Advisory Committee Report

The committee did not attempt to reach consensus for the items contained in this Appendix. However, each item was discussed by the committee which ultimately did not take a position because they either: (1) had very broad application to all types of housing and construction addressed by the guidelines; or, (2) involved a subject that could require significantly more resources than were available to the committee. In deciding not to provide recommendations for these three items, the committee was mindful that its membership, while diverse, might not reflect the interests of all affected stakeholders potentially interested in these specific matters. The committee determined that each of these items deserves study by the Access Board, itself, or a different committee with a different focus.

Kitchen Storage
The committee suggests that the Access Board review Section 804.5 which requires fifty percent of kitchen storage to be within reach, have clear floor space and to provide accessible hardware. The committee believes that, as written, the provision requires above counter storage units to be located so that the lowest shelf is 48 inches above the floor. Consequently, the bottom edge of the storage unit is approximately 10 inches above countertops. This requirement would possibly adversely impact usability of the countertop by reducing the vertical clearance above them in a way that would impede the placement of appliances and other kitchen equipment at the back of the countertop.

While the committee believes that providing access to fifty percent of the storage space in kitchens in emergency transportable housing would be difficult, greater accessibility could potentially be accomplished by using pull-out shelves and other accessible storage devices.

Finally, the committee also questions how to measure shelf space according to the existing requirement for fifty percent of “shelf space in storage facilities” to be within reach. Does this requirement apply to the length of shelves at the front edge or to the overall volume of storage provided by the shelving? The committee does not believe that this subject is unique to emergency housing units.

The committee was concerned that emergency 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 committee discussed the possibility of adding a new requirement to Section 804.5. The new requirement would specify that emergency housing units must provide at least one shelf of all base cabinets and storage shelves mounted above countertops at 48 inches high maximum. This included a discussion to exempt cabinets located above refrigerators, ranges and cook tops.

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. A few members of the committee suggested that consideration should be given to storage alternatives which facilitate reach such as pull-out shelving. The committee also discussed how any such 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, in particular, is not unique to that type of housing.

Bed Clearance
The committee suggests that the Access Board review the need to establish requirements for bed heights to facilitate transfer from a wheelchair and clear space under a bed to accommodate a portable lift.

The committee considered developing technical provisions to address this issue but determined that it is not unique to emergency housing. Providing appropriate bed heights and clearances for lifts will permit safer transfer from a wheelchair in all types of occupancies where beds are provided with the unit. 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 properly.

The committee notes that bed clearances are not currently addressed in the guidelines for other types of occupancies. Some committee members believe the issue is unique to emergency housing because other types of residential dwelling units do not provide beds (except for hotels and motels). They also observed 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.

The committee considered that some, but not all bed frames may be adjustable enough to provide varying heights. Like clearance beneath the bed, requirements for bed heights would have implications for other types of facilities addressed in the guidelines.

Indoor Environmental Quality (IEQ)
The committee does not believe that this subject is unique to emergency housing units. IEQ has broad implications for every building and structure. Much of the potential problem associated with IEQ has a direct correlation to the climate, construction materials, furnishings and contents, among other factors.

IEQ issues were included within the committee’s scope. The committee believes that the concerns of individuals with multiple chemical sensitivities (MCS) are within the Access Board’s authority and responsibility. IEQ was identified early in the committee process as an issue affecting occupants of emergency housing units. The committee received valuable input on this subject in general and in particular, information concerning formaldehyde and volatile organic content (VOC) materials. Knowledgeable committee members and members of the public provided input regarding problems associated with IEQ. Almost every meeting and conference call included some discussion on the subject. Nonetheless, at the conclusion of the committee’s deliberations the committee did not believe that it had the expertise or information to address the problem. There were simply too many issues and variables, materials, environmental dependencies and source research materials for the members of the committee to consider. The committee is aware of no less than ten agencies and non-government organizations that are concerned with this issue including: the California Air Resources Board, Centers for Disease Control, Federal Emergency Management Agency, New York City Office of Emergency Management, National Center for Environmental Health Strategies, National Council on Independent Living, Sierra Club, U.S Department of Housing and Urban Development, U.S. Environmental Protection Agency and U.S. Green Building Council.

Consequently, the committee urges the US Access Board respond to concerns regarding IEQ, possibly by developing an action plan and working proactively with other federal agencies and private sector groups to resolve concerns raised by the disability community and others.