“What if neither ADAAG nor UFAS contain specific standards for a particular type of
In such cases, the technical requirements of the chosen standard should be applied to the
extent possible. If no standard exists for particular features, those features need not
comply with a particular design standard. However, the facility must still be designed
and operated to meet other title II requirements, including program accessibility.
ILLUSTRATION: A public entity is designing and constructing a playground. Because
there are no UFAS or ADAAG standards for playground equipment, the equipment need
not comply with any specific design standard. The title II requirement for equal
opportunity and program accessibility, however, may obligate the public entity to provide
an accessible route to the playground, some accessible equipment, and an accessible
surface for the playground.”
--DOJ Title II Technical Assistance Manual
ADAAG 3.5 Definitions.
Accessible Route. A continuous unobstructed path connecting all accessible elements and
spaces of a building or facility...
Exterior accessible routes may include parking access aisles, curb ramps, crosswalks at
vehicular ways, walks, ramps, and lifts.