1) Q: What's the difference between the ADA, ADA regulations, and ADAAG?
A: The Americans with Disabilities Act - the ADA - is a law, passed by Congress and signed by the President in July of 1990, that prohibits discrimination on the basis of disability. To effect this prohibition, the statute required certain designated Federal agencies to develop implementing regulations, the first of which were promulgated in July of 1991. This rulemaking continues today. The regulations detail a wide range of administrative and procedural requirements, including compliance with design and construction standards; those standards are expressed in the Americans with Disabilities Act Accessibility Guidelines: ADAAG.
2) Q: What does the ADA cover?
A: The Americans with Disabilities Act (Public Law 101-336), has five titles (a title is a discrete part of a larger document), each of which defines and prohibits discrimination on the basis of disability within a specific arena:
Strictly speaking, the titles refer to the divisions within the statute itself. However, they have come to be used as a shorthand way of discriminating between the ADA obligations of public - title II - and private - title III - entities.
The ADA generally exempts religious entities and private clubs from coverage (note that individual state or local regulations may nevertheless require accessible design in such facilities).
3) Q: How is the ADA implemented?
A: The text of the law outlines the findings and purposes that made it necessary. In order to accomplish its objectives, however, the general and specific prohibitions of discrimination mandated by Congress in each title of the statute must be expressed in rules and regulations - terms used interchangably here - that specify and detail its application. This rulemaking is assigned to an appropriate Federal agency in each of the substantive titles (I-IV; title V is largely administrative) of the ADA:
The DOT rule entitled Transportation for Individuals with Disabilities covers transportation services provided by both title II and title III entities. Title II transportation providers must look to the DOT rule for both facility, vehicle, and operational requirements; those who receive Federal monies will also be covered by DOT's implementing regulations for section 504 of the Rehabilitation Act of 1973. Incidental transportation services provided by public accommodations that are not primarily engaged in the business of transporting people is subject to DOJ's title III regulation for operations and barrier removal and to DOT's regulation for vehicles and systems .
4) Q: How does ADAAG fit into the ADA regulations?
A: The DOJ and DOT rules describe all of the ADA obligations of covered entities arising from titles II and III of the Act. The ADA Accessibility Guidelines (ADAAG) were developed to guide new construction and alterations undertaken by covered entities. The guidelines establish the minimum requirements for accessibility in buildings and facilities and in transportation vehicles subject to the title II and title III regulations. When adopted by DOJ and DOT, the Access Board guidelines became the standards for accessible design under title III (title II entities may choose either ADAAG or UFAS - the Uniform Federal Accessibility Standards - until the Department of Justice completes title II rulemaking now underway).
Regulations implementing the general provisions of titles II and III of the ADA - including those that cover buildings and facilities - were published in the Federal Register (FR) on July 26, 1991 in three parts (the Part designations are Federal Register divisions only and do not relate to titles of the statute):
Regulations implementing the transportation provisions of titles II and III of the ADA were published in the Federal Register on September 6, 1991, also in three parts:
5) Q: How are the regulations organized?
A: The DOJ regulations governing title III entities were published in theFederal Register in three major divisions:
Similarly, the DOJ title II rule, as originally published, contained a preamble and regulation; however, no ADAAG is appended to the document published in the Federal Register. Title II entities may elect to follow either ADAAG - excluding its elevator exceptions - or the 1984 Uniform Federal Accessibility Standards (UFAS) for new construction and alterations (the Department of Justice will consider removing this option when it adopts title II guidelines).
The original DOT transportation rule contained a preamble and regulation as well, and incorporates ADAAG (including Section 10. Transportation Facilities) as Appendix A to Part 37. Appendix D contains an interpretive guide. Vehicle standards are in Part 38.
After publication in the Federal Register, regulations are codified in the Code of Federal Regulations (CFR) which does not contain the preamble that accompanied the original issuance.
The Access Board's ADAAG, also published in the Federal Register as a stand-alone document, contained only a preamble, the guidelines, and an advisory appendix. The detailed discussion of the provisions for new construction and alterations found in its preamble will be of particular use to design professionals applying its scoping and technical requirements (copies containing the preamble are no longer being published; consult the July 26, 1991 Federal Register, available at many libraries).
6) Q: How is ADAAG organized?
A: The guidelines contain requirements applicable to new construction and alterations. Organized into five parts, ADAAG includes:
Scoping provisions may require that an accessible element be provided; require accessibility of an element if any are provided; require that a minimum number or percentage of several elements of a type be accessible; or require conformance to a technical provision generally. Special occupancy sections, though generally also subject to sections 4.1 through 4.35, may contain additional or different scoping and technical requirements.
Technical provisions describe the characteristics of an accessible element: the width of a door, the maneuvering clearance required to use it, mounting heights for operating hardware, etc. Some building elements - telephones are a good example - are subject to several kinds of technical provisions as a result of separate scoping provisions: some units must be installed at a height accessible to persons who use wheelchairs; some must be equipped for use by persons who are hard of hearing; others must incorporate (or support the connection of a portable) text telephone. The technical provisions specify the accessibility required in scoping.
In general, specific provisions take precedence over general requirements, and words and text over figures (although some figures may contain requirements not specified in text). Definitions (in ADAAG 3.5) do not constitute provisions and should not be read as requirements. Furniture, furnishings and equipment not fixed to building construction are not scoped or specified in ADAAG (although the DOJ and DOT rules cover some such items). Designers are encouraged to read ADAAG in concert with the relevant regulation and preamble discussion (a chart on p. 35602 of the DOJ title III regulation simplifies cross-referencing). This is particularly important for existing facilities, whose ADA obligations may be markedly different than those applied to new construction and alterations.
Although ADAAG compliance will not generally be reviewed during the permitting process for new construction or alterations, its application is not unlike that of a state or local building code, whose scoping requirements may be contained in the local adopting amendments, while the technical requirements are those of a model code. Indeed, ADAAG itself is based upon the format of ANSI A117.1-1980, whose standards have been adopted - with the addition of state/local scoping provisions - as the accessibility code in many jurisdictions.
7) Q: How was ADAAG developed?
A: The responsibility to supplement existing Federal accessibility guidelines for application to titles II and III of the ADA was assigned to the Architectural and Transportation Barriers Compliance Board (the Access Board) in the statute itself. A Notice of Proposed Rulemaking (NPRM), published in the Federal Register on January 22, 1991, contained the proposed document, the ADA Accessibility Guidelines, modeled on the format and technical specifications of ANSI - the American National Standards Institute - A117.1-1980 and -1986, with scoping based on that required by the existing Uniform Federal Accessibility Standards (UFAS). Public input was sought during a 60-day comment period, which included a number of public hearings across the country. Several proposed provisions were modified as a result of information and data received in response to questions in the NPRM.
Proposed Section 10 Transportation Facilities of the guidelines was reserved at initial publication and later proposed as an amendment to ADAAG in a Supplemental Notice of Proposed Rulemaking..
8) Q: Have there been any changes in ADAAG?
A: There have been a number of changes to the basic ADAAG since publication of the initial document in the Federal Register of July 26, 1991. Several typographical errors have been corrected and minor editorial changes made to clarify intent. Three major changes in the design standards should be noted:
A fourth change to ADAAG was the addition of section 11, Judicial, Legislative and Regulatory Facilities, and section 12, Detention and Correctional Facilities on January 13, 1998. Special provisions for Building Elements Designed for Children's Use were added at the same time. These sections and special provisions have not been adopted by either DOJ or DOT and thus have not become enforceable standards under the ADA, although the children's provisions have been utilized by several entities under section 2.2 Equivalent Facilitation.
9) Q: How can I tell if I have a current edition of ADAAG?
A: Designers who consult the Federal Register of Friday, July 26, 1991 containing the DOJ title III regulation (28 CFR Part 36), which incorporates ADAAG as an appendix, are using the original document, which can be most easily identified by the omission of Section 10 Transportation Facilities. The Access Board publication of a stand-alone ADAAG in the Federal Register of the same date may be similarly identified by the absence of Section 10. Both documents pre-date the ADAAG changes noted above.
On July 1, 1994, DOJ published a compact edition of the title III regulation incorporating ADAAG. It contains Section 10 and updates ATM and fare machine requirements. Minor editorial changes have been made to the text. However, this edition does not reflect the temporary suspension of certain detectable warning requirements. Its cover identifies it as a reprint from the Code of Federal Regulations.
New Access Board editions of ADAAG are dated on the title page. The current (September 1998) publication contains - or references - all of the major changes to ADAAG that have been adopted to date. The version of ADAAG on this Web site is current as of January, 1998.
10) Q: What's next for ADAAG?
A: Sections 11 and 12 (and certain Miscellaneous provisions) were adopted on January 13, 1998, but have not yet been adopted by the Departments of Justice and Transportation. On the same date, the Access Board published a final guidelines for Building Elements Designed for Children's Use. While the children's provisions have not been adopted by DOJ and DOT, several entities have used them underADAAG Section 2.2: Equivalent Facilitation.
A Federal Advisory Committee was established in 1994 to make recommendations to the Board concerning accessibility in Recreation Facilities. Following the submission of the Committee's report (published with an Advance Notice of Proposed Rulemaking - an ANPRM - seeking public response to a series of questions posed by the Board) in 1995, an agenda for guideline development in this area was established. Rulemaking will include:
11) Q: How will ADAAG be updated?
A: The Access Board intends to periodically review and update the guidelines to ensure that they remain state-of-the-art documents. Late in 1994, the Board chartered a Federal Advisory Committee to assist in the first-ever revision to ADAAG. Twenty-two members drawn from organizations representing design professionals, building owners and operators, persons with disabilities, model codes, and state and local governments, have worked through five subcommittees to develop recommendations for the Board to consider in amending ADAAG. The report, Recommendations for a New ADAAG, was delivered in September of 1996. From this and other documentation, the Board will draft text, figures, commentary, and preamble discussion necessary for rulemaking. It is anticipated that a Notice of Proposed Rulemaking containing a fully revised version of the ADA Accessibility Guidelines will be published for public comment in early 1999.
12) Q: What if there are no provisions in ADAAG for a facility type, element, or feature?
A: Facilities for which there are no specific ADAAG criteria are nevertheless subject to other ADA requirements, including the duty to provide equal opportunity. In many cases it will be feasible to provide access by incorporating basic elements specified in ADAAG, such as ramps and other parameters of an accessible route. Where appropriate standards exist, they should be applied. Scoping may be derived from similar occupancies or uses, considering the range of experiences provided; in general, a reasonable number, but at least one of each type of element should be designed to be accessible. ADAAG 2.2 Equivalent Facilitation also permits the use of alternative designs and technologies that provide substantially equivalent or superior access to and usability of a facility. Such innovative approaches may also be useful in providing access to facility types for which no specific standards have been written.
13) Q: What about ADA requirements for existing facilities?
A: ADAAG was developed for new construction and alterations. Existing facilities not otherwise being altered are subject to requirements specified in the DOJ/DOT regulations, not in the guidelines. Title II entities must achieve program accessibility; title III entities must pursue barrier removal - or alternatives - in existing places of public accommodation; employers must make reasonable accommodation to the needs of an employee with a disability. Broadly viewed, ADA implementing regulations outline a hierarchy of obligations:
Thus, the highest degree of accessibility is expected in new work, when the cost of providing accessible features is nominal compared to the overall cost of construction. Alterations and additions, constrained by work already in place, may default to an intermediate standard when structural and site conditions prohibit full accessibility. Existing facilities must do the best they can with what they have, a flexibility that permits needs to be balanced against available resources.
Again, these requirements for remedial action in existing facilities are contained in the DOJ/DOT implementing regulations. There is no expectation under the ADA that existing facilities be improved to fully meet the scoping and technical standards set in ADAAG.
State and local government services are subject to a program accessibility standard (see §35.150 - p. 35719 of the title II regulation and related preamble material). Existing private sector facilities that are places of public accommodation have an on-going obligation to remove barriers to use by persons with disabilities when it is readily achievable to do so (see §36.304 - p. 35597 of the title III regulation and related preamble). In general, where barrier removal or program accessibility measures involve construction, ADAAG (or UFAS, if elected by title II entities) technical standards for alterations will apply. However, neither ADAAG nor UFAS contain scoping for accessibility measures taken to comply with barrier removal or program accessibility requirements in existing facilities.
14) Q: How does program accessibility apply to existing facilities?
A: A public (title II) entity may not deny the benefits of its programs, activities, and services to persons with disabilities because its existing facilities are inaccessible. Thus, it is the general availability of a program to persons with disabilities that must be evaluated, not compliance with facility standards developed for new construction and alterations.
While state and local governments may wish to measure the accessibility of their existing buildings against the scoping and technical provisions in ADAAG or UFAS, program accessibility may be achieved without making every existing facility - or every part of an existing building - accessible. Alternatives to building retrofit can include the temporary relocation of an activity to an accessible facility or the delivery of the service or benefit by other means. In many cases, however, permanent construction that provides physical access may be the most efficient and economical approach to program access, particularly when life cycle costs are considered.
Although physical changes are required only when there is no other feasible way to make a program accessible, public entities are nevertheless required to give priority to methods that result in the most integrated setting appropriate.
The program access obligation is limited: title II entities do not have to take actions that they can demonstrate would result in a fundamental alteration in the nature of a program or that would impose undue financial or administrative burdens.
Most state and local governments were required to prepare a self-evaluation plan to identify program access issues; from this, a transition plan was to be developed to fix items of construction that would be undertaken to achieve program accessibility. Transition plan work - except for curb ramp installation, for which DOJ has proposed an extension - was to have been completed by January 1995.
On November 29, 1995, the Department of Justice published a Notice of Proposed Rulemaking (NPRM) proposing to extend the date by which public entities must complete the installation of curb ramps required by the title II rule. The comment period closed on March 1, 1996; DOJ staff are currently analyzing public response. Transportation planners should note that existing key stations in certain transportation facilities must be made accessible in accordance with requirements outlined in ADAAG 10.3.2 (see also Subpart C of the DOT rule).
15) Q: How does barrier removal affect existing facilities?
A: Barrier removal is the private sector (title III) obligation for existing facilities. Only those commercial facilities that are places of public accommodation must comply with this requirement to remove physical and communications barriers to the use of existing facilities by persons with disabilities. The regulation limits barrier removal to actions that are readily achievable, that is, projects that are relatively easy and inexpensive to accomplish. The DOJ rule provides both examples of and priorities for barrier removal and specifies criteria for assessing what is ready achievable. When a public accommodation can show that barrier removable is not readily achievable, as, for instance, the addition of an elevator to serve an inaccessible story, the public accommodation must make its goods and services available by other (readily achievable) means. Such alternatives to barrier removal might include assigning assistance or providing home delivery.
Because the barrier removal obligation is a continuing one, no compliance date is set. It is anticipated that covered public accommodations will work steadily to improve access over time until the facility meets ADAAG standards for alterations.
Barrier removal is also required of public accommodations that provide transportation service, such as hotel shuttles, college and university campus transport, and van services provided by automobile dealers. However, lift retrofit of vehicles is not required.
16) Q: What about obligations to employees?
A: Reasonable accommodation for employees with disabilities is covered under title I by regulations issued by the Equal Employment Opportunity Commission (EEOC); this includes employee transportation provided by public accommodations. Employee accommodations are not generally subject to ADAAG criteria.
Since employers must provide a reasonable accommodation to an applicant or employee with a disability, commercial facilities that are not places of public accommodation need not make general accessibility improvements to existing facilities until planned alterations or additions provide an opportunity to do so.
17) Q: Who enforces ADAAG provisions?
A: Because the ADA is civil rights law, compliance with and enforcement of its implementing regulations, including its guidelines for new construction and alterations, is not overseen by a local building code official but is exercised through private suit or by specified Federal agencies when discrimination - or the probability of discrimination on the basis of disability - is alleged.
18) Q: What about other accessibility regulations?
A: Most Federal buildings and federally-funded or -assisted construction are covered by the Architectural Barriers Act of 1968 (ABA), for which UFAS is the current accessibility standard. The Access Board is the compliance and enforcement agency for the ABA and provides technical assistance to Federal agencies on the application of UFAS. Federally-funded or -assisted programs and services must also meet the accessibility requirements of Section 504 of the Rehabilitation Act of 1973, for which UFAS is the referenced standard. The concept of program accessibility applied under the ADA to title II entities was first applied in regulations implementing the Rehabilitation Act.
The Access Board is currently reviewing and updating guidelines for newly-constructed, altered, and leased Federal facilities covered by the Architectural Barriers Act of 1968. This effort is being coordinated with the proposed revisions to ADAAG. Working with the four ABA standard-setting agencies - the Departments of Defense and Housing and Urban Development, the General Services Administration, and the Postal Service - the Board anticipates publication of an NPRM proposing new requirements for Federal facilities early in 1999. A single document is anticipated with a scoping section for the ADA, a scoping section for the ABA, and a common set of technical provisions.
Accessibility in multifamily residential facilities generally is covered by the Fair Housing Amendments Act of 1988 (FHAA) and its related regulations and standards; for more information, contact the Department of Housing and Urban Development. All housing - even single-family residences - constructed or altered by or on behalf of state and local governments must meet ADA title II requirements. Since ADAAG does not yet include scoping or technical provisions for residential units, public entities should use UFAS as the accessibility standard until the Access Board completes work on title II housing guidelines. Residential design, construction, and alterations supported by Federal funds are covered by the ABA; Federally-assisted or -conducted housing programs and services are covered by the Rehabilitation Act. Both require conformance to UFAS accessibility provisions in new construction and alterations. Housing projects may in fact be covered by the ABA, the Rehabilitation Act, the FHAA, and the ADA; by applying the most stringent of the UFAS/FHAAG/ADAAG scoping and technical provisions, developers can satisfy all requirements.
Although publicly-operated airports are not subject to DOT's ADA regulation, they are covered by the DOJ title II rule. Additionally, airports that receive Federal financial assistance are covered by the ABA (for facilities designed, constructed, or altered with Federal funds) and Section 504 of the Rehabilitation Act (for Federally-assisted or -conducted programs and services) and the DOT Section 504 regulations. As with housing, UFAS is the generally referenced standard. Privately-operated airports are covered by subpart A of DOT's transportation regulation and by the Department of Justice title III rule as commercial facilities. Most airports also contain places of public accommodation in shops, restaurants, and similar uses. Airline operations are subject to the Air Carrier Access Act of 1986 and its implementing regulations, which include some facility provisions.
Most new construction and alterations projects - and work undertaken as barrier removal or to provide program accessibility, where a local building department requires a permit - will be subject to state accessibility requirements as well as those of the ADA. Almost half of US states reference the ANSI A117.1 accessibility standard. Several have developed unique codes; a few reference UFAS. The balance have adopted ADAAG as their accessibility code and implement its requirements through state and local building code officials in the same way as other applicable building regulations are applied, reviewed, and enforced.
Some jurisdictions have submitted their building code/standard for review by the Department of Justice. Standards that meet or exceed the minimum accessibility requirements of the ADA will be certified. To date, Florida, Maine, Texas and Washington state codes have been certified. The model codes, including ANSI A117.1, have sought to coordinate accessibility provisions through informal review and technical assistance from DOJ.
ADA/ADAAG compliance does not relieve the designer from complying with the provisions of a state or local access code or other accessibility regulation. Where such a code or document contains more stringent requirements, they must be incorporated. Conversely, adoption of ADAAG or certification of the equivalency of a state/local code will not relieve covered entities of their responsibilities to meet the accessibility standards of the ADA (or other accessibility requirements).
The Board is a member of the ANSI A117.1 Committee and shares its interest in more uniform national accessibility specifications. As ADAAG, ANSI A117.1, and state and model codes are periodically reviewed and revised, it will be possible to achieve greater consistency in provisions among the several documents a design professional must apply to new construction and alterations.
Recently, the Access Board issued accessibility guidelines for telecommunications and customer premises equipment under the Telecommunications Act of 1996. The Telecommunications Access Advisory Committee submitted its Final Report to the Board with recommendations and the Board published a Final Rule on February 3, 1998. The Federal Communications Commission is responsible for enforcement.
Design professionals can track these and other regulatory actions of the Board through their professional membership organizations, trade publications, the update posted on this Web site and the toll-free Access Board technical assistance line, which include a monthly update of Board activities. The Access Board also publishes a bi-monthly newsletter, Access Currents, highlighting its research, technical assistance, rulemaking, and ABA enforcement activities.
19) Q: Where can I get more information?
A: Questions about new construction and alterations under ADAAG or UFAS should be addressed to the Access Board technical assistance line at (800) 872-2253 (V) or (800) 993-2822 (TTY). When the automated telephone recording responds, press "2" to speak to an accessibility specialist. Other menu choices include publications ordering (press "1"); the monthly Board news update (press "5"), and a comment line (press "6"). Technical assistance questions can also be submitted by E-mail to email@example.com. At this time, responses to E-mail questions will be by telephone, so you must include a telephone number with your question.
Questions about program accessibility (a title II requirement) andbarrier removal (a title III obligation) in existing facilities should be directed to the Department of Justice ADA information line at (800) 514-0301 (V) or (800) 514-0381 (TTY). The Department of Justice has also published Technical Assistance Manuals for its title II and title III rules; they - and copies of the DOJ regulations - may be ordered through the same telephone number. DOJ regulations also cover other ADA obligations, including those for alternatives to barrier removal, auxiliary aids and services, modifications in policies and procedures, maintenance of accessible features, communications, and similar requirements.
Information about and copies of the transportation regulation governing both title II and title III entities may be obtained from the Department of Transportation (DOT) at (888) 446-4511 (V or TTY). Operational questions should be addressed to DOT at (202) 366-4390. For information about the requirements of the Air Carrier Access Act, contact DOT at (202) 366-4859 (V) or (202) 755-7687 (TTY).
Title I (Employment) issues involving reasonable accommodation and other obligations should be raised with the Equal Employment Opportunity Commission at (800) 669-4000 (V/TTY).
See Links for links to other agency Web sites.
The following frequently asked questions have been compiled by our technical assistance staff. These questions will be updated periodically.
1) Q: When are areas of rescue assistance required? (ADAAG 4.3.11)
A: In new construction, ADAAG requires accessible means of egress in the same number as required for exits by the local life safety regulations. Where direct exit discharge cannot be provided, such as from floors above or below grade, areas of rescue assistance are required, unless a supervised automated sprinkler system is provided. They are not required in altered buildings.
2) Q: Does the definition of "technically infeasible" include cost considerations?
A: Cost is not a factor in determining whether an action would be technically infeasible. Technically infeasible is defined at ADAAG 4.1.6(1)(j) and includes actions such as the removal of a load bearing member which is an essential part of the structural frame of a building. In applying the alterations guidelines, the Department of Justice considers cost under certain circumstances. The terms "readily achievable" and "undue financial and administrative burdens" are used by the DOJ and are not synonymous with "technically infeasible" as defined in ADAAG.
1) Q: Are the mats placed on the floor of my office lobby during wet weather considered carpet that must be firmly attached? (ADAAG 4.3 Accessible route)
A: No, such mats are "furnishings" not covered by ADAAG. However, section 36.211 of the Department of Justice rule requires that accessible features be maintained so such furnishings cannot degrade the accessible route. So-called "walk-off mats" are designed to provide traction on wet floors and, as long as they are stable and do not pose a tripping hazard, they may actually improve the accessibility of a surface. On the other hand, loose throw rugs, for example, could decrease the accessibility of a surface.
2) Q: Is there a specific coefficient of friction required for a surface to be "slip resistant"? (ADAAG 4.5.1)
A: No. There are a variety of ways to measure the coefficient of friction for different materials and no single test device or procedure has been identified. A Board sponsored research project, described in the ADAAG Appendix Section A4.5.1, suggested some values but, without a defined test procedure, these recommendations cannot be applied.
3) Q: ADAAG specifies that carpet must be firmly attached. Does this mean that each individual carpet tile must by glued down? (ADAAG 4.5.3)
A: No. The requirement is to ensure that the carpeted surface provides a firm and stable surface. When carpet tiles are used, they are frequently installed with some tiles glued down and others held in place by friction. As long as the resulting carpeted surface remains firm and stable, that is, the tiles don't move, the carpet is considered to be firmly attached.
1) Q: Why are built-up curb ramps in access aisles problematic? Wouldn't a parking space be more accessible if the curb ramp is close by?
A: Access aisles and the parking spaces they serve must be level (1:50 or 2%) in all directions. Therefore, built-up curb ramps cannot extend into access aisles. It is especially difficult to transfer from a vehicle to a wheelchair on a sloped surface. (ADAAG 4.6.3)
2) Q: Is a doctor's office a medical care facility? How is parking for doctor's offices calculated?
A: While a doctor's office is a professional office of a health care provider, it is not generally a medical care facility and parking must be allocated according to the chart at ADAAG 4.1.2(5)(a) and (b). For example, if 51 to 75 parking spaces are provided, three must be accessible, and one of these must be a van space.
3) Q: Must accessible parking spaces be provided in each parking lot in a facility or can they be grouped?
A: Although parking is calculated on a per-lot basis, it can be located in a different location if equivalent or greater accessibility, in terms of distance to an accessible entrance, fees, and convenience is ensured. For example, while site constraints may may prohibit the location of a large parking lot adjacent to an accessible entrance, the required number of accessible spaces might be installed at the entrance to provide more convenient access.
4) Q: How is the width of an accessible parking space measured?
A: Parking space width is measured from the center line of the stripe on one side to the center line of the stripe on the other.
5) Q: Must the accessible route to a parking space access aisle be at the head of the space?
A: No. Although ADAAG Figure 9 shows the accessible route connecting to the access aisle at the head of the parking space, this configuration is not mandatory. The Access Board recommends that the accessible route not require persons with disabilities to pass behind parked cars, but this is not required. Nevertheless, the accessible route must meet all the requirements of ADAAG 4.3.
1 Q: Are curb ramps required to have detectable warnings?)
A: Originally, ADAAG required detectable warnings, a distinctively bumpy surface detectable by cane and underfoot, on the surface of curb ramps to provide a tactile cue for persons with vision impairments of their approach to streets. This warning was required since the sloped surfaces of curb ramps remove a tactile cue provided by curb faces. They were also required at hazardous vehicular areas, reflecting pools, and the edges of boarding platforms in transit facilities. The Board temporarily suspended these requirements (except those applicable to boarding platforms) in 1994 due to concerns raised about the technical specifications, the availability of complying products, maintenance issues such as snow and ice removal, usefulness, and safety. DOJ and DOT joined the Board in this action, which effectively removed the requirement from the enforceable standards. During the two-year suspension, the Board conducted further research on the need for detectable warnings at curb ramps, which showed that such warnings can be helpful, but that people with vision impairments rely on a combination of cues to detect intersections. The suspension was extended twice (in 1996 and 1998) to accommodate the review and update of ADAAG. The ADAAG Review Advisory Committee recommended that the issue of detectable warnings at curb ramps should be resolved specifically in relation to public rights-of-ways before reinstating any requirements in ADAAG, which specifically applies to facilities on sites. The Board agreed and did not include requirements for detectable warnings at curb ramps (or hazardous vehicular areas and reflecting pools) in its proposal to update ADAAG. Consequently, the Board did not further extend the suspension, which expired on July 26, 2001. However, since the enforcing agencies did not extend the suspension either, the detectable warning requirements are technically part of the standards again. DOJ can provide additional guidance on its enforcement of these requirements pending the update of its standards based on the new ADAAG. The Board intends to revisit the issue specifically in relation to curb ramps in public streets and sidewalks in an upcoming effort to establish guidelines for public rights-of-way.
2) Q: Is there a minimum landing width requirement at the top of a curb ramp? ADAAG Figure 12 shows a dimension "X" that is related to the slope of the side flares, but does not indicate a minimum.
A: The minimum landing width at the top of a curb ramp is 36 inches. A curb ramp is required when an accessible route crosses a curb; the curb ramp is part of the accessible route. Figure 12 is not intended to represent all the requirements for curb ramps. The actual requirements are contained in the text of the technical specifications. Since an accessible route has a maximum cross slope of 1:50 (2%), and the curb ramp side flares do not meet this criterion, the accessible route, with a minimum 36 inch width, must instead connect to the top and bottom of the curb ramp. (ADAAG 4.3.3 & 4.7.1)
1) Q: ADAAG ramp requirements specify "level" landings. Does "level" mean zero slope? (ADAAG 4.6.3 and 4.6.6)
A: No. In general, "level" means having a slope no greater than 1:50 (2%) in any direction.
1) Q: Are all stairs required to be accessible in accordance with section 4.9? (ADAAG 4.9)
A: No. Only stairs which connect levels which are not connected by an accessible route are required to comply with ADAAG 4.9.
1) Q: In new construction, are basements considered stories for the purpose of applying the elevator exception in ADAAG 4.1.3(5) Exception 1?
A: The definition of story in ADAAG 3.5 clarifies that nonoccupiable space is not considered a story. However, a basement that is occupiable as defined in ADAAG, will be considered a story.
1) Q: Are all my doors required to have maneuvering clearances? (ADAAG 4.13.6)
A: Not necessarily. The maneuvering clearances specified applies to doors that are not automatic or power-assisted. Of course, if power doors are provided, the controls must meet the requirements for Controls and Operating Mechanisms (4.27).
2) Q: ADAAG figure 25 (a) appears to permit latch-side clearance on an outswinging door with a front approach to be zero dimension. Is this correct?
A: Yes, if the door has only a latch or a closer, but not both, the "X" dimension may be zero.
1) Q: Can the door of a toilet room swing into the required maneuvering space? (ADAAG 4.22.2 and 4.23.2)
A: Yes, the door can swing into the maneuvering space, but not into the space required at a fixture.
2) Q: Is it acceptable for portable toilets to be designed according to the requirements of ADAAG 4.17 Stalls?
A No. Although only five percent of the portable toilets in a cluster are required to be accessible, each accessible toilet must satisfy the requirements for toilet rooms inADAAG 4.22. (ADAAG 4.1.2(6))
1) Q: How are the provisions of 4.24 sinks applied?
A: The technical provisions for sinks at section 4.24 are not scoped in ADAAG. This means that the technical provisions serve only as guidance, not requirements. The Department of Justice rules generally require that new facilities be accessible to and usable by persons with disabilities. In the absence of specific scoping provisions, the provisions of 4.24 can be the best guidance available, however designers are not precluded from developing their own technical provisions that provide access. Sinks that comply with the side reach ranges specified in ADAAG 4.2.6 may be acceptable in cases where they are for incidental use and where they are usable by right or left handed persons.
1) Q: Can I use standard pipe for handrails? (ADAAG 4.9.2)
A: Yes. Common IPS pipe sizes designated as 1-1/4 to 1-1/2 are considered to be within the dimensional tolerances for handrail diameter.
2) Q: Must the handrails in corridors of nursing homes or housing for elderly persons comply with ADAAG 4.26?
A. Corridor handrails are not required by ADAAG and are, therefore, not covered by section 4.26. However, some housing for elderly persons is covered by standards issued by the Department of Housing and Urban Development. The 1994 edition of the HUD Handbook 4910.1, Minimum Property Standards, Section 100-2, Housing For The Elderly, contains some requirements for corridor handrails. Contact HUD for further information.
1) Q: How can I apply the principle of equivalent facilitation to the placement or intensity of visual alarm strobes? (ADAAG 4.28.3)
A: The current ADAAG requirement is for a minimum 75 candela strobe to provide sufficient illumination in all directions in the horizontal plane 50 feet from the strobe. The formula
I1 divided by D1 squared = I2 divided by D2 squared
can be used, where
If the strobe is to be mounted above 80 inches, calculate the new distance (D2) by the Pythagorean Theorem where the new distance is the hypotenuse of a triangle with 50 feet as its long leg and the height above 80 inches as its short leg.
While strobes of intensity lower than 75 candela can work for rooms smaller than 50 feet, one should not place multiple, unsynchronized strobes in a room or space less than 80 feet across since the resulting composite flash frequency from multiple strobes may exceed the safe limits and trigger some types of epilepsy. Use the least number of strobes and lowest intensity needed to cover a space.
1) Q: How is the 6-inch dimension measured for pictograms that are required to comply with ADAAG 4.30.4?
A: A pictogram includes both a symbol and the field on which it is displayed. The 6-inch vertical dimension applies to the field, not the symbol. The symbol may be smaller than the field. The required equivalent verbal descriptor must be placed below the pictogram and may not intrude on the 6-inch field.
1) Q: In hotels, are the required rooms with roll-in showers to be provided in addition to those rooms that are required to be otherwise accessible?
A: Yes. ADAAG 9.1.2 specifies that, in hotels with 50 or more sleeping rooms or suites, additional accessible sleeping rooms with a roll-in shower shall be provided in conformance with the table. For example, a new 150-room hotel must have a total of seven accessible rooms, two with roll-in showers.
2) Q: In transient lodging, do all the doors to all the rooms have to be accessible?
A: ADAAG 9.4 requires that doors and doorways designed to allow user passage into and within all sleeping rooms or suites comply with ADAAG 4.13.5 for clear width. This includes entry doors, bathroom doors, doors connecting rooms in a suite and doors connecting multiple suites, but does not include doors to shallow closets. This provision does not require compliance with maneuvering clearance or any of the other provisions of 4.13.
1) Q: Are there any accessibility requirements for Boat and Ferry Docks, since Section 10.5 is reserved?
A: The absence of requirements in section 10.5 simply means there are no special requirements for boat and ferry docks. Docks are covered by ADAAG section 4 to the same extent as other facilities required to be accessible by titles II and III. The DOJ technical assistance manual states that the technical requirements should be applied to the extent possible. For example, it may not be possible for a ramp to a floating dock to maintain the 1:12 maximum slope under all tidal conditions.