Welcoming Remarks: Chairman Robert Solomon welcomed the Committee and requested approval of the agenda. The agenda was approved without modification.
Subcommittees: Mr. Ryan Buras, Chair of the Unit Interior Subcommittee and Mr. Dominic Marinelli, Chair of the Definitions Subcommittee briefly reported on the progress of each subcommittee. Then, Mr. Solomon requested that the full committee review the recommendations of each subcommittee in detail to provide them feedback prior to finalizing their recommendations. Therefore, no binding votes were taken during the meeting. Instead, subcommittee chairs were requested to finalize their recommendations for full committee action at the January 2008 meeting.
Exception 3 to Section 205.1 requires only one convenience outlet provided above a kitchen countertop uninterrupted by a sink or appliance to be accessible where two or more outlets are provided. The task group questioned the necessity of this exception to the general rule that all outlets in a kitchen must be accessible, particularly given that emergency transportable housing units do not generally provide numerous convenience outlets. The original exception was based on a requirement in the National Electrical Code that located at least one outlet in a kitchen in a location that cannot meet the requirements in Section 308 of the guidelines specifying maximum obstructed reach ranges.
Discussion: The committee verified that the NEC requires outlets every four feet and 24 inches from a corner. The committee did not take a position regarding the proposal.
Section 205 requires operable parts to be within reach, to have a clear floor space, to be operable not more than five pounds force and they must be operable with one hand without tight grasping, pinching, or twisting of the wrist. The subcommittee questioned whether certain controls within emergency transportable housing units could meet these requirements. The subcommittee proposed exemptions for controls located beneath an emergency transportable housing unit body and for individual water shut-off valves where a single accessible water shut-off valve for the entire unit is provided.
Discussion: Some members of the committee questioned the cost of providing a single water shut-off value within the unit. Committee members representing the industry estimated a cost of approximately $30. The committee determined that their concern regarding controls located beneath the unit body are unique while those regarding water shut-off valves are not unique to emergency transportable housing.
Section 207.1 of the guidelines requires all buildings to provide an accessible means of egress complying with the International Building Code (IBC). A means of egress under the IBC is comprised of exit access, exit and exit discharge. Exit access in an accessible means of egress would be an accessible route within the unit. An exit typically would be an accessible door leading to the outside. And, exit discharge would be an accessible route from the exit to the public way or an area of assisted rescue such as an outside landing which is protected from fire and smoke. The IBC does not provide criteria for accessible means of egress in single family homes.
Park models and travel trailers are only required to have one means of ingress that also serves as a means of escape. Manufactured housing has one primary and one secondary means of escape and imposes travel limitations on both. The guidelines currently require the primary entrance to all types of units to be accessible. There currently are no existing federal or private-sector standards for an accessible means of escape such as from a window or hatch in a bedroom of a transportable housing unit.
The subcommittee questioned whether the National Fire Protection Association might assist them to develop criteria for accessible means of escape from emergency transportable housing units. Additionally, the subcommittee questioned whether platform lifts if used to provide an accessible route to the primary entrance would pose any concerns for occupant evacuation. They noted that the time needed to use or recall a platform lift could be an unnecessary delay.
Discussion: Because the problem of providing accessible means of escape from bedroom widows and other inaccessible openings is not unique to emergency transportable housing, the committee consensus was to focus on criteria that will ensure an accessible route within the unit out trough the primary unit entrance. The committee tentatively agreed that platform lifts should not be used at the primary entrance to the unit which provides the only required accessible route into and from the unit.
Section 404.2.5 of the guidelines requires that thresholds at doors be 1/2 inch maximum beveled at 1:2. Members of the subcommittee have observed that the typical entry door assembly on smaller units does not comply with this requirement. The threshold has a stop that is approximately 3/4 inch tall. The exterior door face extends approximately 5/8 inch to 3/4 inch below the bottom surface of the door. The door swings out onto the ramp landing. For the door to operate freely, the landing must be approximately 1/2 inch to 3/4 inch below the finished unit floor, which is 1-1/8 inches to 1-1/2 inches below the top of the threshold. Larger emergency transportable housing units use door assemblies more common to residential construction which do not appear to present accessibility challenges. The subcommittee recommended that an advisory be included in the guidelines to discourage the designs used in smaller units.
Discussion: Members of the committee representing the industry consulted with manufacturers of smaller units. They reported that the door design could be modified by installing doors used in motor homes which would comply with the current accessibility requirements. FEMA requested data regarding the cost of changing this practice. The committee agreed that guidance could be provided on this point and requested that the subcommittee consider a positive approach by illustrating best practices rather than current and problematic practices.
Section 404.2.7 of the guidelines requires that sliding doors must have hardware that is fully exposed and usable from both sides when the door is in the open position. Also, this hardware must be operable with one hand without tight grasping, pinching, or twisting of the wrist. Members of the subcommittee noted that sliding or pocket doors are commonly used in emergency transportable housing to conserve space and provide usable accessible routes. However, the subcommittee was concerned that the existing guidelines lack technical requirements for the minimum appropriate distance from the edge of the door panel to the door pull which would facilitate hardware use. Also the committee would like to see more guidance regarding the optimal design of hardware which would minimize or eliminate grasping, pinching and twisting of the wrist. The subcommittee considered developing a specification for sliding door hardware.
Discussion: The committee discussed issues relating to sliding doors. They observed that sliding doors are often installed in an opening which is insufficiently wide to provide the minimum clear opening and expose the hardware on the door face when in the open position. The committee would like to see greater guidance on this issue and they suggested that the subcommittee consider a provision which would ensure at a minimum, a 36 inch door with 32 inch clear opening which has U-shaped hardware installed 1 1/2 inches from the latch. This issue is not unique to emergency transportable housing.
The subcommittee reviewed sections in the guidelines which allow housing providers to not make certain features fully accessible at the time of construction because these elements can easily be provided later and, if customized, may better suit a tenant’s unique disability related needs. See Sections 604.5, 606.2, 608.3 and 608.4. In the Uniform Federal Accessibility Standards (UFAS) these features are called “adaptable”. Because emergency transportable housing must be put in place quickly and suppliers of building products specializing in accessibility may not be available during an emergency, the subcommittee was concerned that permitting adaptability would not facilitate an appropriate response to the immediate housing needs of most individuals with disabilities.
Discussion: There was general concurrence that exceptions for adaptability should not apply in emergency transportable housing. In addition, the committee urged the subcommittee to amend Section 608.4 to include a requirement that shower seats be provided in shower stalls in emergency transportable housing units.
The subcommittee considered the necessity of modifying Section 608.7 which prohibits roll-in showers from having thresholds higher than 1/2 inch. In residential and commercial construction, contractors typically nail or screw the threshold flange of an accessible shower to the subfloor. Then they install the ceramic tile, or other finish material, over the flange. When properly installed, the threshold rises no more than 1/2 inch above the finished floor and meets the requirement in the guidelines limiting changes in level on accessible routes. Emergency transportable housing construction uses a vinyl flooring which is much thinner than ceramic tile. The resulting threshold is 3/4 inch to one inch high. However, the subcommittee determined this problem is easily resolved because the floor assembly is plywood over wood joists permitting the shower to be recessed. For example, manufacturers can double the number of joists under the shower. Then, notch the joists to recess the plywood subfloor. Consequently, the subcommittee recommended no action to modify the guidelines.
Discussion: There was general consensus with the subcommittee’s decision not to recommend a modification.
Section 702.1 of the guidelines generally defers criteria for fire alarm systems and smoke detectors to the National Fire Alarm Code (NFPA 72). However, some of the subcommittee members were concerned that occupants with disabilities would require assistance to replace batteries in smoke detectors. They recommended that an advisory note be included which urges manufacturers to provide non rechargeable, non replaceable primary batteries in residential smoke alarms.
Discussion: There was general consensus that non rechargeable, non replaceable primary batteries would make residential smoke alarms easier to maintain. This issue is not unique to emergency transportable housing.
Section 804.3 requires dwelling unit kitchens to provide at least one 30 inch long section of countertop at an accessible height with knee and toe space beneath to be used as a work surface for food preparation. Noting that space is limited in emergency transportable housing units, the subcommittee questioned whether requiring such a work surface with knee space beneath it in a kitchen which has very little kitchen storage would further limit options for accessible storage. They noted that, unlike most other housing, emergency transportable housing units often are provided with furnishings in place. In particular, a kitchen table generally is provided and is located within the kitchen area. When not used for dining, the kitchen table can be used for food preparation if it meets accessibility criteria. The subcommittee recommended an exception to Section 804.3 where a kitchen table complying with 902 is provided within the kitchen.
Discussion: Committee members were concerned that the work surface in the kitchen is the only countertop at 34 inches maximum. Countertops at this height permit a reach over an obstruction where accessible elements are located on the wall behind the counter and they facilitate use of the counter surface. Committee members agreed that where all countertops are at the same height occupants with mobility impairments find it easier to move items along the countertops, including those that may be too hot to handle. While the committee agreed with the concept of exempting the work surface when an accessible kitchen table is provided, they also urged the subcommittee to make the exception contingent on providing all countertops at 34 inches high maximum.
Section 804.5 of the guidelines requires at least 50% of kitchen storage to be within reach, have clear floor space and to provide accessible hardware. The subcommittee was concerned that emergency transportable housing provides very little kitchen storage compared to other housing types. They also noted that, unlike other housing types, there typically is no space in the kitchen and dining area to accommodate additional furniture for storage, such as shelves, pantries or cabinets. Consequently, the subcommittee recommended that a new requirement be added to Section 804.5 specifying that emergency transportable housing units must provide at least one shelf of all base cabinets and storage shelves mounted above counter tops at 48 inches high maximum. They propose to exempt cabinets located above refrigerators, ranges and cook tops.
Discussion: Members of the committee questioned the benefit of the proposed requirement for base cabinets noting that all base cabinets provide shelves no higher than 48 inches. They also questioned whether the suggested exception for shelving located above refrigerators, ranges and cook tops was too broad. Committee members observed that even where shelves in wall cabinets are 48 inches high, users with mobility impairments cannot reach far into them because this height is at the maximum limit for reach specified in the guidelines. The committee noted a possible adverse impact of the proposed requirement; lowering the shelving in all wall cabinets to 48 inches reduces the vertical clearance above countertops and could impede the placement of appliances and other kitchen equipment at the back of the counter. A few members of the committee urged the subcommittee to consider storage alternatives which facilitate reach such as pull-out shelving. The committee suggested that the subcommittee rewrite its proposal to cross reference the reach ranges specified in Section 308 and that they be more specific in the exception regarding the height of a wall cabinets that would be exempt. The committee also urged the subcommittee to consider how their proposal would impact cabinets located in corners because it would not be possible to locate a clear floor space at such cabinets to facilitate their use. Even though kitchen storage is extremely limited in emergency transportable housing, this issue particularly concerns regarding the ability of individuals to reach into storage cabinets, is not unique to that type of housing.
Section 804.6.2 requires kitchen controls, including those on appliances to comply with Section 309 Operable Parts which references Section308 Reach Ranges. Members of the subcommittee were concerned that controls within refrigerators and freezers typically are located on the back walls of the appliance and are therefore out of reach. The subcommittee considered proposing an exception for controls within appliance. However, subcommittee members found examples of compliant products on-line. Therefore, they recommended no action.
Discussion: There was general consensus that a modification of the guidelines is not required at this time. Committee members noted that issues related to kitchen appliances are not unique to emergency transportable housing.
Discussion: Section 806.2.5 of the guidelines requires a clearance 30 by 48 inches on both sides of a bed in transient lodging guest rooms to enable individuals with mobility impairments to transfer to and from the bed. Where two beds are provided, a single clearance between them is permitted to be substituted for clearances alongside both sides of one bed. Clearances on the left and right –hand sides of a bed allow individuals to select the optimal side of the body for transfer depending on their abilities. Currently, there is no corresponding requirement for residential dwelling units because, unlike guest rooms, furniture typically is not provided in such units. However, as noted above in Item #7, furniture generally is provided in emergency transportable housing and smaller bedrooms provide very little flexibility in furniture layout. The subcommittee recommended adding a new requirement for a 30 inch by 48 inch clear floor space to be positioned for a parallel approach alongside at least one side of a bed provided in emergency transportable housing units.
Discussion: There was general consensus among committee members that the proposal is warranted and, because it would require a clearance only on one side of a bed, it would not have a disproportional impact on the unit design. This issue is unique to residential facilities which provide furnishings.
Section 809.2.2 requires all rooms served by an accessible route to have a turning space (T-Turn or 60 inch circle) and Section 404.2.4 requires doors on accessible routes to provide maneuvering clearances. Both the International Building Code (IBC) and the International Residential Code (IRC) require bedrooms to be at least 70 square feet in size and have a minimum plan dimension of 7 feet. See IBC Sections 1208.1 and 1208.3, and IRC Sections R304.1 – R304.3. Although room shape, door arrangement, and furniture layout all can have significant impact on accessibility within a bedroom, in rooms complying with these model codes, the furniture, accessible route, maneuvering clearances, and required turning space can be arranged so that all are usable if the designer thoughtfully lays out the bedroom and closet doors. Unfortunately, there is no requirement specifying the minimum bedroom size for emergency transportable housing units. Therefore, ensuring that required maneuvering space at doors and turning space is usable becomes much more difficult in such units where bedrooms often are smaller than 70 square feet. Therefore, the subcommittee urged the committee to address this concern by adding a new requirement prohibiting the accessible route, maneuvering clearances, and turning space from overlapping space provided for a bed and a dresser.
Discussion: The committee agreed that the proposed requirement is warranted and they noted that such a requirement could cause designers to be more cognizant of the needs of individuals with disabilities as they lay out rooms and furniture.
Section 809.4 of the guidelines requires that one accessible bathing fixture be provided within a residential dwelling unit. The guidelines do not prescribe whether the accessible fixture must be an accessible bath tub, roll-in shower or transfer stall. However, in transient lodging facilities a percentage of guest rooms must have roll-in showers with seats while the remainder must have either accessible bath tubs or transfer stalls. FEMA noted that in their recent experience over 80% of occupants with mobility-related disabilities requested roll-in showers and that their current practice is to provide roll-in showers with folding seats in accessible units. Noting that fewer design options promote faster deployment of units in emergency situations while more design options facilitate usability and independence by people with disabilities, the subcommittee was concerned that uniformity among units might be at the expense of individuals who cannot use a particular type of bathing fixture. Nonetheless, the subcommittee declined to recommend a scoping provision similar to the one in the transient lodging section of the guidelines. They noted that other Federal requirements exist requiring state and local government programs and programs receiving Federal financial assistance to accommodate individual’s unique disability-related needs. To ensure that people with disabilities are alerted to their disability-related civil rights, the subcommittee recommended that FEMA and the Department of Justice draft advisory notes informing individuals with disabilities of specific laws under their purview which require program operators to provide reasonable accommodations in the event that units do not meet their needs.
Discussion: Committee members discussed the possibility of providing scoping for a variety of bathing options. However, they concluded that requiring a particular percentage of units to contain specific types of bathing fixtures would be unworkable. Unlike the facility-based scoping for transient lodging, emergency transportable housing units are provided on multiple sites within a geographic location and they are usually deployed as needed. Therefore, the total number of units to be deployed would not be known until the need for such units is satisfied. The committee concurred that advisory notes would be helpful. This issue is not unique to emergency transportable housing because, except for transient lodging, the guidelines do not contain scoping requiring facilities to provide a variety of bathing options.
|Recommendation 2: Develop Guidance|
|FEMA and the Department of Justice will provide advisory notes to alert individuals with disabilities regarding their rights to a reasonable accommodation under civil rights laws within their purview if the bathing option offered fails to accommodate their disability specific needs. These advisory notes may be used more broadly within the guidelines.|
Section 809.5.5.1 contains a requirement entirely new to the guidelines which requires audible and visible doorbells to be installed at the entry door to units providing access for individuals with communication disabilities. Two percent of units in a facility must comply with this requirement. The subcommittee questioned whether this feature as well as other related items in the guidelines which provide communication accessibility for individuals who are deaf or hard of hearing should be required in emergency transportable housing units at the time of purchase or should be provided when requested by the occupant. Currently, FEMA provides visible alarms in all accessible units. The subcommittee raised a number of questions related to communication features including whether visible alarms should be required in all accessible emergency transportable housing units and whether the other provisions in Section 809.5.1 and 809.5.5 and 809.5.6 should apply to emergency transportable housing. In any emergency, providing shelter as soon as possible is of paramount importance. Matching individuals with hearing impairments with units specifically designed for their use could cause unnecessary delay. Therefore, the subcommittee questioned whether an acceptable approach would be for occupants of emergency transportable housing with communication disabilities to be provided elements such as visible door bells as a reasonable accommodation. The subcommittee deferred this matter to the full committee and did not provide a recommendation.
Discussion: The committee concluded that Sections 809.5.1 Building Fire Alarm Systems, 809.5.3 Interconnection, and 809.5.6 Site, Building, or Floor Entrance would not apply to emergency transportable housing units because, unlike apartment buildings, multiple transportable housing units are not contained in larger buildings. Based on a straw poll, the committee elected to permit an exception for the visible doorbells required by Section 809.5.5.1 Notification and peepholes required by Section 809.5.5.2 Identification. However, the committee did not recommend an exception to the scoping requirement in Section 233 specifying that two percent of units in a facility or project provide smoke detectors in compliance with 809.5.2 Residential Dwelling Unit Smoke Detection System. These issues are unique to emergency transportable housing units.
Section 811 provides that storage must be within the reach heights specified in the guidelines (15 inches to 48 inches). Also, operable parts cannot require more than five pounds force and must be operable with one hand without tight grasping, pinching, or twisting of the wrist. Despite these requirements, individuals with disabilities reported difficulty accessing storage cabinets, closets and lockers. For example, stored items often migrate to the backs of shelving units where they are out of reach and clothing may be stored too tightly on a clothes rod to enable a person to grasp a hanger and withdraw it from the closet. To address this concern, subcommittee members considered a number of storage options such a telescoping clothes rods, lazy susans and other devices aimed at facilitating greater access. The members of the subcommittee were divided on whether the aforementioned features should be provided in accessible unite or should be provided as a reasonable accommodation only to individuals requiring them. Most of these features are add-on devices that can be provided after-market.
Discussion: The committee did not arrive at consensus regarding this issue because a committee member requested more time to provide examples of storage options, particularly those for kitchen cabinets that could facilitate accessibility. The committee discussed how door arrangements can affect accessibility to closets and cabinets by interfering with the maneuvering space ; however, they declined to develop additional guidance regarding this matter. The committee noted that overall unit size and configuration as well as the small number of base cabinets typically provided in kitchens could impact the availability of storage, including accessible storage. To resolve the debate on this matter, the committee requested that the proponents of revisions clarify whether their recommendations are unique to emergency transportable housing and whether such features can be provided by the housing provider as a reasonable accommodation when needed. Some committee members expressed a strong desire to provide advisory regarding the availability of add-on features rather than to specify them in the guidelines.
Some state and local laws require hotels to provide a clearance beneath beds to facilitate the use of portable lifts by individuals who cannot transfer independently into bed without such assistance. These lifts must be inserted beneath the bed frame in order to operate. The subcommittee requested more time to consider appropriate technical requirements before making a recommendation. Some members of the subcommittee believed that this issue is not unique to emergency transportable housing because bed clearances are not currently addressed in the guidelines for other types of occupancies. Others believed the issue is unique because other types of residential dwelling units do not provide beds and that other types of lifting devices such as those which are suspended from ceilings cannot be accommodated in emergency transportable units due to structural considerations.
Discussion: The committee requested that the subcommittee ensure that bed frames providing recommended clearances are readily available prior to making a recommendation. They also questioned whether bed frames are adjustable to provide varying clearances. This issue could have implications for other types of units addressed in the guidelines.
Emergency transportable housing bedrooms usually have ceiling lights operated by wall switches placed near the door. An individual with a disability is likely to require the light on when transferring into and out of bed. While making the transfer, the light switch located at the door is out of reach. The subcommittee noted that bedrooms in emergency transportable housing generally do not provide excess space for nightstands where a bed lamp could be located. To resolve this issue, the subcommittee recommended a requirement for a secondary means to control the overhead light after transferring to the bed. The requirement would be as follows: If provided, bedroom light fixture shall have three way switches. One light switch shall be installed above head of the bed, 38 inches minimum and 48 inches maximum above the finish floor and shall be located between the centerline of the width of the bed and the open side of the bed. All other controls must comply with 309.
Discussion: The committee concurred that the proposed requirement was needed as is unique to emergency transportable housing.
A member of the subcommittee raised concerns regarding the usability of faucets in kitchen sinks and lavatories. He recommended that faucets be required to be of the gooseneck design and that they provide a water flow closer to the front of the basin. He provided the committee some examples of this type of kitchen faucet which is commercially available. He noted that this type of installation could make it easier for individuals with disabilities to wash dishes in emergency transportable housing units which typically do not have dishwashers. Also, he suggested this type of faucet would facilitate personal hygiene, such as hair washing, at bathroom lavatories, particularly when individuals do not have consistent personal assistance to transfer into showers. Although the subcommittee agreed with the proponent that a related hygiene issue might exist for individuals with disabilities immediately after an emergency, they questioned whether the concerns raised are unique to emergency transportable housing. Therefore, they declined to propose a recommendation for a new requirement because of a lack of supporting data. The subcommittee recommended developing an advisory note recommending gooseneck faucets for greater access and ease of use.
Discussion: Several committee members took issue with the notion that goose neck faucets would resolve accessibility concerns at sinks and lavatories related to performing tasks such as dish and hair washing. Committee members concurred with the subcommittee that the concerns raised are not unique to emergency transportable housing. However, there was general consensus that requiring a water sprayer at the kitchen sink could facilitate pot washing where dishwashers are not part of the unit. Therefore the committee urged the subcommittee to develop such a requirement for their consideration.
Weather alert radios are sometimes installed in emergency transportable housing. Where these are installed in a unit, their controls must comply with Section 309. However, the subcommittee believes that the information provided by the radio must be equally accessible to individuals who either cannot hear the audible alert or who cannot read a viewable alert. As a result, they recommended a provision be added to the guidelines to address the accessibility of controls and requiring both audible and visual output. Additionally, the subcommittee urged the committee to apply this requirement weather radios provided in all types of housing.
Discussion: The general consensus of the committee was that the subcommittee recommendations be accepted. The committee also noted that a bill, HR 2787, introduced in the U.S. Congress would amend the National Manufactured Housing Construction and Safety Standards Act of 1974 to require that weather radios be installed in all manufactured homes manufactured or sold in the United States. Because of concerns regarding the accessibility of certain controls on currently available radios, the advisory committee recommended an exception to the subcommittee’s proposed requirement which would exempt controls on weather radios from the Section 309.4 Operation. That provision would require controls to be operable with one hand, not require tight grasping, pinching, or twisting of the wrist and within 5 pounds force.
The subcommittee presented a definition of the term “emergency transportable housing” which they believed addressed concerns raised by committee members regarding certain limitations on the use of smaller units, such as park models and travel trailers. According to Section 3282.8 Applicability of the Department of Housing and Urban Development (HUD) Manufactured Home Construction and Safety Standards (24 CFR 3290) (HUD Code) these units, which are exempt from the HUD Code, are to be used as “temporary living quarters for recreational, camping, travel, or seasonal use.” Given this limitation and the fact that emergency transportable housing often is used by an occupant for extended periods of time, members of the committee questioned whether such units were appropriate to accommodate individuals affected by disasters.
The subcommittee considered establishing a minimum unit size but ultimately declined to recommend such a requirement because of a concern that the requirement would unnecessarily restrict creativity and potentially could result in the relocation of occupants to alternative living arrangements such as hotels and group sites.
Discussion: Some members of the committee objected to the proposed definition: “Housing designed as a residence or that can be occupied on an emergency basis that is transportable in one section without structural modification to and from a disaster area designated by the authority having jurisdiction for the duration of said designation” on the basis that the terms “housing” and “residence” would place units exempt from the HUD Code in direct violation of that code. For example, units between 320 and 400 square feet are installed in recreation vehicle parks but not in facilities containing manufactured housing. To address these concerns, the committee developed a substitute proposal: “A structure that can be occupied as a dwelling on an emergency basis that is transportable in one section without structural modification to and from a disaster area designated by the authority having jurisdiction for at least the duration of said designation.” The new definition resolved manufacturer’s concerns by using the terms “structure” and “dwelling” which they believed would not imply that their units are to be used as “housing”.
Additional concerns were raised by committee members regarding the phrase “designated by the authority having jurisdiction for at least the duration of said designation.” Their concerns were twofold (1) the term “authority having jurisdiction” was somewhat vague because it could be interpreted to mean one or more governing bodies, e.g. federal, state or local; and (2) there was a question as to whether the proposed definition implies that units deployed during an emergency are not to be considered “emergency transportable housing” when the emergency or disaster proclamation is no longer in effect. These concerns were not resolved. The Federal members volunteered to suggest revisions at the January, 2008 meeting.
Members of the subcommittee agreed that the practice of installing emergency transportable housing on residential sites maintains the fabric of the community and facilitates occupant home security and repairs. According to FEMA, most unit installations are on residential sites, not group sites. Only 5% of units deployed by the Agency on the Gulf Coast are within group sites; 95% of units are on private or commercial sites. Therefore, the subcommittee proposed revisions to the guidelines which would facilitate the installation of units required to accessible on residential property. They acknowledged that physical or legal constraints often limit the amount of space available for an emergency transportable housing unit and therefore they crafted proposals aimed at alleviating the tension between the space demands imposed by compliant accessible units and constrained private residential sites.
The subcommittee’s proposals permit exceptions to requirements for exterior accessible routes only. The subcommittee considered modifications applicable to interior rooms and spaces of accessible units when they are deployed on constrained sites, e.g. permitting one, as opposed to all sleeping rooms, to be accessible. However, they discarded this option because of a concern that provisions promoting reduced accessibility in constrained sites would lead to compromises in accessibility even where sites are not constrained.
The subcommittee recommended limiting exceptions for site constraints to site containing units 600 square feet or smaller. The proposed limitation would discourage trade-offs between unit size and accessibility to exterior features on sites with enough space to accommodate larger units.
Discussion: The committee generally agreed with the approach taken by the subcommittee. However, the committee disagreed that proposed special exceptions for constrained sites should apply only to site containing smaller units. Committee members observed that such a limitation would unnecessarily restrict occupant’s options regarding accessible housing.
Several factors affect the finished floor height of units, including tire size, distance to the sanitary hook-up, and the base flood elevation. FEMA informed the committee that certain requirements prohibit the removal the tires on transportable units. Therefore, the lowest possible elevation is 32 inches for smaller units and, according to FEMA; the average height of units is about 36 inches. Without exceptions to the requirement at Sections 405.2 Slope and 405.6 Rise, a compliant ramp and landing will require 168 to 190 square feet to rise 32 inches. Therefore, where site constraints could negate the opportunity to live on one’s own property, the subcommittee recommended increasing the maximum ramp slope for one single ramp run from 1:12 to 1:10 and permitting a the run to rise pf 36 inches, as opposed to 30 inches, before an intermediate landing is required. These changes, taken together, would permit a single ramp run at 1:10 without an intermediate landing to rise 36 inches maximum. The exceptions can reduce the area consumed by a ramp 16.67%.
Discussion: Although some members of the committee would have preferred an option involving the removal of the tires on the unit to reduce the rise, they agreed that increasing ramp slope and permitting exceptions for maximum rise provided a workable solution where site constraints would prohibit the installation of a complying ramp.
If provided within accessible units, the subcommittee was concerned that slide-outs, which increase square footage within the unit once it is installed on a site, could create conflicts with accessibility. The committee wished to either prohibit slide-outs or be assured that they did not present accessibility concerns.
Accessible routes and accessible space cannot have changes in level greater than 1:2 inch (beveled) and 1/4 inch (vertical). Therefore, the joint between the unit floor and the slide-out floor must essentially be flush. Also, the joint cover must be stable, firm, and slip resistant. An additional question was whether slide-outs are required to be cycled or activated periodically. If so, activating the slide-out would pose extreme difficulty for individuals with disabilities who would need to move furniture before operating the mechanism. Although the subcommittee was assured that joints between slide-out and the adjacent floor can be treated to comply with the guidelines and was provided information regarding manufacturer’s which provide slide-outs activated by switches within the unit, the subcommittee did not resolve whether or not slide-out must be activated from time-to-time. Therefore, they deferred a decision regarding the use of slide-outs to the full committee.
Discussion: Members of the committee representing the industry provided information from manufacturers of electric and hydraulic slide-out which are readily available and which do not require the unit to be exercised. Consequently, the committee refrained from prohibiting slide-outs in emergency transportable housing.
At the request of a committee member, the committee deferred discussion of this topic to the January, 2008 meeting.
Dates: The meeting is scheduled for January 24 and 25, 2007 from 10:00 a.m. to 5:00 p.m. on January 24 and from 9:00 a.m. to 5:00 p.m. on January 25.
Address: The meeting will be held at the Access Board’s offices, 1331 F Street, N.W., suite 1000, Washington, DC.
Minutes prepared by: Marsha Mazz, U.S. Access Board, 1331 F Street, N.W., suite 1000, Washington, DC 20004-1111. Telephone number (202)272-0020 (Voice); (202)272-0082 (TTY). E-mail address: email@example.com.