Appendix 2: Summary of Requirements
Key:
ABRA -- Access Board Regulatory Assessment of Final ADA/ABRA Guidelines (July 2004).
ADAAG -- Americans with Disabilities Act and Architectural Barriers Act Accessibility Guidelines (July 2004).
DOJ Final Rules – Department of Justice Final Rules - 2010 ADA Standards for Title II (28 C.F.R. part 35) and Title III (28 C.F.R. part 36).
IBC -- International Building Code.
UFAS -- Uniform Federal Accessibility Standards.
1991 Standards -- DOJ ADA Standards for Accessible Design (28 C.F.R. part 36, App. A)
ENTRANCES, DOORS AND ROUTES
(1) Public Entrances
ABRA 6.4. ADAAG 206.4.1; 404.
At least 60% of public entrances in newly constructed facilities will be required to be accessible.The current requirement requires 50% of public entrances to be accessible, plus additional entrances so the total number of accessible public entrances is equal to the number of required exits (based on building or fire codes; typically two), but not exceeding the total number of planned public entrances. For most facilities, it is likely to have no effect. However, for large facilities such as arenas, stadiums, convention centers, and shopping malls that are required to have many exits and plan to use them as public entrances/exits, this change will likely result in fewer accessible entrances than the current standard would have required. The revision will have no effect on altered or existing facilities.
(2) Maneuvering Clearance or Standby Power for Automatic Doors
ABRA 7.8. ADAAG 404.3.2.
Neither the 1991 Standards nor the Final Rules require automatic doors to be installed. However, when a facility installs an automatic door and it serves as part of an accessible means of egress, the door will now be required to have sufficient maneuvering clearance unless stand-by power is provided or the door/gate remains open when the power is off. Currently, maneuvering clearance is not required for accessible egress doors even if no stand-by power is provided and there is no open-when-off feature. ABRA 7.8 states that this requirement would have limited application and would primarily affect in-swinging automatic doors that serve small spaces with an occupant load of less than 50 persons.
(3) Automatic Door Break-Out Openings
ABRA 6.24. ADAAG 404.1; 404.3; 404.3.1; 404.3.6, Exception.
Automatic doors that are part of a means of egress without standby power will be required to provide 32 inch minimum break out openings (“swing out” option) when operated in emergency mode (unless there are manual swinging doors serving the same means of egress). ABRA 6.23 states that most automatic doors already comply with this requirement.
(4) Thresholds at Doorways
ABRA 6.22. ADAAG 404.1; 404.2.5, Exception.
Exterior sliding doors that are part of an accessible route [1] will have to provide lower (1/2 inch) thresholds (currently 3/4 inch). The revision maintains the current exception for existing thresholds that do not exceed 3/4 inch and are beveled on each side, and so will effect no change for altered or existing facilities. The revision effects no change for interior sliding doors, which are currently required to provide ½ inch thresholds.
(5) Door and Gate Surfaces
ABRA 6.22. ADAAG 404.1; 404.2.10, Exceptions 2, 4.
Swinging doors and gates except tempered glass doors without stiles will be required to meet technical requirements (smooth surfaces on lowermost 10 inches) so that individuals who use wheelchairs can open these doors/gates without creating a trap or pinch point. Currently, there is no requirement with respect to the surface features of doors. Existing doors and gates are specifically exempted. ABRA 6.22 states that most doors are thought to be in compliance.
(6) Location of Accessible Routes
ABRA 6.3. ADAAG 206.3.
An accessible route will have to coincide with or be located in the same area as the circulation path [2] used by the general public. Currently, accessible routes must coincide with general circulation paths to the maximum extent feasible. Because, by statute, altered facilities need only comply with accessibility requirements to the maximum extent feasible, this revision effects no change for altered or existing facilities.
(7) Common Use Circulation Paths in Employee Work Areas
ABRA 6.2. ADAAG 203.9; 206.2.8; 403.5, Exception; 405.5, Exception; 405.8, Exception Common use circulation paths within employee work areas will have to comply with the technical requirements for accessible routes, with specific exceptions provided where compliance may be difficult due to the size, arrangement, location or function of the work area. Currently, employee work areas are only required to permit individuals with disabilities to approach, enter, and exit. However, common use areas (which do have to be accessible) such as employee toilet or locker rooms, break rooms, kitchenettes, and the exits serving these spaces, are often located in areas adjacent to or interspersed with employee work areas. This requirement does not apply to barrier removal because it involves areas used exclusively by employees.
(8) Accessible Means of Egress
ABRA 6.7. ADAAG 207.1, Exception 1; 216.4.
The Final Rules incorporate by reference the International Building Code (IBC) [3] requirements for accessible means of egress. The 1991 Standards generally incorporate scoping and technical requirements of local codes instead of the IBC; according to ABRA 6.7, these codes are the same as the IBC in most respects.
(9) Stairs (NC)
(10) Stairs (ALT/BR)
ABRA 6.10. ADAAG 210.1, Exception 2; 504.2.
All stairs that are part of a means of egress will have to comply with the requirements for accessible stairs, which cover treads, risers, and handrails. For purposes of alterations, however, where levels are connected by an accessible route, only the handrail requirement applies. Under the 1991 Standards the requirements for stairs do not apply to stairs serving levels that are otherwise connected by an accessible route (e.g., an elevator).
(11) Handrails along Walkways
ABRA 6.20. ADAAG 403.6.
Handrails on non-ramp walkways, while not required, if installed will be subject to accessibility requirements (including height, gripping surface, and clearance requirements). Currently, the technical requirements for handrails only apply to handrails that are themselves required (e.g., for ramps and accessible routes with a slope steeper than 1:20).
(12) Handrails
ABRA 5.22. ADAAG 505.5 thru 505.10
The technical requirements for handrails in the Final Rules will be more flexible as compared to the current standards. These more flexible requirements apply, for example, to the distance between handrail gripping surfaces and other surfaces (currently exactly 1.5 inches; revised a minimum of 1.5 inches) and a wider range of approved handrail gripping surface diameters. This revised provision also eliminates the requirement for a horizontal section of handrail at the bottom of stairs.
(13) Accessible Routes from Site Arrival Points and Within Sites
ABRA 5.3. ADAAG 206.2.1, Exception 2; 206.2.2, Exception.
With respect to areas within sites or between an entrance and site arrival point that can only be accessed by vehicle (such as the roads and parking areas of many suburban “big-box” retail shopping malls), facilities will be exempt from providing a pedestrian accessible route. Currently buildings and facilities on a site are required to be connected by an accessible route even if sidewalks are not provided.
LIFTS/ELEVATORS
(14) Standby Power for Platform Lifts
ABRA 7.2. ADAAG 207.2.
Where a platform lift is used as part of an accessible means of egress, it will be required to have a back-up power source. Currently, such lifts are not required to have back-up power.
(15) Power-Operated Doors for Platform Lifts
ABRA 7.9. ADAAG 410.6.
Platform lifts will be required to have power-operated doors with the exception of lifts that serve no more than two landings which are permitted to have self-closing manual doors on opposite ends. Current standards permit either maneuvering space or power-operated doors. ABRA 7.9 states that platform lifts typically do serve only one or two landings and do have self-closing manual doors on both sides.
(16) Alterations to Existing Elevators
ABRA 6.6. ADAAG 206.6.1.
When an element in an existing elevator is altered, the same element will have to be altered in any other elevators that are programmed to respond to the same call button. Currently, only elements being altered have to be made accessible.
(17) Platform Lifts in Hotel Guest Rooms and Dwelling Units
ABRA 5.8. ADAAG 206.7; 206.7.6.
A multi-story hotel guest room or residential dwelling unit that is required to be accessible will be allowed to use a platform lift in lieu of an elevator as part of the accessible route. Under the current standard, only elevators would be permitted.
(18) Limited Use/Limited-Application Elevators (LULA) and Private Residence Elevators
BRA 5.7. ADAAG 206.2.3, Exceptions 1-2; 206.6, Exceptions 1-2; 206.7
Facilities that are not required to install an elevator but that plan one anyway will be permitted to install a LULA instead. This provision will also permit private residence elevators to be used in a multi-story residential dwelling unit. The revision will affect multi-story facilities that meet the elevator exemption in ADAAG 206.2.3 or 206.7.
PARKING LOTS, GARAGES AND LOADING ZONES
(19) Van Accessible Parking Spaces
ABRA 7.3. ADAAG 208.2.4.
One in six (rather than one in eight) accessible spaces is required to be van accessible. This will only affect facilities with more than 200 parking spaces. ABRA 7.3 states that facilities that are required to provide only two van accessible spaces (those with 600 or fewer total parking spaces) may not incur increased cost where the two spaces are placed together and share a common access aisle.
(20) Valet Parking
ABRA 6.9. ADAAG 208.2.Facilities with valet-only parking services, which currently must provide an accessible passenger loading zone but are not required to provide accessible parking spaces, will now have to provide accessible parking spaces as well.
(21) Mechanical Access Parking Garages
ABRA 6.9. ADAAG 209.4-5.
Mechanical access parking garages [4] will no longer be exempt from providing an accessible passenger loading zone; these loading zones, will be required at vehicle drop-off and pick-up areas.
(22) Direct Access Entrances from Parking Structures
ABRA 6.5. ADAAG 206.4.2.
All (rather than one) direct pedestrian connections from a parking structure to a facility will be required to be accessible. For large facilities such as shopping malls, this may result in more accessible entrances than would otherwise be required by ADAAG 206.4.1.
(23) Passenger Loading Zones
ABRA 6.8. ADAAG 209.2.1; 503.2-4.
Facilities that provide one long continuous passenger loading zone will have to provide one accessible passenger loading zone for every 100 feet of loading space. Access aisles will have to be on the same level as the vehicle pull-up space (currently can be on a sidewalk with a curb ramp). ABRA 6.8 states that this requirement is designed to apply to airports, where loading zones more than 100 feet long are common.
(24) Parking Spaces
ABRA 5.9. ADAAG 208.1, Exception.
This provision clarifies that parking spaces designated for the exclusive use of buses, delivery vehicles, law enforcement vehicles and the like are not required to be accessible. Parking lots containing such spaces, however, if they are accessed by the public, will have to have an accessible loading zone.
(25) Parking Spaces (Signs)
ABRA 5.9. ADAAG 216.5, Exceptions 1-2.
Facilities with four or fewer parking spaces and residential facilities with assigned parking spaces will no longer be required to identify accessible parking spaces (including the van accessible space) with signs displaying the International Symbol of Accessibility.
(26) Passenger Loading Zones at Medical Care and Long-Term Care Facilities
ABRA 5.10. ADAAG 209.3.
Where a medical or long-term care facility offers periods of stay longer than 24 hours, it is required to provide at least one passenger loading zone at an accessible entrance. Currently, these accessible loading zones are required to have a canopy or roof overhang. Under the revised provision, they will not.
BATHROOMS
(27) Ambulatory Accessible Toilet Compartments
ABRA 7.4. ADAAG 213.3.1; 604.8.2.
In multi-user men’s toilet rooms where the number of toilet compartments and urinals equals six or more, at least one toilet compartment will have to be ambulatory accessible. The 1991 Standards currently count only toilet compartments for this purpose; ABRA 7.4. states that the change is intended to create parity with multi-user women’s toilet rooms.
(28) Water Closet Clearance in Single-User Toilet Rooms with Out-Swinging Doors
ABRA 7.10. ADAAG 604.3.
This provision only represents a change for single-user toilet rooms that have a lavatory installed adjacent to the water closet; this number represents rooms with out-swinging doors. For such toilet rooms, the water closet will now have to provide clearance for both a forward and a parallel approach (the current provision permits one or the other), and the lavatory will no longer be permitted to overlap the water closet clearance, except in special dwelling unit cases.
(29) Shower Spray Controls
ABRA 7.11. ADAAG 607.6; 608.6.
In accessible bathtubs and shower compartments, the revised standards require shower spray controls to have an on/off control and to deliver water that is 120°F (49°C) maximum. Currently, neither feature is required. Meeting the latter specification will require either controlling the maximum temperature at each shower spray unit or at the hot water supply.
(30) Urinals
ABRA 5.13. ADAAG 213.3.
In men's toilet rooms with only one urinal, an accessible urinal will no longer be required. Currently, where a toilet room provides only one urinal, it must be accessible. Because an inaccessible urinal has limited clear floor space, it is inaccessible not only to wheelchair users but also to ambulatory users who walk with crutches or a cane. Such toilet rooms will still be required to provide an accessible toilet compartment.
(31) Multiple Single-User Toilet Rooms
ABRA 5.12. ADAAG 213.2, Exception 4.
Where multiple single-user toilet rooms are clustered in a single location, 50% (rather than 100%) will be required to be accessible. Among the types of facilities to which this will likely apply are medical facilities where multiple single-user toilet rooms are provided for specimen collection. Accessible single-user toilet rooms will have to be identified by the international symbol of accessibility.
(32) Water Closet Clearance in Single-User Toilet Rooms with In-Swinging Doors
ABRA 5.23. ADAAG 603.2.3, Exception 2; 604.3
This provision only represents a change for single-user toilet rooms that have a lavatory installed adjacent to the water closet; this number represents rooms with in-swinging doors. For such toilet rooms, the water closet will now have to provide clearance for both a forward and a parallel approach (the current provision permits one or the other), and the lavatory will no longer be permitted to overlap the water closet clearance, except in special dwelling unit cases. The in-swinging doors will be permitted to swing into the clearance around any fixture, as long as clear floor space is provided within the toilet room beyond the door's arc.
(33) Water Closet Location and Rear Grab Bar
ABRA 5.24. ADAAG 604.2; 604.5.2, Exception 1.
The revised provision will allow greater flexibility for the placement of the centerline of water closets, and will also permit a shorter grab bar where there is not enough space due to special circumstances (e.g., because a lavatory is located next 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). The 1991 Standards contain no exception for grab bar length, and require the centerline to be exactly 18 inches from the side wall, while the revised requirement will allow the centerline to be between 16 and 18 inches from the wall.
(34) Patient Toilet Rooms
ABRA 5.19. ADAAG 223.1, Exception.
Toilet rooms that are part of critical or intensive care patient sleeping rooms will no longer be required to provide mobility features.
COMMON ELEMENTS
(35) Drinking Fountains
ABRA 6.11. ADAAG 211.2, Exception; 211.3, Exception; 602.2, Exception; 602.4; 602.7.
Drinking fountains will be required to provide a forward approach only (with knee and toe clearance) unless they are used exclusively by children. The 1991 Standards permit both parallel and forward approaches. ABRA 6.11 states that the forward approach is more common in new drinking fountains.
(36) Sinks
ABRA 6.12. ADAAG 212.1.3; 606.2, Exception.
(Note: Sinks are used in places like kitchens, and are distinguished from lavatories, which are used in places like toilet and locker rooms.)
The 1991 Standards provide technical specifications but no scoping requirement for sinks, which are only subject to the general rule for unscoped elements (“a reasonable number, but at least one”). Under the revised provision, at least 5% of sinks in each accessible space will be required to be accessible. Both the 1991 Standards and the Final Rules permit the clear floor space for sinks to be positioned for a parallel approach, but the revised provision makes an exception for spaces that include a cook top or conventional range, which will have to be positioned for a forward approach.
(37) Side Reach
ABRA 6.19. ADAAG 205.1; 228.1-2; 308.3; 309.3.
Compared to the current requirement, the revised side reach requirement will have a lower maximum (48" instead of the current 54") and higher minimum (15" instead of 9"). The requirement will apply to operable parts on accessible elements located on accessible routes, and to elements in accessible rooms and spaces. Elements and operable parts and controls that could be affected by the revised side reach requirements include: electrical outlets; thermostats; fire-alarm pull stations; card readers; keypads; coat hooks; window control hardware; paper towel dispensers and hand dryers in toilet rooms; ATMs; and at least one in each group of depositories, vending machines, change machines, and gas pumps (with a specified exception). (Elements may comply with either the side or forward reach requirement.)
(38) Sales and Service Counters (NC)
(39) Sales and Service Counters (ALT)
ABRA 5.26. ADAAG 904.4, Exception; 904.4.1, Exception; 904.4.2.
For counters providing a forward approach, the revised requirement will permit the counter to be shorter in length, by 6 inches, than currently required (30" instead of the current 36"). Altered facilities could install even shorter (24”) counters if longer counter lengths would require reducing the number of existing counters.
(40) Washing Machines (technical and scoping)
(41) Clothes Dryers (technical and scoping)
ABRA 5.21. ADAAG 214.2-3; 611.3; 309.3; 309.3.2, Exception 1.
The revised requirements specify the number of machines of each type required to be accessible (1-2 depending upon the total number provided). An exception permits the maximum height for the tops of these machines to be 2 inches higher than the general requirement for high reach maximums over an obstruction. ABRA 5.21 states that the exception is designed to accommodate the height of currently available machines.
(42) Self-Service Storage Facility Spaces
ABRA 5.20. ADAAG 225.3.
The revised requirements specify the number of storage spaces required to be accessible; i.e., 5% of the first 200 storage spaces and 2% of the excess over 200. Currently, only one storage unit in each class is required to be accessible.
(43) Limited Access Spaces and Machinery Spaces
ABRA 5.1. ADAAG 203.4-5.
The revised requirement exempts spaces that either have limited means of access (catwalks, crawl spaces, etc.) or are visited only by service personnel, even if such spaces are nonetheless “occupiable.” The current provision only exempts such spaces if both conditions apply and the space is “non-occupiable.”
(44) Operable Parts
ABRA 5.2. ADAAG 205.1, Exceptions.
Various exceptions will be added to the requirement that operable parts be accessible, including exceptions for operable parts to be used solely by service or maintenance personnel, redundant controls (except for light switches), extra outlets along an uninterrupted kitchen counter, floor electrical receptacles, outlets for dedicated use, and HVAC diffusers.
(45) Bathrooms in Accessible Guest Rooms (vanities and water closet clearances)
ABRA 7.10. ADAAG 604.3 (water closet clearances) & ABRA 7.13. ADAAG 806.2.4.1 (transient lodging guest room vanities)
Due to considerations unique to bathrooms in mobility-accessible guest rooms in transient lodging facilities (i.e., inns, hotels, and motels), the specifications in the Final Rules for water closet clearances and comparable guest room vanities are addressed collectively in this requirement. With respect to water closet clearances: This requirement only represents a change for a single-user toilet room in a mobility-accessible guest room that has a lavatory installed adjacent to the water closet; this requirement assumes the toilet room has an out-swinging door. For such toilet rooms, the water closet will now have to provide clearance for both a forward and a parallel approach (the current standard permits one or the other), and the lavatory will no longer be permitted to overlap the water closet clearance. With respect to vanities: If vanity countertop space is provided in a toilet or bathing room in a lodging facilities’ mobility-accessible guest room, vanity counter top space that is comparable, in terms of size and proximity to the lavatory, will be required. This requirement may make the mobility-accessible bathroom more usable to all hotel guests.
(46) Operable Windows
ABRA 7.6. ADAAG 229.1.
In accessible rooms where the windows are intended to be opened by the occupants, at least one window will have to be accessible (i.e., meet the technical requirements for operable windows). An exception applies to accessible rooms in public dwelling units. This requirement does not apply to windows intended to be opened by employees. The revision will primarily affect hotel guest rooms, dorm rooms and patient sleeping rooms with mobility features because windows in most other types of facilities are intended to be opened by service or maintenance personnel and not the occupants.
(47) Dwelling Units with Communication Features [1991 Standards]
(48) Dwelling Units with Communication Features [UFAS]
ABRA 7.14. ADAAG 809.5; 708.4.
At least 2% of public housing units will be required to provide communication features. Communication features include peepholes and doorbells with both audible and visual signals at primary entrances (if provided within sleeping quarters, turn-off switch required); voice and TTY at entrance (if voice communication provided at entrances); extension of system wiring to smoke detection systems within these units (if alarm system provided in building); extension of visual alarms (if provided) into these units and building area where units are located.
(49) Galley Kitchen Clearances
ABRA 7.12. ADAAG 804.2.
The revised requirement clarifies what constitutes a “pass-through” kitchen, but makes no changes to clearance requirements. This clarification means that “galley” style kitchens that do not have two entrances must meet the greater (60 inches) clearance requirements of “u-shaped” kitchens. Spaces without a cook top or conventional range will be exempt from kitchen clearance requirements. ABRA 7.12 states that this revision primarily affects “galley” kitchens without two entrances in dwelling units with mobility features. The 1991 Standards do not provide any requirement with respect to kitchen clearances.
(50) Shower Compartments in Hotel Guest Rooms with Mobility Features
ABRA 5.25. ADAAG 608.1; 608.2.1; 608.2.3; 608.4; 608.5.3; 608.7,
Exception.
The revised requirement will provide more flexible specifications for transfer-type and roll-in showers. Specifications for transfer-type showers (which must be 36" x 36") will accommodate molded compartments with rounded bottom edges and permit a higher maximum curb (as high as 2 inches; otherwise only a ½ inch) in altered facilities where structural reinforcement of the floor slab would otherwise be disturbed. “Alternate” roll-in showers (larger than standard roll-in showers --at least 36" x 60," rather than 30" x 60," with a 36" opening on the long side) which are currently permitted only in hotel rooms and require the shower controls to be located adjacent to the seat on the long side, will now be permitted in all facilities and will permit the controls to be located elsewhere. Also, a low curb (up to ½ inch high) will be allowed in roll-in showers, which may reduce usability for some while improving the containment of water in some installations.
ASSEMBLY AREAS
(51) Location of Accessible Route to Stages
ABRA 7.1. ADAAG 206.2.6.
For stages where the circulation path (for the general audience) directly connects the stage to the seating area, the accessible route also will have to be direct. Currently, an accessible route connecting accessible seating locations to performing areas may go outside the assembly area and use an indirect interior accessible route.
(52) Wheelchair Space Overlap in Assembly Areas
ABRA 6.26. ADAAG 802.1.4, 802.1.5.
Wheelchair spaces will not be permitted to overlap accessible routes or circulation paths. Currently, although accessible routes and circulation paths are not supposed to be obstructed by any object, this requirement was not explicit.
(53) Lawn Seating in Assembly Areas
ABRA 6.15. ADAAG 221.5.
Lawn seating and exterior overflow seating areas without fixed seats will have to connect to an accessible route. The accessible route does not, however, have to extend through the lawn seating area.
(54) Handrails on Aisle Ramps in Assembly Areas
ABRA 5.11. ADAAG 210.1, Exception 3; 405.1, Exception.
Handrails on aisle ramps adjacent to seating in assembly areas that are part of an accessible route to accessible seating or other accessible elements, which are required to be on only one side of the ramp (the side that is not adjacent to the seats), will be permitted to be discontinuous and need not have extensions beyond the ramp where the handrails must be discontinuous to allow access to seating and aisle crossing.
(55) Wheelchair Spaces in Assembly Areas
ABRA 5.18. ADAAG 221.2; 221.2.1-3.
A revised formula will reduce the number of wheelchair spaces required in larger assembly areas with fixed seating. This revised formula provides 6 wheelchair spaces for the first 500 seats; 1 space for each 150 seats for the next 500 to 5000 seats; and 1 space for each 200 seats in excess of 5000 seats. The revision will also clarify that these requirements should be applied separately to each type of seating. The current formula provides for 6 wheelchair spaces for the first 500 seats and then 1 space for each 100 seats in excess of 500.
(56) Accessible Route to Tiered Dining Areas in Sports Facilities
ABRA 5.4. ADAAG 206.2.5, Exception 3.
An accessible route will have to be provided to 25% of tiered dining areas. Each tier will have to provide the same services and the accessible route will have to serve accessible seating. Currently, all newly constructed tiered dining areas must be accessible, while in alterations, tiered dining areas are not required to be made accessible as long as the same services and décor are provided on an accessible level that is usable by the general public.
(57) Accessible Route to Press Boxes
ABRA 5.4. ADAAG 206.2.5, Exception 3.
Where the aggregate area of all press boxes does not exceed 500 square feet, small press boxes that are located on bleachers with entrances on only one level and freestanding small press boxes elevated more than 12 feet will be exempted from accessibility requirements. ABRA 5.5 states that this new exception was designed to apply to high school sports facilities; it could affect smaller facilities at colleges as well.
EFFECTIVE COMMUNICATION
(58) Public TTYs
ABRA 7.5. ADAAG 217.4.
For interior pay phones in private facilities, at least one public TTY will be required in facilities with more than 4 public pay phones (per building and/or per floor) and in banks of 4 or more phones. For interior pay phones in government facilities, at least one public TTY will be required in facilities with at least one public pay phone in a public use area (per building and/or per floor) and in banks of 4 or more phones. (For both types of facilities, this requirement will not apply if there is another bank of telephones containing a public TTY within 200 feet and on the same floor.) For exterior pay phones in both types of facilities, at least one public TTY is required on a site with 4 or more public pay phones in an exterior location. The 1991 Standards require TTYs in these facilities but not on each floor that has four or more (or one or more, for government facilities) public phones. New with this revision is the requirement for a TTY wherever there are banks of four or more telephones (except as specified) and at all public rest stops that have a public pay phone.
(59) Public Telephone Volume Controls
ABRA 6.13. ADAAG 217.3; 704.3.
All public pay phones (interior and exterior) will be required to have volume controls; identifying signs will no longer be required. The revision will also expand the volume increase range. ABRA 6.13 states that these are the same technical requirements now in effect under other accessibility laws.
(60) Two-Way Communication Systems
ABRA 7.7. ADAAG 230.1; 708.
Two-way communication systems at entrances used to gain admission to a facility or a restricted area inside a facility will be required to have visible as well as audible signals. Handsets, if provided, will be subject to minimum handset cord length requirements.
(61) ATMs and Fare Machines
ABRA 6.26. ADAAG 707.
Revision will add specific technical requirements for privacy, speech output, tactilely discernable input controls, display screens, and Braille instructions to current general accessibility requirements. Exceptions will be made that relate to the type of network or information provided (for example, audible tones will not be required for visible output where privacy is desirable). The 1991 Standards require these machines to be accessible to and independently usable by persons with vision impairments, but do not contain any technical specifications.
(62) Assistive Listening Systems (Technical)
ABRA 6.25 and 5.17. ADAAG 706, 219.3, Exception 2.
Assistive listening systems (ALS) will now be required to meet certain technical requirements (such as standard mono jacks and specifications for sound level pressure, signal-to-noise ratio, and peak clipping levels). In addition, a new provision requires 25% (minimum 2) of the ALS receivers provided by an assembly areas to be hearing-aid compatible unless the assembly area uses an induction loop assistive listening system. ABRA 6.25 states that currently available assistive listening systems meet the new specifications.
(63) Visible Alarms in Alterations to Existing Facilities
ABRA 5.14. ADAAG 202.3; 215.1, Exception.
New exception will require visible alarms to be added to existing fire alarm systems only when systems are upgraded or replaced, or when a new system is installed.
(64) Detectable Warnings (scoping) and
(65) Detectable Warnings (technical)
ABRA 5.27. ADAAG 218.2-3; 810.5; 810.5.2; 705.1.1-3; 705.2.
Curb ramps, hazardous vehicular areas, and reflecting pools will no longer be subject to the requirement for detectable warnings. Detectable warnings will still be required at transit platform edges. New technical requirements will be added for detectable warnings. This requirement has been suspended in part during much of the period since its adoption and is being reconsidered by the Access Board under another set of guidelines.
(66) Assistive Listening Systems (Scoping)
ABRA 5.17. ADAAG 219.2, Exception; 219.3, Exceptions 1-2.
Revised formula will reduce the number of receivers required for assistive listening systems in larger assembly areas. Revised formula will require the number of receivers to equal 4% (minimum 2) of the seats for the first 500 seats, 3% of the next 501-1000 seats, 2% of the next 1001-2000 seats, and 1% of seats over 2000. (Current formula requires the number of receivers to equal 4% (minimum 2) of all the seats, with no change in formula for larger areas). Multiple assembly areas within one facility and under the same management will be able to calculate the number of receivers based on total seats in the facility. Assembly areas (except courtrooms) without audio amplification systems will no longer be required to provide assistive listening systems (currently assistive listening systems are required in all assembly areas that have an occupant load of at least 50 people).
STATE AND LOCAL JUDICIAL, DETENTION AND CORRECTIONAL FACILITIES
(67) Accessible Courtroom Stations
ADAAG 231.2; 808 (also 304, 305, and 902).
Clear floor space for a forward approach will be required for all courtroom stations (judges’ benches, clerks’ stations, bailiffs’ stations, deputy clerks’ stations, court reporters’ stations and litigants’ and counsel stations). Other accessibility specifications will include accessible work surface heights and toe and knee clearance.
(68) Accessible Attorney Areas and Witness Stands
ADAAG 206.2.4.
Vertical access by ramp, elevator, or platform lift will have to be fully in place at time of construction or alteration. (Members of the public who need vertical access could appear at any time as members of the jury, attorneys, or witnesses.)
(69) Raised Courtroom Stations Not for Members of the Public
ADAAG 206.2.4, Exception 1.
Raised courtroom stations that are used by judges, clerks, bailiff, and court reporters will not have to provide full vertical access when first constructed or altered if they are constructed to be easily adaptable to vertical accessibility. (The need for vertical access to these stations will be known far enough in advance to add the actual access when effective.)
EXERCISE FACILITIES
(70) Accessible Route to Exercise Machines and Equipment
ABRA–REC Chapters 9 and (court sports) 11. ADAAG 206.2.13.
An accessible route must serve fixed exercise machines and equipment that are required to be accessible.
(71) Accessible Exercise Machines and Equipment
ABRA–REC Chapters 9 and (court sports) 11. ADAAG 236; 1004.
One of each type of exercise machine must meet clear floor space specifications. Types of machines are generally defined according to the muscular groups exercised or the kind of cardiovascular exercise provided.
(72) Accessible Saunas and Steam Rooms (NC) &
(111) Accessible Saunas and Steam Rooms (ALT/BR)
ABRA–REC Chapter 10. ADAAG 241; 612.
Saunas and steam rooms will be required to meet accessibility requirements, including accessible turning space and an accessible bench. Where they are provided in clusters, 5% but at least one sauna or steam room in each cluster will have to be accessible.
(73) Accessible Lockers
ABRA–REC Chapters 9 and (court sports) 11. ADAAG 225.2.1; 811.
Lockers will be required to be accessible. Where lockers are provided in clusters, 5% but at least one locker of each type (e.g., full-length, half-length, etc.) in each cluster will have to comply. Under the current standard, only one locker of each type provided is required to be accessible. Therefore, this requirement represents a change only for facilities with more than 20 of a particular type of locker in a cluster.
(74) Accessible Dressing Rooms, Fitting Rooms, or Locker Rooms
ABRA–REC Chapters 9 and (court sports) 11. ADAAG 222; 803.
Dressing rooms, fitting rooms, and locker rooms will have to be accessible. Where rooms are provided in clusters, 5% but at least one of each type of room in each cluster will have to be accessible.
OTHER RECREATIONAL FACILITIES
(75) Wheelchair Space in Team or Player Seating Areas
One or more wheelchair spaces will be required in each team or player seating area with fixed seats, depending upon the number of seats provided for spectators. For bowling lanes, the requirement will be limited to lanes required to be accessible.
(76) Accessible Route in Court Sport Facilities
ABRA–REC Chapters 9 and (court sports) 11. ADAAG 206.2.12.
Each area of sport activity (e.g., courts and playing fields, whether indoor or outdoor) will have to be served by accessible route. In court sports, the route will also have to directly connect both sides of court.
(77) Accessible Route to Bowling Lanes
ABRA–REC Chapters 9 and (court sports) 11. ADAAG 206.2.11.
An accessible route will be required to each bowling lane. Where bowling lanes are provided in clusters, 5% but at least one lane in each cluster will have to be accessible. This requirement will only represent a change for bowling facilities with more than 20 lanes per cluster.
(78) Shooting Facilities with Firing Positions
ABRA–REC Chapters 9 and (court sports) 11. ADAAG 243; 1010.
An accessible turning space will be required for each different type of firing position at a shooting facility if designed on site. Where firing positions are provided in clusters, 5% but at least one position of each type in each cluster will have to be accessible. This requirement will only represent a change for shooting facilities with more than 20 firing positions of a particular type per cluster.
(79) Primary Accessible Means of Entry to Pools (NC/ALT) &
(112) Primary Accessible Means of Entry to Pools (BR)
ABRA–REC Chapter 10. ADAAG 242.2; 1009.2-1009.3.
Swimming pools generally will be required to have at least one accessible means of entry. This primary accessible entry must be either a pool lift or a sloped entry. Larger swimming pools (i.e., those with over 300 linear feet of pool wall) must also provide a second accessible means of entry which is addressed separately in Requirement ## 115 & 116.
(80) Accessible Means of Entry to Wading Pools[5]
ABRA–REC Chapter 10. ADAAG 242.3; 1009.3.
At least one sloped means of entry will be required into the deepest part of each wading pool.
(81) Accessible Means of Entry to Spas (including hot tubs)
ABRA–REC Chapter 10. ADAAG 242.4; 1009.2, 4, 5.
Spas will be required to meet accessibility requirements, including an accessible means of entry. Where spas are provided in clusters, 5% but at least one spa in each cluster will have to be accessible. Either a pool lift, a transfer wall, or transfer system will be permitted.
RECREATIONAL BOATING FACILITIES AND FISHING PIERS[6]
(82) Accessible Route to Boating Facilities
206.2.10; 1003.2
New Construction Requirement: An accessible route will be required to all accessible boating facilities, including boat slips and boarding piers at boat launch ramps. If gangways (only one end of route is attached to land) and floating piers (neither end is attached to land) are involved, a number of exceptions from the general standards for accessible routes will be provided in order to take into account the difficulty of meeting accessibility slope requirements due to fluctuations in water level.
Alterations Requirement: Where an existing gangway or series of gangways is replaced or altered, an increase in the length of the gangway shall not be required except to the extent required by the path of travel requirement.
(83) Accessible Boarding Piers (NC) &
(84) Accessible Boarding Piers (ALT/BR)
ABRA–REC Chapter 5. ADAAG 235.3; 1003.2-3.
If provided at boat launch ramps, 5% of boarding piers, but at least one, will have to be accessible. Accessible boarding piers must comply with the requirements for accessible boat slips for the entire length of the pier. Clear pier space at least 60" wide and at least as long as boat slip. Every 10' maximum of linear pier edge must contain at least one continuous clear opening at least 60" wide. (Exception permitting clear pier space to be 36" wide for length of up to 24", provided that multiple 36" wide segments are separated by segments that are at least 60" clear in width and length.) Permits edge protection up to 4" high and up to 2" deep at continuous pier openings. Cleats and other boat securement devices are not required to comply with height provisions for controls and operating mechanisms.
(85) Accessible Boat Slips (NC) &
(86) Accessible Boat Slips (ALT/BR)
ABRA–REC Chapter 5. ADAAG 235.2; 1003.3.1.
New Construction Requirement: A specified number of boat slips in each recreational boating facility will be required to meet specified accessibility standards and to be dispersed throughout the boat slip area and among the various types of slips provided. The scoping ranges from 1 accessible boat slip for facilities with 25 or fewer boat slips to 12 accessible boat slips for facilities with 901 to 1000 boat slips (plus 1 additional accessible boat slip for each 100 boat slips over 1000). Where the number of boat slips is not identified, each 40 feet of boat slip edge provided along perimeter of pier counts as one boat slip. Increase in number of accessible boat slips not required. Clear pier space at least 60" wide and at least as long as boat slip. Every 10' maximum of linear pier edge must contain at least one continuous clear opening at least 60" wide. (Exception permitting clear pier space to be 36" wide for length of up to 24", provided that multiple 36" wide segments are separated by segments that are at least 60" clear in width and length.) Permits edge protection up to 4" high and up to 2" deep at continuous pier openings. Cleats and other boat securement devices are not required to comply with height provisions for controls and operating mechanisms.
Alterations Requirement: In existing piers, clear pier space may be perpendicular to and extend the width of the boat slip if the facility has at least one accessible boat slip and providing more will reduce the total number (or widths) of boat slips.
(87) Accessible Route to Fishing Piers
ABRA–REC Chapter 6. ADAAG 206.2.14; 1005.1.
New Construction Requirement: An accessible route will be required to each accessible fishing pier and platform. The exceptions described under recreational boating will apply to gangways and floating piers.
Alterations Requirement: Where an existing gangway or series of gangways is replaced or altered, an increase in the length of the gangway shall not be required except to the extent required by the path of travel requirement.
(88) Accessible Fishing Piers and Platforms
ABRA–REC Chapter 6. ADAAG 237; 1005.
At least 25% of railings will be required to be no higher than 34" high (so that a person seated in a wheelchair could reach over the railing) and dispersed among the piers and platforms. If railings, guards, or handrails are provided, accessible edge protection, clear floor or ground space, and turning space will be required. An exception permits railings to comply, instead, with the IBC provision, which permits railings to be 42" high.
GOLF AND MINIATURE GOLF COURSES
(89) Accessible Route to Golf Courses
ABRA–REC Chapter 4. ADAAG 206.2.15; 1006.2-3.
An accessible route will be required to connect all accessible elements within the boundary of the golf course and, in addition, to connect golf car rental areas, bag drop areas, teeing grounds, putting greens, and weather shelters. An exception permits the accessible route requirements to be met, within the boundaries of the golf course, by a "golf car passage" (the path typically used by golf cars) if specifications for width and curb cuts are met.
(90) Accessible Teeing Grounds, Putting Greens, and Weather Shelters at Golf Courses (ALT/BR)
ABRA–REC Chapter 4. ADAAG 238.2; 1006.4.
Golf cars will have to be able to enter and exit each putting green, each weather shelter, and, for each hole, at least one teeing ground (two if more than two teeing grounds are provided), including the forward ground. In existing golf courses, where compliance is not feasible due to terrain, the forward teeing ground is not required to be one of the teeing grounds that can be accessed by a golf car.
(91) Accessible Teeing Grounds, Putting Greens, and Weather Shelters at Golf Courses (NC)
ABRA–REC Chapter 4. ADAAG 238.2; 1006.4.
Golf cars will have to be able to enter and exit each putting green, each weather shelter, and, for each hole, at least one teeing ground (two if more than two teeing grounds are provided), including the forward ground.
(92) Accessible Practice Grounds (Putting Greens, Practice Teeing Grounds, and Teeing Stations) at Driving Ranges
ABRA–REC Chapter 4. ADAAG 238.3.
5% but at least one of each of practice putting greens, practice teeing grounds, and teeing stations at driving ranges will have to permit golf cars to enter and exit.
(93) Accessible Route to Mini Golf Holes
ABRA–REC Chapter 8. ADAAG 206.2.16; 239.3; 1007.2.An accessible route will be required to connect accessible miniature golf holes and, as well, the last accessible hole directly to the course entrance or exit; generally, the accessible holes will have to be consecutive with one permitted break in the sequence of holes. Specified exceptions would be available for accessible routes located on the playing surfaces of holes.
(94) Accessible Mini Golf Holes
ABRA–REC Chapter 8. ADAAG 239.2; 1007.3.At least 50% of miniature golf holes on miniature golf courses will be required to be accessible (includes specified clear space at start of play and specified golf club reach range area).
RIDES AND PLAY AREAS [7]
(95) Accessible Route to Amusement Rides
ABRA–REC Chapter 4. ADAAG 206.2.9; 1002.2.
An accessible route will be required to serve each ride, including the load/unload area.
(96) Wheelchair Space, Transfer Seat or Transfer Device for Amusement Ride
ABRA–REC Chapter 4. ADAAG 234.2; 1002.4-6.
New Construction Requirement: Each newly constructed amusement ride, except for mobile/temporary rides and a few additional excepted rides, will be required to provide at least one type of wheelchair accessibility, by means of one wheelchair space or one transfer seat or one transfer device (the design of the transfer device is not specified).
Alterations Requirement: Existing amusement rides are exempt unless their structural or operational characteristics are altered to the extent that their performance differs from that specified by the manufacturer or the original design.
(97) Maneuvering Space in Load and Unload Area of Amusement Ride
ABRA–REC Chapter 4. ADAAG 234.2; 1002.3.
Specified maneuvering space is required in the load/unload area of each amusement ride, except for mobile/temporary rides.
(98) Signs at Amusement Rides
ABRA–REC Chapter 4. ADAAG 216.12.
Signs are required at entries to queues and waiting lines identifying the type and location of access for the amusement ride.
(99) Accessible Route to Play Components (BR),
(101) Accessible Route to Play Components (ALT) &
(103) Accessible Route to Play Components (NC)
ABRA-PLAY Chapter 4. ADAAG 206.2.17; 240.1-.2; 1008.2-.4.
At least one accessible route must be provided within each play area, which must connect ground level play components required to be accessible and elevated play components required to be accessible, including entry and exit points. A number of exceptions to the usual accessible route requirements apply. Special rules apply to accessible ground surfaces, incorporated by reference from nationally recognized standards for accessibility and safety in play areas (among compliant materials are certain engineered wood fiber and rubber surfacing products). Ground surfaces must be inspected and maintained regularly and frequently to ensure continued compliance. In existing play areas, if only play components are altered and the ground surface is not altered, the ground surface need not comply except to the extent required by the path of travel requirement (up to 20% of the cost of the alteration).
(100) Accessible Play Components (BR),
(102) Accessible Play Components (ALT) &
(104) Accessible Play Components (NC)
ABRA-PLAY Chapter 4. ADAAG 240.2; 1008.4
ABRA-PLAY Chapter 4. ADAAG 240.1-.2; 1008.4
At least one ground level play component of each type provided (e.g., for different experiences such as rocking, swinging, climbing, spinning, and sliding) must be accessible, connected to an accessible route, and (where there is more than one) dispersed throughout the play area and integrated with other play components. If elevated play components (those that are approached above or below grade and that are part of a composite play structure) are provided, a certain proportion (representing a defined number of different types) must be accessible. The alterations requirement does not apply when existing play components are merely relocated for purposes of creating safe use zones and the ground surface is not altered or extended for more than one use zone.
(106) Post Secondary School Multi-Story Dorm Facility
DOJ Final Rules 35.151(f); 36.406(e); ADAAG 224; 806
Public post secondary schools that had previously opted to comply with the UFAS will now be subject to the requirements for transient lodging. With respect to dormitory facilities, the biggest differences are accessible vertical access (i.e., elevators, platform lifts, etc.) between all levels, distribution of rooms with communications features for people who are deaf or hard of hearing, and distribution of rooms with mobility features. The DOJ Final Rules require broader access for people with disabilities than UFAS.
(107) Mobility Accessible Prison Cell
DOJ Final Rules 35.151(k); ADAAG 232.2; 807.2
Detention and correctional facilities that previously complied with UFAS will now be required to comply with the DOJ Final Rules and ADAAG. ADAAG 807.2 specifies the accessibility requirements for cells with mobility features. Under the DOJ Final Rules, fewer mobility-accessible cells (from 5% to 3%) are required as compared to UFAS.
(108) Communication Accessible Prison Cell
ADAAG 232.2; 807.3
Detention and correctional facilities will be required, for cells equipped with audible emergency alarm systems or permanently installed telephones, to provide 2% of these cells with accessible communication features in compliance with ADAAG 807.3.
(109) Social Service Establishments – Elevator Access
ADAAG 233.1; 206.2.3
Group homes, halfway houses, shelters, or similar social service establishments that provide temporary sleeping accommodations or residential dwelling units will now be subject to the requirements for residential facilities, including ADAAG 206 concerning accessible routes. Currently, these types of social service establishments must comply with section 9.5 of the 1991 Standards or UFAS, depending on the nature of the facility (i.e., public or private). One notable effect of this change is that multi-story social service establishments may no longer be required to provide accessible vertical access (i.e., elevator or platform lift) to each story or level so long as all common and public use areas are otherwise located on an accessible route.
(110) Social Service Establishments – Clear Floor Space Around Beds
DOJ Final Rules 35.151(e)(1); 36.406(d)(1); ADAAG 806.2.3
Group homes, halfway houses, shelters, or similar social service establishments that provide temporary sleeping accommodations or residential dwelling units, andwhich are operated by public entities that previously complied with UFAS,willnow be subject to the new requirements for residentialdwelling units in the ADA Standards. Themainimpact of the changefor these facilities is that in sleeping roomswith more than 25 beds,5% of the beds will now be required to provideclear floor space to enable a person using a wheelchair to transfer into the bed.
(113) Housing at Place of Education - Kitchen Turning Space
DOJ Final Rules 35.151(f)(1); 36.406(e)(1); ADAAG 809.2.2.
Housing at places of education (i.e., college dormitories, student apartments, or other types of residential housing provided in an educational setting) that are covered by the ADA will be required by the Final Rules to comply with the transient lodging standards in ADAAG, as well as several additional requirements (drawn primarily from residential housing standards) to provide greater accessibility for students with disabilities. One of these additional requirements relates to turning spaces in kitchens in such facilities when kitchens are located either within housing units containing accessible sleeping rooms with mobility features (including suites and clustered sleeping rooms) or on floors containing accessible sleeping rooms with mobility features. Covered kitchens will be required to provide larger turning spaces that comply with ADAAG 809.2.2.
(114) Housing at Place of Education – Kitchen Work Surface
DOJ Final Rules 35.151(f)(1); 36.406(e)(1); ADAAG 804.3.
Specified kitchens in housing at places of education, as noted above, will be required by the Final Rules to provide several enhanced accessibility features (in addition to complying with applicable transient lodging standards in ADAAG). These kitchens, in addition to providing larger turning spaces (see Requirement # 113), must also provide work surfaces that comply with ADAAG 804.3, including a lower height for a specified section (i.e., at least 30 inches wide minimum) of the counter.
(115) Secondary Accessible Means of Entry to Pools (NC/ALT) &
(116) Secondary Accessible Means of Entry to Pools (BR)
ABRA–REC Chapter 10. ADAAG 242.2; 1009.2-1009.6.
Larger swimming pools with over 300 linear feet of pool wall will be required to provide – in addition to an accessible primary entry via pool lift or sloped entry (see Requirement ## 79 & 112) – a second accessible means of entry. This secondary accessible entry may be a transfer wall, transfer system, pool stairs, pool lift, or sloped entry.
(117) Social Service Establishments – Roll-In Shower
DOJ Final Rules 35.151(e)(2); 36.406(d)(2); ADAAG 608.2.2; 608.2.3.
Group homes, halfway houses, shelters, or similar social service establishments with more than 50 beds and that have common use bathing facilities will be required to provide at least one roll-in shower that complies with ADAAG 608.2.2 or 608.2.3. When separate common use shower facilities are provided for men and women, one roll-in shower must be provided for each gender. The 1991 Standards currently permit such facilities the option of choosing among several different types and configurations of accessible bathing facilities, including roll-in showers. Under the Final Rule, this choice is eliminated and covered social service establishments must provide roll-in showers.
[1] An accessible route must comply with specifications for walking surfaces, running slope, doorways, ramps, curb ramps, elevators, platform lifts, etc. Specifications include width of unobstructed surface, cross slope, and amount of turning space.
[2] A circulation path is an exterior or interior way of passage provided for pedestrian travel, including but not limited to, walks, hallways, courtyards, elevators, platform lifts, ramps, stairways, and landings.
[3] The IBC is a voluntary model building code that has been adopted, in whole or in part, by nearly all States and local jurisdictions.
[4] Mechanical access garages use lifts, elevators, or other mechanical devices to move vehicles from the street level to a parking tier.
[5] The Department is aware that this requirement may not be technically feasible in many circumstances. The requirement has been included in this analysis, but with an extremely low likelihood of occurrence.
[6] Recreational Boating Facilities include marinas, launching facilities, piers, and docks that are designed for recreational use, but do not include the design of passenger vessels or ferry docks, or access on and off passenger vessels.
[7] Play areas include those designed for children aged 2 and older. Exceptions include family facilities where the proprietor resides. Requirements apply separately to play areas separated geographically or by age.
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March 8, 2011