply with the requirements of 4.1 and 4.34 except as follows: . . .   (b)  Residential occupancies in multiple dwellings where the occupants are primarily permanent in nature, including:   Facilities Multifamily housing (Apartment houses):     Application Federally assisted 5 percent of the total, or at least one unit, whichever is greater, in projects of 15 or more dwelling units . . . . Federally owned 5 percent of the total, or at least one unit, whichever is greater. Dormitories 5 percent of the total, or at least one unit, whichever is greater.   (c)  Residential occupancies in one (1) and two (2) family dwellings where the occupancies are primarily permanent in nature and not classified as preceding residential categories or as institutional.     Facilities One and two family dwelling:     Application Federally assisted, rental 5 percent of the total, or at least one unit, whichever is greater, in projects of 15 or more dwelling units . . . . Federally assisted, home ownership   To be determined by home buyer. Federally owned 5 percent of the total, or at least one unit, whichever is greater.	233.1 General.  Facilities with residential dwelling units shall comply with 233.   233.2 Residential Dwelling Units Provided by Entities Subject to HUD Section 504 Regulations.  Where facilities with residential dwelling units are provided by entities subject to regulations issued by the Department of Housing and Urban Development (HUD) under Section 504 of the Rehabilitation Act of 1973, as amended, such entities shall provide residential dwelling units with mobility features complying with 809.2 through 809.4 in a number required by the applicable HUD regulations.  Residential dwelling units required to provide mobility features complying with 809.2 through 809.4 shall be on an accessible route as required by 206.  In addition, such entities shall provide residential dwelling units with communication features complying with 809.5 in a number required by the applicable HUD regulations.  Entities subject to 233.2 shall not be required to comply with 233.3.   233.3 Residential Dwelling Units Provided by Entities Not Subject to HUD Section 504 Regulations.  Facilities with residential dwelling units provided by entities not subject to regulations issued by the Department of Housing and Urban Development (HUD) under Section 504 of the Rehabilitation Act of 1973, as amended, shall comply with 233.3.   233.3.1 Minimum Number: New Construction.  Newly constructed facilities with residential dwelling units shall comply with 233.3.1. Exception:  Where facilities contain 15 or fewer residential dwelling units, the requirements of 233.3.1.1 and 233.3.1.2 shall apply to the total number of residential dwelling units that are constructed under a single contract, or are developed as a whole, whether or not located on a common site.   233.3.1.1 Residential Dwelling Units with Mobility Features.  In facilities with residential dwelling units, at least 5 percent, but no fewer than one unit, of the total number of residential dwelling units shall provide mobility features complying with 809.2 through 809.4 and shall be on an accessible route as required by 206.   233.3.1.2 Residential Dwelling Units with Communication Features.  In facilities with residential dwelling units, at least 2 percent, but no fewer than one unit, of the total number of residential dwelling units shall provide communication features complying with 809.5.   233.3.2 Residential Dwelling Units for Sale.  Residential dwelling units offered for sale shall provide accessible features to the extent required by regulations issued by Federal agencies under the Americans with Disabilities Act or Section 504 of the Rehabilitation Act of 1973, as amended.
Model Codes & Standards
IBC 2000:  Section 1107.5.4 requires 2 percent of dwelling units in certain multi-family occupancies to comply with the requirements for Type A dwelling units in ICC/ANSI A117.1-1998.   IBC 2003:  Section 1107.6.2.1.1 requires 2 percent of dwelling units in certain multi-family occupancies to comply with the requirements for Type A dwelling units in ICC/ANSI A117.1-1998.

 

The current guidelines contain scoping requirements for the new construction of Federal, State, and local government housing required to comply with the Architectural Barriers Act and Americans with Disabilities Act.[130]  For federally owned housing, the current guidelines require 5 percent of newly constructed dwelling units to provide mobility features.  For federally assisted housing, the current guidelines require 5 percent of newly constructed dwelling units in projects of 15 or more dwelling units to provide mobility features.  The current guidelines do not define the term “project.”

 

The final revised guidelines differentiate between entities subject to the Department of Housing and Urban Development’s (HUD) regulations implementing section 504 of the Rehabilitation Act, and entities not subject to the HUD regulations.  The HUD regulations apply to recipients of Federal financial assistance through HUD, and require at least 5 percent of dwelling units in multi-family projects of five or more dwelling units to provide mobility features and at least 2 percent of the dwelling units to provide communication features.[131]  The HUD regulations define a project unique to its programs as “one or more residential structures . . . which are covered by a single contract for Federal financial assistance or application for assistance, or are treated as a whole for processing purposes, whether or not located on a common site.”[132]  To avoid any potential conflicts with the HUD regulations, the final revised guidelines require entities subject to the HUD regulations to comply with the scoping requirements in the HUD regulations, instead of the scoping requirements in the final revised guidelines.

 

For entities not subject to the HUD regulations, the final revised guidelines require at least 5 percent of the dwelling units in residential facilities to provide mobility features, and at least 2 percent of the dwelling units to provide communication features.  The final revised guidelines define facilities in terms of buildings located on a site.[133] The final revised guidelines permit facilities that contain 15 or fewer dwelling units to apply the scoping requirements to all the dwelling units that are constructed under a single contract, or are developed as whole, whether or not located on a common site.

 

The final revised guidelines defer to the Department of Justice and agencies responsible for issuing regulations under section 504 of the Rehabilitation Act to determine the extent to which accessible features are to be provided in dwelling units offered for sale.

 

The scoping requirements in the final revised guidelines for new construction of dwelling units with mobility features are sufficiently similar to the current guidelines that the impacts are expected to be minimal.  The technical requirements in the final revised guidelines for dwelling units with communication features will have monetary impacts and are further discussed in Chapter 7.14.

6.17     Alterations to Federal, State, and Local Government Housing

 

Table 6.17 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for alterations to Federal, State, and local government housing.  The current guidelines refer to UFAS.

 

Table 6.17 – Alterations to Federal, State, and Local Government Housing (text version)

Current Guidelines	Final Revised Guidelines
4.16  Accessible Buildings: Alterations.   (1)  General.  Alterations to existing buildings and facilities shall comply with the following:   (a)  If existing elements, spaces, essential features, or common areas are altered, then each such altered element, space, feature, or area shall comply with the applicable provisions of 4.1.1 to 4.1.4 of 4.1, Minimum Requirements. . . .   (c)  If alterations of single elements, when considered together, amount to an alteration of a space of a building or facility, the entire space shall be made accessible. . . .   (2)  Where a building or facility is vacated and it is totally altered, then it shall be altered to comply with 4.1.1 to 4.1.5 of 4.1, Minimum Requirements, except to the extent where it is structurally impracticable.   (3)  Where substantial alteration occurs to a building or facility, then each element or space that is altered or added shall comply with the applicable provisions of 4.1.1 to 4.1.4 of 4.1, Minimum Requirements, except to the extent where it is structurally impracticable.  The altered building or facility shall contain:   (a)  At least one accessible route complying with 4.3, Accessible Route, and 4.1.6(a);   (b)  At least one accessible entrance complying with 4.14, Entrances.  If additional entrances are altered then they shall comply with 4.1.6(a); and   (c)  The following toilet facilities, whichever is greater:   (i)  At least one toilet facility for each sex in the altered building complying with 4.22, Toilet Rooms; and 4.23, Bathrooms, Bathing Facilities, and Shower Rooms.   (ii)  At least one toilet facility for each sex on each substantially altered floor, where such facilities are provided, complying with 4.22, Toilet Rooms; and 4.23, Bathrooms, Bathing Facilities, and Shower Rooms.   (d)  In making the determination as to what constitutes “substantial alteration,” the agency issuing standards for the facility shall consider the total cost of all alterations (including but not limited to electrical, plumbing, and structural changes) for a building or facility within any twelve (12) month period.  For guidance in implementing this provision, an alteration to any building or facility is to be considered substantial if the total cost for this twelve month period amounts to 50 percent or more of the full and fair cash value of the building as defined in 3.5.	202.3 Alterations.  Where existing elements or spaces are altered, each altered element or space shall comply with the applicable requirements of Chapter 2. Exceptions: . . .  3.  Residential dwelling units not required to be accessible in compliance with a standard issued pursuant to the Americans with Disabilities Act or Section 504 of the Rehabilitation Act of 1973, as amended, shall not be required to comply with 202.3.   202.4 Alterations Affecting Primary Function Areas.  In addition to the requirements of 202.3, an alteration that affects or could affect the usability of or access to an area containing a primary function shall be made so as to ensure that, to the maximum extent feasible, the path of travel to the altered area, including the rest rooms, telephones, and drinking fountains serving the altered area, are readily accessible to and usable by individuals with disabilities, unless such alterations are disproportionate to the overall alterations in terms of cost and scope as determined under criteria established by the Attorney General. . . . Exception:  Residential dwelling units shall not be required to comply with 202.4.    233.3 Residential Dwelling Units Provided by Entities Not Subject to HUD Section 504 Regulations.  Facilities with residential dwelling units provided by entities not subject to regulations issued by the Department of Housing and Urban Development (HUD) under Section 504 of the Rehabilitation Act of 1973, as amended, shall comply with 233.3.   233.3.4 Alterations.  Alterations shall comply with 233.3.4.  Exception:  Where compliance with 809.2, 809.3, or 809.4 is technically infeasible, or where it is technically infeasible to provide an accessible route to a residential dwelling unit, the entity shall be permitted to alter or construct a comparable residential dwelling unit to comply with 809.2 through 809.4 provided that the minimum number of residential dwelling units required by 233.3.1.1 and 233.3.1.2, as applicable, is satisfied.    233.3.4.1 Alterations to Vacated Buildings.  Where a building is vacated for the purposes of alteration, and the altered building contains more than 15 residential dwelling units, at least 5 percent of the residential dwelling units shall comply with 809.2 through 809.4 and shall be on an accessible route as required by 206.  In addition, at least 2 percent of the residential dwelling units shall comply with 809.5.   233.3.4.2 Alterations to Individual Residential Dwelling Units.  In individual residential dwelling units, where a bathroom or a kitchen is substantially altered, and at least one other room is altered, the requirements of 233.3.1 shall apply to the altered residential dwelling units until the total number of residential dwelling units complies with the minimum number required by 233.3.1.1 and 233.3.1.2.  Residential dwelling units required to comply with 233.3.1.1 shall be on an accessible route as required by 206. Exception:  Where facilities contain 15 or fewer residential dwelling units, the requirements of 233.3.1.1 and 233.3.1.2 shall apply to the total number of residential dwelling units that are altered under a single contract, or are developed as a whole, whether or not located on a common site.
Model Codes & Standards
No requirements for alterations to dwelling units.

 

The current guidelines require Federal, State, and local government housing to comply with the general requirements for alterations to facilities.  Applying the general requirements for alterations to housing can result in partially accessible dwelling units where single elements or spaces in dwelling units are altered. 

 

The final revised guidelines contain specific scoping requirements for alterations to dwelling units by entities that are not subject to the Department of Housing and Urban Development’s (HUD) regulations implementing section 504 of the Rehabilitation Act.[134]  Dwelling units that are not required to be accessible are exempt from the general requirements for alterations to elements and spaces and for alterations to primary function areas.[135]

 

The scoping requirements for alterations to dwelling units are based on the general requirements in the current guidelines for alterations to facilities that are vacated and for substantially altered facilities, and are expected to have minimal impacts compared to the current guidelines.

 

• Where a building is vacated for purposes of alterations and has more than 15 dwelling units, at least 5 percent of the altered dwelling units are required to provide mobility features and at least 2 percent of the dwelling units are required to provide communication features. 

 

• Where a bathroom or a kitchen is substantially altered in an individual dwelling unit and at least one other room is also altered, the dwelling unit is required to comply with the scoping requirements for new construction until the total number of dwelling units in the facility required to provide mobility features and communication features is met. 

 

As with new construction, the final revised guidelines permit facilities that contain 15 or fewer dwelling units to apply the scoping requirements to all the dwelling units that are altered under a single contract, or are developed as whole, whether or not located on a common site.  The final revised guidelines also permit a comparable dwelling unit to provide mobility features where it is not technically feasible for the altered dwelling unit to comply with the technical requirements. 

6.18     Accessible Routes in Dwelling Units with Mobility Features

 

Table 6.18 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping and technical requirements for accessible routes in dwelling units with mobility features.  The current guidelines refer to UFAS.

 

Table 6.18 – Accessible Routes in Dwelling Units with Mobility Features (text version)

Current Guidelines	Final Revised Guidelines
4.34.1  General.  The requirements of 4.34 apply to dwelling units required to be accessible by 4.1.   4.34.2  Minimum Requirements.  An accessible dwelling unit shall be on an accessible route.  An accessible dwelling unit shall have the following accessible elements and spaces as a minimum: . . .   (3)  At least one accessible route complying with 4.3 shall connect the accessible entrances with all accessible spaces and elements within the dwelling units. . . .   (12)  At least one full bathroom shall comply with 4.34.5. . . .   (13)  The kitchen shall comply with 4.34.6.   (14)  If laundry facilities are provided, they shall comply with 4.34.7.   (15)  The following spaces shall be accessible and shall be on an accessible route:    (a)  The living area.   (b)  The dining area.   (c)  The sleeping area, or the bedroom in one bedroom dwelling areas, or at least two bedrooms or sleeping spaces in dwelling units with two or more bedrooms.	233.3.5 Dispersion.  Residential dwelling units required to provide mobility features complying with 809.2 through 809.4 . . . shall be dispersed among the various types of residential dwelling units in the facility and shall provide choices of residential dwelling units comparable to, and integrated with, those available to other residents. Exception:  Where multi-story residential dwelling units are one of the types of residential dwelling units provided, one-story residential dwelling units shall be permitted as a substitute for multi-story residential dwelling units where equivalent spaces and amenities are provided in the one-story residential dwelling unit.   809.1 General. . . . Residential dwelling units required to provide mobility features shall comply with 809.2 through 809.4 . . . .   809.2 Accessible Routes.  Accessible routes complying with Chapter 4 shall be provided within residential dwelling units in accordance with 809.2. Exception:  Accessible routes shall not be required to or within unfinished attics or unfinished basements.   809.2.1 Location.  At least one accessible route shall connect all spaces and elements which are a part of the residential dwelling unit.  Where only one accessible route is provided, it shall not pass through bathrooms, closets, or similar spaces.    809.4 Toilet Facilities and Bathing Facilities.  At least one toilet facility and bathing facility shall comply with 603 through 610.  At least one of each type of fixture provided shall comply with applicable requirements of 603 through 610.  Toilet and bathing fixtures required to comply with 603 through 610 shall be located in the same toilet and bathing area, such that travel between fixtures does not require travel between other parts of the residential dwelling unit.
Model Codes & Standards
ICC/ANSI A117.1-1998:  Section 1002.3 has an equivalent requirement for accessible routes in Type A dwelling units.

 

In dwelling units with mobility features, the current guidelines require the living area, kitchen and dining area, bedroom, bathroom, and laundry area where provided to be on an accessible route.  Where dwelling units have two or more bedrooms, at least two bedrooms are required to be on an accessible route.[136]

 

The final revised guidelines require all spaces and elements within dwelling units with mobility features to be on an accessible route.  The final revised guidelines exempt unfinished attics and unfinished basements from the accessible route requirement.  The final revised guidelines also include an exception to the dispersion requirement that permits single-story dwelling units or “flats” to be constructed, where multi-story dwelling units are provided.[137]  A “flat” eliminates the need to provide a residential elevator or platform lift to connect stories.  In multi-family construction, building codes and fire and life safety codes typically require one-hour minimum fire-resistance rated construction between dwelling units regardless of type.  There is little difference in the cost of constructing two adjacent two-story dwelling units, and a “flat” and a second dwelling unit on top.

6.19     Side Reach[138]

 

Table 6.19 shows the relevant text of the current guidelines and the final revised guidelines with respect to the scoping requirements for some of the elements required to be placed within a forward or side reach, and the technical requirements for a side reach.
 

Table 6.19 – Side Reach (text version)

Current Guidelines	Final Revised Guidelines
4.1.3  Accessible Buildings: New Construction.  Accessible buildings and facilities shall meet the following minimum requirements: . . .    (13)  Controls and operating mechanisms in accessible spaces, along accessible routes, or as parts of accessible elements . . . shall comply with 4.27.   4.27.3  Height.  The highest operable part of controls, dispensers, receptacles, and other operable equipment shall be placed within at least one of the reach ranges specified in 4.2.5 or 4.2.6. . . .   4.2.6  Side Reach.  If the clear floor space allows a parallel approach by a person in a wheelchair, the maximum high side reach allowed shall be 54 in (1370 mm) and the low side reach shall be no less than 9 in (230 mm) above the floor (Fig. 6 (a) and (b)).  [Note:  Figures 6 (a) and (b) show a reach depth of 10 inches maximum.]	205.1  General.  Operable parts on accessible elements, accessible routes, and in accessible rooms and spaces shall comply with 309.    228.1  General.  Where provided, at least one of each type of depository, vending machine, change machine, and fuel dispenser shall comply with 309.  Exception:  Drive-up only depositories shall not be required to comply with 309.    228.2 Mail Boxes.  Where mailboxes are provided in an interior location, at least 5 percent, but no fewer than one, of each type shall comply with 309.  In residential facilities, where mailboxes are provided for each residential unit, mail boxes complying with 309 shall be provided for each residential dwelling unit required to provide mobility features complying with 809.2 through 809.4.    309.3  Height.  Operable parts shall be placed within one or more of the reach ranges specified in 308.   308.3  Side Reach.   308.3.1 Unobstructed.  Where a clear floor or ground space allows a parallel approach to an element and the side reach is unobstructed, the high side reach shall be 48 inches (1220 mm) maximum and the low side reach shall be 15 inches (380 mm) minimum above the finish floor or ground. Exceptions: . . .  2:  Operable parts of fuel dispensers shall be permitted to be 54 inches (1370 mm) maximum measured from the surface of the vehicular way where fuel dispensers are installed on existing curbs.    308.3.2  Obstructed High Reach.  Where a clear floor or ground space allows a parallel approach to an element and the high side reach is over an obstruction, the height of the obstruction shall be 34 inches (865 mm) maximum and the depth of the obstruction shall be 24 inches (610 mm) maximum.  The high side reach shall be 48 inches (1220 mm) maximum for a reach depth of 10 inches (255 mm) maximum. . . .
Model Codes & Standards
ICC/ANSI A117.1-1998:  Sections 308.3.1 and 308.3.2 have equivalent requirements for a side reach.

 

The current guidelines and the final revised guidelines require operable parts on accessible elements, along accessible routes, and in accessible rooms and spaces to be placed within a forward or side reach.  The final revised guidelines also require at least one of each type of depositories, vending machines, change machines, and gas pumps; and at least 5 percent of mailboxes provided in an interior location to meet the technical requirements for a forward or side reach. 

 

The current guidelines specify a maximum 54 inch high side reach and a minimum 9 inch low side reach for a reach depth of 10 inches maximum.  The final revised guidelines specify a maximum 48 inch high side reach and a minimum 15 inch low side reach for an unobstructed reach, and a maximum 48 inch high side reach for a reach depth of 10 inches maximum over an obstruction 34 inches maximum in height. 

 

Changing the side reach will affect a variety of building elements such as light switches, electrical outlets, thermostats, fire-alarm pull stations, card readers, and keypads.  Installing the elements at the proper height when a facility is newly constructed or when an element or space is altered typically will involve little or no cost. 

 

The Access Board held public meetings in October 2000 to gather additional information on the impacts of changing the side reach on automated teller machines, gas pumps, and vending machines.[139]  Information provided at the public meeting disclosed that the revision will have minimal impacts:

 

• Most currently available automated teller machines can meet the 48 inch high side reach.

 

• Fire and life safety codes typically require gas pumps to be protected from vehicular impact either by elevating the equipment on a 6 inch high island, or by providing bollards or other barriers around the equipment.  The 6 inch high island is the preferred or required method of protection in many jurisdictions.  Many currently available gas pumps can meet the 48 inch high side reach, when installed without a 6 inch high island.  These gas pumps can meet the 48 inch high side reach when installed on a 6 inch high island by using add-on buttons and card readers installed at a lower height.  The final revised guidelines include an exception for gas pumps installed on existing islands that permit a 54 inch high side reach.  Some of the newer model gas pumps can meet the 48 inch high side reach, when installed on a 6 inch high island.

 

• Only vending machines that are fixed or built-in to a facility are required to meet the 48 inch high side reach.  The majority of vending machines are portable.  Some vending machines currently meet the 48 inch high side reach.  Until more vending machines incorporate a 48 inch high side reach, there may be a limited choice of equipment.  Portable vending machines can always be used as an alternative to built-in equipment.

 

6.20     Handrails Along Walkways[140]

 

Table 6.20 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirement for handrails along walkways that are not ramps. 

 

Table 6.20 – Handrails Along Walking Surfaces (text version)

Current Guidelines	Final Revised Guidelines
No requirement.	403.6 Handrails.  Where handrails are provided along walking surfaces with running slopes not steeper than 1:20 they shall comply with 505.   [Note:  The following requirements in 505 are applicable to handrails along walking surfaces:  505.4 Height; 505.5 Clearance; 505.6 Gripping Surface; 505.7 Cross Section; 505.8 Surfaces; and 505.9 Fittings.  An exception to 505.6 permits the handrail gripping surfaces to be obstructed along their entire length where they are integral to crash rails or bumper guards.]
Model Codes & Standards
No requirement for handrails along walking surfaces.

 

The current guidelines do not contain any technical requirement for handrails provided along walkways that are not ramps.  The final revised guidelines require handrails along walkways that are not ramps to comply with certain technical requirements..

 

The revision is expected to have minimal impacts since handrails provided along walkways that are not ramps are typically installed in accordance with the model codes, which are generally consistent with the final revised guidelines.  Certain health care facilities provide handrails in corridors for use by ambulatory patients or residents.  Health-care facilities may also provide bumper guards along walls to protect the walls from damage by carts, beds, and other moving equipment.  Products that are designed to serve as bumper guards only are not required to comply with the technical requirements for handrails.  There are products designed to serve as combination bumper guards and handrails that meet the technical requirements for handrails.  Where combination bumper guards and handrails are provided, the final revised guidelines contain an exception that permits the bottom of the gripping surface to be obstructed along the entire length.

 

6.21     Thresholds at Doorways

 

Table 6.21 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirement for thresholds at doorways. 

 

Table 6.21 – Thresholds at Doors (text version)

Current Guidelines	Final Revised Guidelines
4.13.8  Thresholds at Doorways.  Thresholds at doorways shall not exceed ¾ in (19 mm) in height for exterior sliding doors or ½ in (13 mm) for other types of doors.  Raised thresholds and floor level changes at accessible doorways shall be beveled with a slope no greater than 1:2 (see 4.5.2).    [Note:  Section 4.5.2 requires changes in level between ¼ inch and ½ inch to be beveled with a slope not steeper than 1:2.]	404.1 General.  Doors, doorways, and gates that are part of an accessible route shall comply with 404.   404.2.5 Thresholds.  Thresholds, if provided at doorways, shall be ½ inch (13 mm) high maximum.  Raised thresholds and changes in level at doorways shall comply with 302 and 303. EXCEPTION:  Existing or altered thresholds ¾ inch (19 mm) high maximum that have a beveled edge on each side with a slope not steeper than 1:2 shall not be required to comply with 404.2.5.
Model Codes & Standards
IBC 2000:  Section 1003.3.1.6 has an equivalent requirement for thresholds at doorways that are part of an accessible means of egress, except for sliding doors.  Section 3408.7.14 has an equivalent exception for existing or altered thresholds.   IBC 2003:  Section 1008.1.6 has an equivalent requirement for thresholds at doorways that are part of an accessible means of egress, except for sliding doors.  Section 3409.7.12 has an equivalent exception for existing or altered thresholds.   ICC/ANSI A117.1-1998:  Section 404.2.5 has an equivalent requirement for thresholds at doorways.  Section 1002.5 has an equivalent requirement for thresholds at doorways in Type A dwelling units, except for exterior sliding doors.

 

The current guidelines require thresholds at doorways not to exceed ½ inch; and thresholds at exterior sliding doors not to exceed ¾ inch.  The final revised guidelines require thresholds at all doorways that are part of an accessible route not to exceed ½ inch.  The current guidelines and the final revised guidelines require raised thresholds that exceed ¼ inch to be beveled on each side with a slope not steeper than 1:2.  The final revised guidelines include an exception that exempts existing and altered thresholds which do not exceed ¾ inch and are beveled on each side from the requirement. 

 

Exterior sliding doors typically have higher thresholds than other doors to provide a barrier for water and wind infiltration, and to prevent the doors from being lifted out of the tracks.  Threshold heights for exterior sliding doors typically exceed 1 inch.  The ¾ inch threshold requirement in the current guidelines is typically met by providing a special installation detail.  In wood construction, the threshold may need to be set on the sub-floor, or the sub-floor material or thickness may need to change at the threshold.  In concrete construction, the slab may need to be recessed at the door location.  Adding a lightweight concrete floor topping on the structural floor can also raise the finish floor in relation to the threshold height.  Changing the threshold requirement from ¾ inch to ½ inch will make the special installation detail slightly more difficult, but is not expected to add any quantifiable cost to the work.

 

Lower thresholds, whether ¾ inch or ½ inch, make it more difficult to prevent water and wind infiltration, and require special design consideration to be given to the detail at the juncture of exterior walls and floors where exterior sliding doors are provided.  Changing the threshold requirement from ¾ inch to ½ inch may require some additional design consideration, but does not add to the cost of the sliding door or to the design solution.  Where the design solution is too difficult or too costly, a swinging door can be used instead of a sliding door.  Swinging doors must also meet the ½ inch threshold requirement, but threshold heights and profiles for swinging doors are more varied than for sliding doors.  Swinging doors can meet the ½ inch threshold requirement without any special installation detail and provide greater protection against water and wind infiltration.

6.22     Door and Gate Surfaces

 

Table 6.22 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirement for door and gate surfaces. 

 

Table 6.22 – Door and Gate Surfaces (text version)

Current Guidelines	Final Revised Guidelines
No requirement.	404.1 General.  Doors, doorways, and gates that are part of an accessible route shall comply with 404.   404.2.10 Door and Gate Surface.  Swinging door and gate surfaces within 10 inches (255 mm) of the finish floor or ground measured vertically shall have a smooth surface on the push side extending the full width of the door or gate.  Parts creating horizontal or vertical joints in these surfaces shall be within 1/16 inch (1.6 mm) of the same plane as the other.  Cavities created by added kick plates shall be capped. Exceptions: . . . 2.  Tempered glass doors without stiles and having a bottom rail or shoe with the top leading edge tapered at 60 degrees minimum from the horizontal shall not be required to meet the 10 inch (255 mm) bottom smooth surface height requirement. . . . 4.  Existing doors and gates without smooth surfaces within 10 inches (255 mm) of the finish floor or ground shall not be required to comply with 404.2.10 provided that if added kick plates are installed, cavities created by such kick plates are capped.
Model Codes & Standards
ICC/ANSI A117.1-1998:  Section 404.2.10 has an equivalent requirement for door and gate surfaces and exception for tempered glass doors without stiles.

 

The current guidelines do not contain any technical requirement for door surfaces.  The final revised guidelines require a smooth surface on the bottom 10 inches of the push side of swinging doors so that individuals who use wheelchairs can open the door without creating a trap or pinch point.  The revision is expected to have minimal impacts since wood, metal, and composite doors with flush surfaces meet the technical requirements.  Doors with raised or inset panels 10 inches above the bottom of the door also meet the technical requirements.  The final revised guidelines contain an exception that exempts tempered glass doors without stiles from the technical requirements.  The exception requires the top rail to be beveled to the glass surface, which is a common detail on tempered glass doors.  The final revised guidelines also contain an exception for existing doors.

 

6.23     Automatic Door Break-Out Openings

 

Table 6.23 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirement for automatic door break-out openings. 

 

Table 6.23 – Automatic Door Break-Out Openings (text version)

Current Guidelines	Final Revised Guidelines
4.13.12  Automatic Doors and Power-Assisted Doors. If an automatic door is used, then it shall comply with ANSI/BHMA A156.10-1985.  Slowly opening, low-powered, automatic doors shall comply with ANSI A156.19-1984. . . .	404.1 General.  Doors, doorways, and gates that are part of an accessible route shall comply with 404.   404.3  Automatic and Power-Assisted Doors and Gates.  Automatic doors and automatic gates shall comply with 404.3. . . .    404.3.1  Clear Width.  Doorways shall provide a clear opening of 32 inches (815 mm) minimum in power-on and power-off mode.  The minimum clear width for automatic door systems in a doorway shall be based on the clear opening provided by all leaves in the open position.   404.3.6 Break Out Opening.  Where doors and gates without standby power are a part of a means of egress, the clear break out opening at swinging or sliding doors and gates shall be 32 inches (815 mm) minimum when operated in emergency mode. Exception:  Where manual swinging doors and gates comply with 404.2 and serve the same means of egress compliance with 404.3.6 shall not be required.
Model Codes & Standards
IBC 2000:  Sections 1003.3.1.1 and 1003.3.1.3.2 have an equivalent requirement for automatic door break-out openings.   IBC 2003:  Sections 1008.1.1 and 1008.1.3.2 have an equivalent requirement for automatic door break-out openings.

 

The current guidelines do not contain any technical requirement for automatic door break out openings.  The final revised guidelines require automatic doors that are part of a means of egress and that do not have standby power to have a 32 inch minimum clear break out opening when operated in emergency mode.  The minimum clear opening width for automatic doors is measured with all leaves in the open position.  Automatic bi-parting doors or pairs of swinging doors that provide a 32 inch minimum clear break out opening in emergency mode when both leaves are opened manually meet the technical requirement.  The final revised guidelines include an exception that exempts automatic doors from the technical requirement for break-out openings when accessible manual swinging doors serve the same means of egress.  The revision is expected to have minimal impacts since most automatic doors that are part of a means of egress meet the technical requirement.

 

6.24     Assistive Listening Systems[141]

 

Table 6.24 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirements for assistive listening systems. 

 

Table 6.24 – Assistive Listening Systems (text version)

Current Guidelines	Final Revised Guidelines
4.33.7  Types of Assistive Listening Systems.  Assistive listening systems (ALS) are intended to augment standard public address and audio systems by providing signals which can be received directly by persons with special receivers or their own hearing aids and which eliminate or filter background noise.  The type of assistive listening system appropriate for a particular application depends on the characteristics of the setting, the nature of the program, and the intended audience.  Magnetic induction loops, infra-red and radio frequency systems are types of listening systems which are appropriate for various applications.	706.1 General.  Assistive listening systems required in assembly areas shall comply with 706.   706.2 Receiver Jacks.  Receivers required for use with an assistive listening system shall include a 1/8-inch (3.5 mm) standard mono jack.   706.3 Receiver Hearing-Aid Compatibility.  Receivers required to be hearing-aid compatible shall interface with telecoils in hearing aids through the provision of neckloops.   706.4 Sound Pressure Level.  Assistive listening systems shall be capable of providing a sound pressure level of 110 dB minimum and 118 dB maximum with a dynamic range on the volume control of 50 dB.   706.5 Signal-to-Noise Ratio.  The signal-to-noise ratio for internally generated noise in assistive listening systems shall be 18 dB minimum.   706.6 Peak Clipping Level.  Peak clipping shall not exceed 18 dB of clipping relative to the peaks of speech.
Model Codes & Standards
ICC/ANSI A117.1-1998:  No specific requirements for assistive listening systems.

 

The current guidelines do not contain specific technical requirements for assistive listening systems.  The final revised guidelines require assistive listening systems to have standard mono jacks; and require hearing-aid compatible receivers to have neckloops to interface with telecoils in hearing aids.  The final revised guidelines also specify sound level pressure, signal-to-noise ratio, and peak clipping level.  The revision is expected to have minimal impacts since currently available assistive listening systems meet the technical requirements. 

6.25     Automated Teller Machines and Fare Machines

 

Table 6.25 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirements for automated teller machines and fare machines. 

 

Table 6.25 – Automated Teller Machines and Fare Machines (text version)

Current Guidelines	Final Revised Guidelines
4.34.1  General.  Each automated teller machine required to be accessible by 4.1.3 shall be on an accessible route and shall comply with 4.34.   4.34.5  Equipment for Persons with Vision Impairments.  Instructions and all information for use shall be made accessible to and independently usable by persons with vision impairments.   10.3.1  New Construction.  New stations in rapid rail, light rail, commuter rail, intercity bus, intercity rail, high speed rail, and other fixed guideway systems (e.g., automated guideway transit, monorails, etc.) shall comply with the following provisions, as applicable: . . .    (7)  Automatic fare vending, collection and adjustment (e.g., add fare) systems shall comply with . . . 4.34.5.	707.1  General.  Automatic teller machines and fare machines shall comply with 707.   707.3  Operable Parts.  Operable parts shall comply with 309.  Unless a clear or correct key is provided, each operable part shall be able to be differentiated by sound or touch, without activation. . . .   707.4  Privacy.  Automatic teller machines shall provide the opportunity for the same degree of privacy of input and output available to all individuals.   707.5  Speech Output.  Machines shall be speech enabled.  Operating instructions and orientation, visible transaction prompts, user input verification, error messages, and all displayed information for full use shall be accessible to and independently usable by individuals with vision impairments.  Speech shall be delivered through a mechanism that is readily available to all users, including but not limited to, an industry standard connector or a telephone handset.  Speech shall be recorded or digitized human, or synthesized. Exceptions: 1.  Audible tones shall be permitted instead of speech for visible output that is not displayed for security purposes, including but not limited to, asterisks representing personal identification numbers. 2.  Advertisements and other similar information shall not be required to be audible unless they convey information that can be used in the transaction being conducted. 3.  Where speech synthesis cannot be supported, dynamic alphabetic output shall not be required to be audible.   707.5.1  User Control.  Speech shall be capable of being repeated or interrupted.  Volume control shall be provided for the speech function. Exception:  Speech output for any single function shall be permitted to be automatically interrupted when a transaction is selected.   707.5.2  Receipts.  Where receipts are provided, speech output devices shall provide audible balance inquiry information, error messages, and all other information on the printed receipt necessary to complete or verify the transaction. Exceptions:  1.  Machine location, date and time of transaction, customer account number, and the machine identifier shall not be required to be audible. 2.  Information on printed receipts that duplicates information available on-screen shall not be required to be presented in the form of an audible receipt. 3.  Printed copies of bank statements and checks shall not be required to be audible.   707.6  Input.  Input devices shall comply with 707.6.   707.6.1  Input Controls.  At least one tactilely discernible input control shall be provided for each function.  Where provided, key surfaces not on active areas of display screens, shall be raised above surrounding surfaces.  Where membrane keys are the only method of input, each shall be tactilely discernable from surrounding surfaces and adjacent keys.   707.6.2  Numeric Keys.  Numeric keys shall be arranged in a 12-key ascending or descending telephone keypad layout.  The number five key shall be tactilely distinct from the other keys.   707.6.3  Function Keys.  Function keys shall comply with 707.6.3.   707.6.3.1  Contrast.  Function keys shall contrast visually from background surfaces.  Characters and symbols on key surfaces shall contrast visually from key surfaces.  Visual contrast shall be either light-on-dark or dark-on-light. Exception:  Tactile symbols required by 707.6.3.2 shall not be required to comply with 707.6.3.1.   707.6.3.2  Tactile Symbols.  Function key surfaces shall have tactile symbols as follows: Enter or Proceed key: raised circle; Clear or Correct key: raised left arrow; Cancel key: raised letter ex; Add Value key: raised plus sign; Decrease Value key: raised minus sign.   707.7  Display Screen.  The display screen shall comply with 707.7. Exception:  Drive-up only automatic teller machines and fare machines shall not be required to comply with 707.7.1.   707.7.1  Visibility.  The display screen shall be visible from a point located 40 inches (1015 mm) above the center of the clear floor space in front of the machine.   707.7.2  Characters.  Characters displayed on the screen shall be in a sans serif font.  Characters shall be 3/16 inch (4.8 mm) high minimum based on the uppercase letter "I".  Characters shall contrast with their background with either light characters on a dark background or dark characters on a light background.    707.8  Braille Instructions.  Braille instructions for initiating the speech mode shall be provided.  Braille shall comply with 703.3.
Model Codes & Standards
ICC/ANSI A117.1-1998:  Section 707 has similar requirements for automatic teller machines and fare machines.

 

The current guidelines require instructions and all information for using automated teller machines and fare machines to be accessible to and independently usable by persons with vision impairments.  Blind individuals and their organizations have entered into settlement agreements with major banks to implement the current guidelines by providing speech output and tactilely discernable input controls on automated teller machines.[142]  The manufacturers of automated teller machines have responded by making available equipment with these features.  The final revised guidelines contain technical requirements for privacy, speech output, tactilely discernable input controls, display screens, and Braille instructions.[143]

 

The Access Board held a public meeting in October 2000 to gather additional information on the capabilities of automated teller machines, especially with respect to speech output.[144]  Based on the meeting and supplemental comments from the banking industry, the final revised guidelines include several exceptions:

 

• Where the network cannot support speech synthesis, dynamic alphabetic output is not required to be audible.

 

• Audible tones are permitted instead of speech for visible output that is not displayed for security purposes, such as asterisks representing personal identification numbers.

 

• Advertisements are not required to be audible unless they convey information that can be used in the transaction being conducted.

 

• Speech output for any single function is permitted to be automatically interrupted when a transaction is selected.

 

• Information on printed receipts that duplicates information available during the transaction is not required to be presented in the form of an audible receipt.

 

• Information on printed receipts identifying machine location, machine number, date and time of transaction, and customer account number is not required to be audible.

 

• Printed copies of bank statements and checks are not required to be audible.

 

• Tactile symbols for the enter or proceed key, clear or correct key, cancel key, add value key, and decrease value key are not required to contrast visually from background surfaces.

 

The revision is expected to have minimal impacts since the technical requirements are consistent with current technology, and the exceptions address the concerns of the banking industry.

 

6.26     Wheelchair Space Overlap in Assembly Areas[145]

 

Table 6.26 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirements for wheelchair space overlap in assembly areas. 

 

Table 6.26 – Wheelchair Space Overlap in Assembly Areas (text version)

Current Guidelines	Final Revised Guidelines
4.3.3  Width.  The minimum clear width of an accessible route shall be 36 in (915 mm) except at doors (see 4.13.5 and 4.13.6). . . .	402.1  General.  Accessible routes shall comply with 402.   402.2  Components.  Accessible routes shall consist of one or more of the following components: walking surfaces with a running slope not steeper than 1:20, doorways, ramps, curb ramps excluding the flared sides, elevators, and platform lifts.  All components of an accessible route shall comply with the applicable requirements of Chapter 4.   403.5.1  Clear Width.  Except as provided in 403.5.2 and 403.5.3, the clear width of walking surfaces shall be 36 inches (915 mm) minimum. . . .   802.1.4  Approach.  Wheelchair spaces shall adjoin accessible routes.  Accessible routes shall not overlap  wheelchair spaces.   802.1.5  Overlap.  Wheelchair spaces shall not overlap circulation paths.
Model Codes & Standards
IBC 2000:  Section 1008.7.6 prohibits obstructions in the required width of assembly aisles, except for handrails.   IBC 2003:  Section 1024.9.6 prohibits obstructions in the required width of assembly aisles, except for handrails.

 

The current guidelines and the final revised guidelines require walkways that are part of an accessible route to have a 36 inch minimum clear width.  The final revised guidelines specifically prohibit accessible routes from overlapping wheelchair spaces.  This is consistent with the technical requirements for accessible routes, since the clear width of accessible routes cannot be obstructed by any object.  The final revised guidelines also specifically prohibit wheelchair spaces from overlapping circulation paths.  An advisory note clarifies that this prohibition applies only to the circulation path width required by applicable building codes and fire and life safety codes since the codes prohibit obstructions in the required width of assembly aisles. 

 

The revision does not present any difficult design challenges and is expected to have minimal impacts.  Where a main circulation path is located in front of a row of seats that contains a wheelchair space and the circulation path is wider than required by applicable building codes and fire and life safety codes, the wheelchair space may overlap the “extra” circulation path width.  Where a main circulation path is located behind a row of seats that contains a wheelchair space and the wheelchair space is entered from the rear, the aisle in front of the row may need be to be wider in order not to block the required circulation path to the other seats in the row, or a mid-row opening may need to be provided to access the required circulation path to the other seats.

 

6.27     Visible Alarms in Hotel Guest Rooms with Communication Features

 

Table 6.27 shows the relevant text of the current guidelines and the final revised guidelines with respect to the technical requirement for visible alarms in hotel guest rooms with communication features.[146]

 

Table 6.27 – Visible Alarms in Hotel Guest Rooms with Communication Features (text version)

Current Guidelines	Final Revised Guidelines
9.3.1  General.  In sleeping rooms required to comply with this section, auxiliary visual alarms shall be provided and shall comply with 4.28.4. . . .   4.28.4  Auxiliary Alarms.  Units and sleeping accommodations shall have a visual alarm connected to the building emergency alarm system or shall have a standard 110-volt electrical receptacle into which such an alarm can be connected and a means by which a signal  from the building emergency alarm system can trigger such an auxiliary alarm.  When visual alarms are in place the signal shall be visible in all areas of the unit or room.  Instructions for use of the auxiliary alarm or receptacle shall be provided.	806.3  Guest Rooms with Communication Features.  Guest rooms required to provide communication features shall comply with 806.3.   806.3.1  Alarms.  Where emergency warning systems are provided, alarms complying with 702 shall be provided.   702.1  General.  Fire alarm systems shall have permanently installed audible and visible alarms complying with NFPA 72 (1999 or 2002 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1) . . .  In addition, alarms in guest rooms required to provided communication features shall comply with sections 4-3 and 4-4 of NFPA 72 (1999 edition) or sections 7.4 and 7.5 of NFPA 72 (2002 edition).
Model Codes & Standards
IBC 2000:  Section 907.9.1.2 has an equivalent requirement for visible alarms in hotel guest rooms with communication features.   IBC 2003:  Section 907.9.1.3 has an equivalent requirement for visible alarms in hotel guest rooms with communication features.

 

The current guidelines require hotel guest rooms with communication features to provide either permanently installed visible alarms that are connected to the building fire alarm system, or portable visible alarms that are connected to a standard 110-volt electrical outlet and are activated by the building fire alarm system.  People who are deaf or hard of hearing have reported that portable visible alarms used in hotel guest rooms are deficient because the alarms are not always activated by the building fire alarm system, and the alarms do not work when the building power source goes out in emergencies.[147] 

 

The final revised guidelines require hotel guest rooms with communication features to provide permanently installed visible alarms complying with the NFPA 72, National Fire Alarm Code (1999 or 2002 edition).  The NFPA 72 contains technical requirements for visible alarms in sleeping areas, and requires combination smoke alarms and visible notification appliances that are connected to the building’s electrical system.[148]  The revision is consistent with the model building codes and fire and life safety codes, which are adopted by all the States and require newly constructed hotels to provide hard- wired smoke alarms complying with the NFPA 72 in guest rooms, including combination visible notification devices in guest rooms for individuals with hearing impairments.[149] 

 

As discussed in Chapter 5.14, the final revised guidelines add a new exception for alterations to existing facilities that exempt existing fire alarm systems from providing visible alarms, unless the fire alarm system is upgraded or replaced, or a new fire system is installed.  Hotels that alter guest rooms are not required to provide permanently installed visible alarms complying with the NFPA 72 if the existing fire alarm system has not been upgraded or replaced, or a new fire alarm system has not been installed. 

 

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