Erie County Jail - ADA Barriers Report

 

2010 Standards Citation

1991 Standards Citation

Violation

Requirement/Action Required

 

 

 

Erie County Correctional Facility - 11581 Walden Avenue

 

1

211, 602.7

4.1.6(1)(b), 4.1.3(10), 4.15.2

Throughout the facility, many of the drinking fountains do not comply with the Standards.

Ensure that 50% of all drinking fountains per building (but at least 1) comply with the Standards and have a spout mounted at the front of the unit no higher than 36 inches (measured from the finished floor or ground surface to the spout outlet). Ensure that fountain controls require no more than 5 pounds of force to operate; are operable with one hand without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Additionally, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a “hi-lo” fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser; or by such other means as would achieve the required accessibility for each group of people.

2

217.3, 704.3

4.1.3(17)(b), 4.31.5(2)

Throughout the facility, none of the telephones have volume controls.

Provide a sufficient number of telephones such that 25% are hearing aid compatible and have a volume control mechanism.

3

226.1, 902

4.1.3(18), 4.32

Throughout the facility, the tables used by both detainees and visitors are not accessible to persons who use wheelchairs.

Provide a sufficient number of accessible tables so that 5% of them in each area (but no fewer than one) are available for use by people with mobility disabilities. Each accessible table must be on an accessible route, must have knee space at the table at least 27 inches high, 30 inches wide, and 17 inches deep, and must have a table top between 28 inches and 34 inches above the floor. Ensure that the tables are distributed throughout the facility.

4

217.4.8

4.1.6(1)(b), 4.1.3(17)(c)(ii)

Throughout the facility, TTY's are not provided for detainees and for the public.

Provide at least one accessible TTY for use by detainees. Adopt policies and procedures to ensure that access afforded to the TTY for detainees with disabilities is equal to the access afforded to detainees who use the standard telephone. In addition, where detainee telephone calls are time-limited, adopt policies permitting detainees with disabilities who use TTY’s a longer period of time to make those calls, due to the slower nature of TTY communications compared with voice communications. In addition, provide at least one accessible public TTY with appropriate signage.

 

 

 

Accessible Routes - Exterior

 

5

206.1, 406.1, 406.2

4.1.6(1)(b), 4.1.2(1) & (2), 4.7.2

The curb ramp near the bus stop has a slope of 10.9% and the adjacent roadway to the curb ramp has a cross slope of 8.6%.

Provide a curb ramp that is at least 36 inches wide, has a maximum slope of 8.33% and a maximum cross slope of 2%. Ensure that the adjacent gutter and road surface has a cross slope of no more than 5% and are flush and free of abrupt change.

6

208, 502.4, 302

4.1.6(1)(b), 4.1.2(5), 4.6.3

A significant portion of the accessible parking spaces and access aisles have slopes or cross-slopes in excess of 2%, ranging between 3.3% and 9.8%.

Provide designated accessible parking spaces and access aisles that are flat and level, with slopes and cross-slopes not exceeding 2% in all directions.

7

206.1, 406.2

4.1.6(1)(b), 4.1.2(1) & (2), 4.7.2

At the curb ramp near the accessible public parking, the transition to the vehicular surface is abrupt and 2 1/2 inches high.

Provide a curb ramp that is at least 36 inches wide and has transitions on and off that are flush and free of abrupt changes.

 

 

 

Non-Contact Visitation - Detainee and Visitor Side

 

8

226, 232.5, 305, 306, 902, 904.4.2, 904.6

4.1.6(1)(b), 4.1.3(18), 4.32.4

The visitation area is not accessible to wheelchair users on both the visitor and detainee side.

Provide a visitation or other area such that at least 5% of cubicles provide accessible clear floor space and work surfaces on both the visitor and detainee sides. Where counters are provided, provide at least one that is, on both the visitor and detainee side, at least 30 inches long and no more than 36 inches high, with knee space and clear floor space provided under the counter. Where solid partitions or security glazing separate visitors from detainees, a method to facilitate voice communication shall be provided. 

9

217.2, 704.2.4

4.1.6(1)(b), 4.1.3(17)(a), 4.31.8

The telephone cord is less than 29 inches long.

Provide an accessible telephone with a cord that is at least 29 inches long on the visitor and detainee side.

 

 

 

Video Visitation

 

10

226, 232.5, 902.2, 902.3

4.1.6(1)(b), 4.1.3(18), 4.32.3, 4.32.4

The video visitation station is not accessible to wheelchair users.

Provide a visitation or other area such that at least 5% of cubicles provide accessible clear floor space and work surfaces on both the visitor and detainee sides. Where counters are provided, on both the visitor and detainee side, provide at least one that is at least 30 inches long and no more than 36 inches high, with knee space and clear floor space provided under the counter. If a telephone is part of the video visitation station, provide a phone cord that is at least 29 inches long.

11

206.1, 403.5

4.1.6(1)(b), 4.1.3(2), 4.4.1

The accessible route to the video visitation station narrows to only 29 1/2 inches wide.

Provide an accessible route to each area, feature, or element described with a minimum clear width of 36 inches, except at doors and at obstructions that are less than 24 inches long, where the width may decrease to 32 inches.

 

 

 

Visitor Waiting

 

12

205, 309.4

4.1.6(1)(b), 4.1.3(13), 4.27.4

The locker keys require tight grasping, tight pinching, or twisting of the wrist to operate.

Provide this element with mechanical controls that can be operated with no more than 5 pounds of force and that can be used with one hand and without tight grasping, pinching, or twisting of the wrist (lever-operated, push-type, and electronically controlled mechanisms are examples of acceptable designs).

13

204.1, 307.2

4.1.6(1)(b), 4.1.3(2), 4.4.1

The underside of a wall-hung counter is 35 1/2 inches above the floor and projects 12 inches into the circulation path.

Provide a circulation path at this location such that no objects have their leading edges protruding more than 4 inches into walks, halls, corridors, passageways, or aisles at a height between 27 inches and 80 inches above the finished floor or ground. Freestanding objects mounted on posts or pylons may overhang no more than 12 inches at a height between 27 and 80 inches above the finished floor or ground. Providing a cane-detectable barrier is an acceptable solution. A protruding object (and cane-detectable barrier) shall not reduce the clear width of an accessible route or maneuvering space.

 

 

 

Visitor Waiting - Men's Toilet Room With Stalls

 

14

206.5, 213.2, 216.2, 404, 603, 604, 605, 606, 703

4.1.6(1)(b), 4.1.3(7)&(8), 4.1.3(11), 4.1.3(16)(a), 4.13.6, 4.17, 4.18,4.19.4, 4.30.4

The toilet room does not have any accessible features.

Provide an accessible toilet room such that all of the room’s elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Visitor Waiting - Women's Toilet Room With Stalls

 

15

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b), 4.1.3(7)&(8), 4.1.3(11), 4.1.3(16)(a), 4.13.6, 4.17, 4.19.4, 4.30.4

The toilet room does not have any accessible features.

Provide an accessible toilet room such that all of the room’s elements, including door, door hardware, clear floor space, water closet, compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Processing Transport Waiting - Single User Toilet Room

 

16

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b)& (d), 4.1.3, 4.13.5, 4.13.9

The toilet room does not have any accessible features.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Processing Transport Waiting - Female Holding

 

17

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

Provide accessible cells so that at least 3% minimum of the total cells are accessible and ensure that all inmates with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards.

 

 

 

Library

 

18

206.1, 405.8, 505.4

4.1.6(1)(b), 4.1.3(1), 4.8.5

The top of the ramp handrails is 32 1/2 inches high.

Provide handrails that are mounted such that the top is between 34 inches and 38 inches above the ramp surface.

19

206.1, 405.8, 505.10

4.1.6(1)(b), 4.1.3(1), 4.8.5

The handrail extensions over the bottom landing are not level.

Provide handrails that extend at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface.

20

206.1, 405.9

4.1.6(1)(b), 4.1.3(1), 4.8.7

The ramp has no edge protection on one side.

Provide edge protection at least 2 inches high at the drop off side.

21

227.3, 904.4

4.1.6(1)(b), 7.2(1)

The checkout counter is 39 1/4 inches above the floor.

Provide a counter such that a portion at least 36 inches wide and no more than 36 inches above the finished floor.

 

 

 

Classrooms

 

22

206.1, 405, 505.2

4.1.6(1)(b), 4.1.3(1), 4.8.2

In the corridor to the GED classroom, the ramp does not comply with the Standards.

Provide a ramp that is at least 36 inches wide with a slope not exceeding 8.33% and a cross slope not exceeding 2%; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; with level landings measuring at least 60 inches by 60 inches when the ramp changes direction; with no level changes in excess of 1/2 inch vertically and no level changes greater than 1/4 inch vertically unless they are beveled with a slope no greater than 50%; and with edge protection that is at least 2 inches high at the drop off sides. Provide handrails that are between 1 1/4 inches and 1 1/2 inches in diameter such that the inside handrail is continuous and both handrails have a continuous gripping surface along both sides of the ramp extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface; the handrails do not rotate within their fittings; and both handrails are mounted with the tops between 34 inches and 38 inches above the ramp surface and at least 1 1/2 inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post.

 

 

 

Chapel

 

23

219, 706

4.1.6(1)(b), 4.1.3(19)(b),

There is no assistive listening system.

Provide an assistive listening system. It may be permanently installed or it may be portable.

24

206.1, 303.4, 405, 406, 410

4.1.6(1)(b), 4.1.3(1), 4.3.8

The detainee entrance to the Parole Hearing Room is through the Chapel and across the stage. The route is blocked by 6 steps.

Establish a procedure for providing access to this program or install ramps, platform lifts, or an elevator in compliance with the Standards. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances.

 

 

 

Recreation Yard

 

25

206.1, 303.4, 405, 406, 410

4.1.6(1)(b), 4.1.2(1) & (2), 4.3.8

The accessible route to the recreation yard is blocked by a 4 inch step.

Establish a procedure for providing access to this program or install ramps, platform lifts, or an elevator in compliance with the Standards. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances.

 

 

 

Medical Care Unit

 

26

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11)

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

27

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b), 4.1.3(11)

The toilet facilities do not have accessible features.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

28

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

Provide accessible cells so that at least 3% minimum of the total cells are accessible and ensure that all inmates with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards.

 

 

 

Negative Pressure Cells

 

29

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

Provide accessible cells so that at least 3% minimum of the total cells are accessible and ensure that all detainees with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards.

 

 

 

Psychiatric Unit

 

30

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

Provide accessible cells so that at least 3% minimum of the total cells are accessible and ensure that all detainees with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards.

31

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(7)&(8)&(11), 4.13.9

There is no accessible shower.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Kilo Unit - Male Dormitory (Alteration)

 

32

206.1, 303.4

4.1.6(1)(b), 4.1.3(1), 4.3.8

The accessible route to the recreation yard is blocked by 5 steps.

Establish a procedure for providing access to this program or install ramps, platform lifts, or an elevator in compliance with the Standards. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances.

33

205, 309.3

4.1.6(1)(b), 4.1.3(13), 4.27.3

The mail slot is not accessible because it is mounted 57 inches above the floor.

Provide this element in a location where there is a compliant 30 inch by 48 inch clear floor space and the operable parts are within 48 inches of the floor. 

34

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b), 4.1.3(11),

The toilet room does not have any accessible features.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

35

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11),

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Juliette Unit - Female Dormitory (Alteration)

 

36

232, 807.2.3

4.1.6(1)(b), 232.3, 4.1.3

There are not a sufficient number of accessible beds.

Provide access to 5% of the beds, such that the sides of these beds are on an accessible route and there is a 30 inch by 48 inch clear floor space parallel to the side of the beds.

37

206.1, 303.4

4.1.6(1)(b), 4.1.3(1), 4.3.8

The accessible route to the recreation yard is blocked by 5 steps.

Establish a procedure for providing access to this program or install ramps, platform lifts, or an elevator in compliance with the Standards. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances.

38

205, 309.3

4.1.6(1)(b), 4.1.3(13), 4.27.3

The mail slot is not accessible because it is mounted 52 inches above the floor.

Provide this element in a location where there is a compliant 30 inch by 48 inch clear floor space and the operable parts are within 48 inches of the floor. 

39

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b), 4.1.3(11),

The toilet room with stalls does not have any accessible features.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

40

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11),

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Kitchen - Inmate Single User Toilet Room

 

41

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b), 4.1.3(11), 4.13, 4.16, 4.18, 4.19, 4.26, 4.27, 4.30

The toilet room does not have any accessible features.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Cell Blocks - Male and Female 

 

42

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

For new and altered facilities, the County shall provide a minimum of 3%, but no fewer than one, of the total number of cells in a facility to be accessible, and shall provide cells with mobility features for each classification level and special housing area. Ensure that all detainees with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards. 

43

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b), 4.1.3(11),

The toilets in the cell block bathrooms do not have accessible features.

In designated accessible housing units, provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

44

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11),

The showers do not have any accessible features.

In designated accessible housing units, provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

45

206.1, 303.4

4.1.6(1)(b), 4.1.2(1) & (2), 4.3.8

The accessible routes to the recreation yards are blocked by steps.

Establish a procedure for providing access to this program or install ramps, platform lifts, or an elevator in compliance with the Standards. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances.

46

226.1, 902.2

4.1.6(1)(b), 4.1.3(18), 4.32

Throughout the cell blocks, the tables used by detainees are not accessible to persons who use wheelchairs.

In designated accessible housing units, provide a sufficient number of accessible tables so that 5% of them in each area (but no fewer than one) are available for use by people with mobility disabilities. Each accessible table must be on an accessible route, must have knee space at the table at least 27 inches high, 30 inches wide, and 17 inches deep, and must have a table top between 28 inches and 34 inches above the floor. Ensure that the tables are distributed throughout the facility.

 

 

 

Erie County Correctional Facility - 1999 Housing Expansion (new construction)

 

 

 

 

Constant Observation

 

47

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.3(11)

The shower does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

48

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

Provide accessible cells so that at least 3% minimum of the total cells are accessible and ensure that all detainees with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards.

 

 

 

R Dormitory - General Population

 

49

213.2, 606.2

4.1.3(11), 4.19.3

The lavatory knee and toe space is 12 inches deep.

Provide a lavatory with knee and toe space that complies with the Standards. The knee and toe space shall be at least 30 inches wide and shall extend 17 to 19 inches under the lavatory. The knee and toe space may be wider than the lavatory.

50

213.2, 603.3

4.1.3(11), 4.19.6

The reflective surface of the mirror is mounted 55 inches above the floor.

Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor.

51

213.2, 604.8.1.1

4.1.3(11), 4.17.3

The toilet stall is 50 inches wide.

Provide a toilet compartment that is at least 60 inches wide.

52

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.3(11),

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

53

206.1, 303.4

4.1.6(1)(b), 4.1.2(1) & (2), 4.3.8

The accessible route to the yard is blocked by a 7 1/2 inch step. 

Establish a procedure for providing access to this program or install ramps, platform lifts, or an elevator in compliance with the Standards. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances.

 

 

 

L Dormitory - General Population

 

54

232, 807.2.3

4.1.6(1)(b), 232.3, 4.1.3

There are not a sufficient number of accessible beds.

Provide access to 5% of the beds, such that the sides of these beds are on an accessible route and there is a 30 inch by 48 inch clear floor space parallel to the side of the beds.

55

213.2, 603.3

4.1.3(11), 4.19.6

The reflective surface of the mirror is mounted 55 inches above the floor.

Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor.

56

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.3(11),

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Erie County Holding Center - 10 & 40 Delaware Ave

 

 

 

 

General

 

57

211, 602.7

4.1.6(1)(b), 4.1.3(10), 4.15.2

Many of the drinking fountains throughout the facility do not comply with the Standards.

Ensure that 50% of all drinking fountains per building (but at least 1) comply with the Standards and have a spout mounted at the front of the unit no higher than 36 inches (measured from the finished floor or ground surface to the spout outlet). Ensure that fountain controls require no more than 5 pounds of force to operate; are operable with one hand without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Additionally, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a “hi-lo” fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser; or by such other means as would achieve the required accessibility for each group of people.

58

217.3, 704.3

4.1.3(17)(b), 4.31.5(2)

None of the telephones throughout the facility have volume controls.

Provide a sufficient number of telephones such that 25% are hearing aid compatible and have a volume control mechanisms.

59

226.1, 902.2

4.1.3(18), 4.32

Throughout the facility, the tables used by both detainees and visitors are not accessible to persons who use wheelchairs.

Provide a sufficient number of accessible tables so that 5% of them in each area (but no fewer than one) are available for use by people with mobility disabilities. Each accessible table must be on an accessible route, must have knee space at the table at least 27 inches high, 30 inches wide, and 17 inches deep, and must have a table top between 28 inches and 34 inches above the floor. Ensure that the tables are distributed throughout the facility.

60

217.4.8

4.1.6(1)(b), 4.1.3(17)(c)(ii)

Throughout the facility, TTY's are not provided for detainees and for the public.

Provide at least one accessible TTY for use by detainees. Adopt policies and procedures to ensure that access afforded to the TTY for detainees with disabilities is equal to the access afforded to detainees who use the standard telephone. In addition, where detainee telephone calls are time-limited, adopt policies permitting detainees with disabilities who use TTY’s a longer period of time to make those calls, due to the slower nature of TTY communications compared with voice communications. In addition, provide at least one accessible public TTY with appropriate signage.

 

 

 

Lobby

 

61

217.2, 704.2.2

4.1.6(1)(b), 4.1.3(17)(a), 4.31.3

The highest control on the telephone is 59 inches above the floor.

Provide an accessible telephone with a clear floor space of at least 30 inches by 48 inches with the highest operable part of the telephone mounted no more than 48 inches above the floor; that is hearing aid compatible and has a volume control mechanism; with a cord of at least 29 inches long from the telephone to the handset; and with a shelf and electrical outlet. Also, provide a volume control mechanism on 25% of the other telephones in the bank.

62

205, 309.4

4.1.6(1)(b), 4.1.3(13), 4.27.4

The locker keys require tight grasping, tight pinching, or twisting of the wrist to operate.

Provide this element with mechanical controls, that can be operated with no more than 5 pounds of force and that can be used with one hand and without tight grasping, pinching, or twisting of the wrist (lever-operated, push-type, and electronically controlled mechanisms are examples of acceptable designs).

 

 

 

Lobby - Women's Room

 

63

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b)&(d), 4.1.3, 4.13.5, 4.13.9

The toilet room does not have any accessible features.

Provide an accessible toilet room such that all of the room’s elements, including door, door hardware, clear floor space, water closet, compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Lobby - Men's Room

 

64

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b)&(d), 4.1.3, 4.13.5, 4.13.9

The toilet room does not have any accessible features.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Visitation - Attorney Conference Room

 

65

206.5, 404, 904.2

4.1.6(1)(b)&(d), 4.1.3(7)&(8)& (18), 4.13.5, 4.13.6, 4.13.9, 4.32.3

The room is not accessible to a person who uses a wheelchair. 

Provide an accessible room such that all of the room's elements, including door, door hardware, clear floor space, desk (if provided) and arrangement comply with the Standards.

 

 

 

Intake Holding Cells #1 and #3

 

66

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b)&(d), 4.1.3, 4.13.5, 4.13.9

The toilet rooms do not have any accessible features.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Intake Isolation 3

 

67

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b)&(d), 4.1.3, 4.13.5, 4.13.9

The toilet room does not have any accessible features.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Intake Female Shower/Change

 

68

206.5, 404.2.3

4.1.6(1)(b)&(d), 4.1.3(7)&(8), 4.13.5

The clear opening of the shower space doorway is 31 inches.

Provide a doorway that has a minimum 32 inch clear opening width.

69

213.3.7, 305, 308, 603.4

4.1.6(1)(b), 4.1.3(13), 4.27.3

The clothes hook is 76 inches above the floor.

Provide a clothes hook between 15 and 48 inches high accompanied by clear floor space of 30 by 48 inches.

70

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11),

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Intake Male Shower/Change

 

71

206.5, 404.2.3

4.1.6(1)(b)&(d), 4.1.3(7)&(8), 4.13.5

The clear opening of the shower space doorway is 31 inches.

Provide a doorway that has a minimum 32 inch clear opening width.

72

213.3.7, 305, 308, 603.4

4.1.6(1)(b), 4.1.3(13), 4.27.3

The clothes hook is 76 inches above the floor.

Provide a clothes hook between 15 and 48 inches high accompanied by clear floor space of 30 by 48 inches.

73

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11),

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Court Holding Area #3

 

74

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b)&(d), 4.1.3, 4.13.5, 4.13.9

The toilet room does not have any accessible features.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Kitchen Area - Inmate Toilet

 

75

206.5, 213.2, 216.2, 404, 603, 604, 606, 703

4.1.6(1)(b)&(d), 4.1.3, 4.13.5, 4.13.9

The toilet room is not accessible.

Provide an accessible toilet room such that all of the room's elements, including door, door hardware, clear floor space, water closet, urinal (if provided), compartment size and arrangement (if provided), compartment door (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards.

 

 

 

Medical Dayroom Shower - Male

 

76

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.3(11)

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Medical

 

77

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

Provide accessible cells so that at least 3% minimum of the total cells are accessible and ensure that all inmates with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards.

 

 

 

Rooftop Recreation Yard

 

78

206.1, 303.4

4.1.6(1)(b), 4.1.3(1), 4.3.8

The accessible route to the recreation yard is blocked by one step.

Establish a procedure for providing access to this program or install ramps, platform lifts, or an elevator in compliance with the Standards. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances.

 

 

 

Sixth Floor Outdoor Recreation Yard (alteration)

 

79

206.1, 403.3, 405.8, 505

4.1.6(1)(b), 4.1.3(1), 4.3.7

The accessible route to the sixth floor recreation yard has a ramp at the door that rises more than 6 inches and has a slope that is significantly steeper than 8.33%. No handrails are provided.

Provide a ramp that is at least 36 inches wide with a slope not exceeding 8.33%; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp. Provide handrails that are between 1 1/4 inches and 1 1/2 inches in diameter such that the inside handrail is continuous and both handrails have a continuous gripping surface along both sides of the ramp extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface.

80

206.5, 404.2.5

4.1.6(3)(d)(ii)

The threshold on the exterior side of the door is 2 1/2 inches high.

Provide a door that has a threshold not exceeding 1/2 inch in height and, if it is greater than 1/4 inch in height, beveled with a slope no greater than 50%.

 

 

 

Short Block

 

81

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

Provide accessible cells so that at least 3% minimum of the total cells are accessible and ensure that all detainees with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards.

82

226.1, 902.2

4.1.6(1)(b), 4.1.3(18), 4.32

None of the tables in the detainee day space provides clear floor space that is at least 30 inches wide and 19 inches deep.

Provide a sufficient number of accessible tables so that 5% of them (but no fewer than one) are available for use by people with mobility disabilities. Each accessible table must be on an accessible route, must have knee space at the table at least 27 inches high, 30 inches wide, and 17 inches deep, and must have a table top between 28 inches and 34 inches above the floor. Ensure that the tables are distributed throughout the facility.

83

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11),

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Alpha - Dayroom - Female

 

84

213.2, 604.5.1

4.1.6(1)(b), 4.1.3(11), 4.16.4

The front end of the grab bar on the sidewall is only 47 1/2 inches from the rear face of the toilet/lavatory fixture.

Provide a side grab bar that is at least 42 inches in overall length, with the far end mounted at least 54 inches from the rear wall and the closer end 12 inches or less from the rear wall.

85

213.2, 608.4, 608.5

4.1.6(1)(b), 4.1.3(11),

The controls in the roll-in shower are on the opposite wall from the seat and does not comply with the Standards.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Delta North Cell Block - Mental Health

 

86

217.2, 704.2.1

4.1.6(1)(b), 4.1.3(13), 4.31.2

The clear floor space at the telephone is only 25 inches wide.

Provide an accessible telephone with a clear floor space of at least 30 inches by 48 inches that allows either a forward or a parallel approach by a person using a wheelchair such that bases, enclosures, and fixed seats do not impede approaches to the telephone.

87

205, 309.3

4.1.6(1)(b), 4.1.3(13), 4.27.3

The countertop is 37 inches high and the controls are 17 inches from the front edge. Therefore, the sink faucet is out of reach.

Provide this element in a location where there is a compliant 30 inch by 48 inch clear floor space and that the operable parts are within 48 inches of the floor. If a forward approach is required, the clear floor space may extend under an obstruction with a maximum depth of 25 inches. If the obstruction is 20 inches to 25 inches deep, the operable parts must be mounted within 44 inches of the floor. If a side approach is possible, the operable parts may be obstructed for a maximum height of 34 inches and for a maximum depth of 24 inches. When this obstruction is deeper than 10 inches the operable parts must be within 46 inches of the floor.

88

226.1, 902.2

4.1.6(1)(b), 4.1.3(18), 4.32

None of the tables provides clear floor space that is at least 30 inches wide and 19 inches deep.

Provide a sufficient number of accessible tables so that 5% of them (but no fewer than one) are available for use by people with mobility disabilities. Each accessible table must be on an accessible route, must have knee space at the table at least 27 inches high, 30 inches wide, and 17 inches deep, and must have a table top between 28 inches and 34 inches above the floor. Ensure that the tables are distributed throughout the facility.

89

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11),

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

90

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

Provide accessible cells so that at least 3% minimum of the total cells are accessible and ensure that all detainees with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards.

 

 

 

Delta Mental Health - Male

 

91

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11)

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards.

 

 

 

Delta Constant Observation - Female

 

92

213.2, 604.5.1

4.1.6(1)(b), 4.1.3(11), 4.16.4

The side grab bar is only 24 inches long. The front end is only about 30 inches from the rear face of the toilet/lavatory fixture.

Provide a side grab bar that is at least 42 inches in overall length, with the far end mounted at least 54 inches from the rear wall and the closer end 12 inches or less from the rear wall.

93

213.3.6, 608.2.2

4.1.6(1)(b), 4.1.3(11), 4.21.2

The clear floor space at the shower is blocked by the toilet.

Provide a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening.

 

 

 

Gulf East (keeplock) - Disciplinary

 

94

205, 309.3

4.1.6(1)(b), 4.1.3(13), 4.27.3

The countertop is 36 inches tall and the controls are about 17 inches from the front edge. Therefore, the sink faucet is out of reach.

Provide this element in a location where there is a compliant 30 inch by 48 inch clear floor space and that the operable parts are within 48 inches of the floor. If a forward approach is required, the clear floor space may extend under an obstruction with a maximum depth of 25 inches. If the obstruction is 20 inches to 25 inches deep, the operable parts must be mounted within 44 inches of the floor. If a side approach is possible, the operable parts may be obstructed for a maximum height of 34 inches and for a maximum depth of 24 inches. When this obstruction is deeper than 10 inches the operable parts must be within 46 inches of the floor.

95

205, 309.3

4.1.6(1)(b), 4.1.3(13), 4.27.4

The faucets on the hand washing sink requires tight grasping, tight pinching, or twisting of the wrist to operate.

Provide this element with mechanical controls, that can be operated with no more than 5 pounds of force and that can be used with one hand and without tight grasping, pinching, or twisting of the wrist (lever-operated, push-type, and electronically controlled mechanisms are examples of acceptable designs).

96

206.5, 213.2, 213.3.6, 404, 603, 608

4.1.6(1)(b), 4.1.3(11),

The shower room does not have any accessible features.

Provide a transfer shower that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards. Alternatively, provide access to an accessible shower.

 

 

 

Cell 30 - Disciplinary

 

97

28 CFR § 35.151(k), 232, 807

4.1.3(7), 4.1.3(11), 4.13, 4.16, 4.19, 4.26, 4.27, 9.2.2, Figs. 28, 29, 35, 36, 37. See also UFAS § 4.1.4(9)

There are no accessible cells. 

Provide accessible cells so that at least 3% minimum of the total cells are accessible and ensure that all inmates with disabilities are housed in accessible cells. To be accessible, all of the cells' elements, including door, clear floor space, water closet, grab bars, lavatory, mirror, bed, desk, controls, and dispensers, comply with the ADA Standards.

 

 

 

Echo Dorm. (Trustee Housing)

 

98

226.1, 902.2

4.1.6(1)(b), 4.1.3(18), 4.32

None of the tables provides clear floor space that is at least 30 inches wide and 19 inches deep.

Provide sufficient accessible tables so that 5% of them (but no fewer than one) are available for use by people with mobility disabilities. Each accessible table must be on an accessible route, must have knee space at the table at least 27 inches high, 30 inches wide, and 17 inches deep, and must have a table top between 28 inches and 34 inches above the floor. Ensure that the tables are distributed throughout the facility.

 

 

 

Echo Dorm (Trustee housing) Bathroom (alteration)

 

99

213.2, 604.5.1

4.1.6(1)(b), 4.1.3(11), 4.17.6

The front end of the side grab bar is only 48 inches from the rear wall.

Provide a side grab bar that is at least 40 inches in overall length, with the far end mounted at least 52 inches from the rear wall and the closer end 12 inches or less from the rear wall; mounted 33 to 36 inches above the finished floor; with a diameter between 1 1/4 and 1 1/2 inches; with 1 1/2 inches between the grab bar and the wall; and at least 1 1/2 inches between the grab bar and any object beside or below it and at least 12 inches between the grab bar and any object above it.

100

213.2, 604.8.1.5

4.1.6(1)(b), 4.1.3(11), 4.17.6

The rear grab bar is only 24 inches long.

Provide a 36-inch grab bar behind the toilet that extends at least 12 inches to each side of the toilet centerline; mounted 33 to 36 inches above the finished floor; with a diameter between 1 1/4 and 1 1/2 inches; with 1 1/2 inches between the grab bar and the wall; and at least 1 1/2 inches between the grab bar and any object beside or below it and at least 12 inches between the grab bar and any object above it.