This guide explains scoping and technical requirements for accessible routes in the ADA Standards.
Where Required: Site Arrival Points
At least one accessible route must be provided within the site to accessible facility entrances from these site arrival points, where provided:
- accessible parking and accessible passenger loading zones
- public streets and sidewalks
- each public transportation stop.
Accessible Routes from Site Arrival Points [§206.2.1]
Accessible Routes within a Site
At least one accessible route within the boundary of the site originating from site arrival points must connect all accessible buildings, facilities, elements, and spaces on a site.
Accessible Routes (Exterior) within a Site
Accessible Routes within a Building or Facility
At least one accessible route must connect all accessible spaces and elements. If a circulation path is interior, the accessible route also must be interior. Accessible vertical interior circulation must be in the same area as stairs and escalators, not isolated in the back of the facility.
Recommendation: In alterations and additions, an accessible route is required where circulation paths are altered or built (§202.3). Also, alterations or additions to areas containing a primary function (a major activity for which a facility is intended) require an accessible path of travel that extends to site arrival points to the extent that the additional cost does not exceed 20% (§202.4). Otherwise, if a space or element is altered, but the circulation path to it is not, an accessible route is not required.
Where Required: Multi-Story Buildings and Facilities
An accessible route must connect each story and mezzanine in a facility unless an exception applies. However, if a building does qualify for an exception in the Standards:
- all other provisions in the Standards still apply to stories and mezzanines not served by an accessible route
- elevators provided anyway must fully comply (as standard or LULA elevators)
- vertical access still may be required by an applicable state or local code.
Private Sector Facilities (Places of Public Accommodation & Commercial Facilities)
An accessible route is not required to connect stories in a private sector facility (place of public accommodation or commercial facility subject to title III of the ADA) that is either less than 3 stories or that has under 3,000 square feet per story and is not a:
- shopping center or mall with 5 or more sales or rental establishments
- professional office of a health care provider
- public transit facility or airport terminal
In mixed use facilities that otherwise qualify for this exception, vertical access is required to any story containing occupancies not permitted the exception.
Public Sector (Government) Facilities
An accessible route between stories is required in multi-story government facilities subject to title II of the ADA except those with no more than two stories where the inaccessible story above (or below) the entry level has no public use space and an occupant load of five maximum.
Exceptions for Specific Occupancies [§206.2.3]
The Standards also include limited exceptions for accessible routes between stories in air traffic control towers and, under certain conditions, detention and correctional facilities, residential facilities, multi-story transient lodging guest rooms, and qualified historic facilities.
Mezzanines (Private and Public Sector Facilities)
An accessible route must serve mezzanines in multi-story facilities where vertical access between stories is required or provided. An accessible route to mezzanines is not required in:
- single story facilities (mezzanines do not count as a story) or
- facilities that are exempt from the requirement for an accessible route between stories (additional conditions apply to restaurants and cafeterias).
Alterations and Additions
In alterations and additions to multi-story facilities, an accessible route to stories and mezzanines is required where a stair or escalator is provided where none existed previously and major structural modifications are necessary (§184.108.40.206). The accessible route must connect each level served by the new stair or escalator (except where a compliant connecting accessible route already exists).
An accessible route to stories or mezzanines may be required as part of an accessible path of travel to primary function areas that are altered or added (§202.4). Alterations or additions involving primary function areas must include an accessible path of travel that extends to site arrival points to the extent that the cost is not “disproportionate” (i.e., more than 20% of the total cost of alterations to the primary function area).
Exceptions for accessible routes between stories and to mezzanines permitted in new construction, including those based on the number of stories or square footage per story, apply fully to alterations and additions, including those that trigger an accessible path of travel to a primary function area.
When Accessible Routes to Stories/ Mezzanines are Required in Alterations or Additions
Accessible Routes to Accessible Spaces and Elements
An accessible route must connect accessible facility entrances with all accessible spaces and elements in a facility that are connected by a circulation path (§206.2.4). Exceptions for accessible routes to stories and mezzanines (§206.2.3 and §206.2.4, Ex. 3) do not extend to level changes within a story or mezzanine that are part of a required accessible route to spaces or elements. These exceptions apply only to the portions of an accessible route that connect stories or that connect a story and mezzanine.
Dining Areas in Restaurants and Cafeterias
In newly built restaurants and cafeterias, an accessible route must serve all dining areas, including those that are raised or sunken or located outdoors (§206.2.5). If a story or mezzanine is exempt from the requirement for vertical access, an accessible route within each story or mezzanine is still required to connect dining areas and other spaces and elements even though an elevator (or ramp) does not serve the story or mezzanine.
Recommendation: In alterations, an accessible route is not required to existing raised/ sunken dining areas or to all parts of outdoor dining areas if the same services and decor are available in other dining areas that are accessible (§206.2.5, Ex. 2). A platform lift (or limited use-limited application elevator) can be used to provide access to such areas in alterations, but not in new construction (§206.7).
An accessible route must connect stages and other performance areas directly to seating areas where they are directly connected by a circulation path as well as to dressing rooms and other ancillary spaces used by performers (§206.2.6).
An accessible route is required to press boxes except where the aggregate area of all press boxes serving a playing field or assembly area is no more than 500 sq. ft. if press boxes are either:
- free-standing and elevated above grade at least 12’ or
- located in bleachers with points of entry on one level.
Employee Work Areas
Common use circulation paths must be accessible in employee work areas that are 1,000 sq. ft. or more in size. This applies to the size of work areas as defined by permanently installed walls, partitions, counters, casework, or furnishings, but not modular partitions or furnishings, including systems furniture. Other portions of areas used only by employees for work are not required to comply.
This requirement does not apply to employee work areas that are either less than 1,000 sq. ft. in size or that are exterior and fully exposed to the weather. However, these types of employee work areas still must be accessible for “approach, entry, and exit” (§203.9). This requires a connecting accessible route to the work area, a compliant entrance, including entry doors or gates, and a wheelchair space within the work area. Work areas must also be served by an accessible means of egress, as required by the International Building Code. (See the ADA Scoping: New Construction Guide.
Common Use Circulation Paths in Employee Work Areas Over 1,000 SF
Recreation Facilities [§206.2.9 – §206.2.17]
The ADA Standards also address accessible routes to amusement rides, boating facilities, bowling lanes, court sports, exercise machines and equipment, fishing piers and platforms, golf and miniature golf facilities, and play areas.
Components of accessible routes include walking surfaces, doorways, ramps, curb ramps, elevators, and, where permitted, platform lifts.
Components of Accessible Routes
The minimum 36” continuous clear width of accessible routes can reduce to 32” at points, such as doorways, for a maximum distance of 24”. Greater clearance is required for 180 degree turns around narrow obstructions and for wheelchair turning space. The minimum clearance cannot be reduced by any elements, including handrails or protruding objects.
180 Turns Around Obstructions
Additional clearance is required at 180 degree turns around an element that is less than 48” wide. The clear width must be at least 48” at the turn and 42” minimum approaching the turn (unless the clear width at the turn is 60” minimum).
Passing space is required every 200 feet and must be provided as a 60” by 60” minimum space or as T-shaped space where each stem is at least 48” long.
Handrails Along Walking Surfaces
Handrails are required at ramps with a rise greater than 6” and at stairs that are part of a means of egress, but not at other locations. Where handrails are provided along other portions walking surfaces, they must comply. (Handrails provided in elevator cabs or on platform lifts are not required to comply).
Handrails along Walking Surfaces
- 34” to 38” high measured to the top of the gripping surface.
- Gripping surface must be continuous the full length and top and sides cannot be obstructed.
- The bottom gripping surface can be obstructed up to 20% of the length (or along the full entire length when part of crash rails or bumper guards).
- No sharp or abrasive elements on gripping surfaces or adjacent surfaces, and no rotation within fittings.
Surface requirements and clearances facilitate a power grip along the length of handrails. Handrails can have circular or non-circular cross-sections, but must have rounded edges. The gripping surface and adjacent surfaces must be free of abrasive or sharp elements.
Circular Cross Section and Clearance (§505.5, §505.7)
Non-Circular Cross Section and Clearance (§505.5, §505.7)
If no pedestrian route onto a site is provided, is an accessible route still required?
An accessible route from the boundary of the site is not required where the only means of site arrival is a vehicular way without pedestrian access. Where vehicular ways are also intended to accommodate pedestrian travel, such as a shopping center parking lot, an accessible route is required.
Do accessible routes that cross vehicular ways need to be marked as a crossing?
No, accessible routes that cross vehicular ways are not required by the Standards to be marked as a crossing. The Standards only require access aisles at accessible parking spaces and accessible passenger loading zones to be marked. (Local codes and traffic laws may require crossings to be marked).
Do stories not required to be on an accessible route have to comply with the Standards?
Yes, stories (and mezzanines) not connected by an accessible route must still meet all other applicable requirements in the Standards. This ensures access for people with disabilities who can use stairs and facilitates compliance should vertical access be achieved through later renovations or additions.
Do basements count in determining a facility’s story count?
As defined in the Standards, a “story” pertains to those portions of buildings “designed for human occupancy included between the upper surface of a floor and upper surface of the floor or roof next above” (§106.5). A basement or other level below grade designed for human occupancy (i.e., equipped with lighting, ventilation, and means of egress) counts as a story. Basements or other levels not containing any space designed for human occupancy are not considered stories under the Standards.
Is an accessible route required to rooftop levels?
In facilities where an accessible route is required to each story (§206.2.3), an accessible route must serve rooftop levels that contain public or common use spaces or elements that are required to be accessible, such as sun decks, lounges, dining areas, bars, or swimming pools. An accessible route is not required to rooftop levels in those facilities that are exempt from the requirement for an accessible route to each story based on the number of stories or the square footage per story. In determining whether a facility qualifies for this exception, rooftop levels are not counted as a story unless they meet the definition of “story.” The Standards define a story as “that portion of a building or facility designed for human occupancy,” (i.e., equipped with lighting, ventilation, and means of egress) that is “included between the upper surface of a floor and upper surface of the floor or roof next above” (§106.5).
Do the exceptions for accessible routes between stories apply to facilities that are only partially occupied by entities not permitted the exception, such as health care facility or shopping center?
Accessible routes between stories are not required in private sector facilities that are either less than 3 stories or that have less than 3,000 square feet per story excluding the professional offices of health care providers, shopping centers and malls with at least 5 sales or rental establishments, and public transit facilities, including airport terminals. In mixed use facilities that otherwise qualify for this exception, an accessible route is required to serve each story containing occupancies not permitted the exception. For example, if all sales or rental establishments of a shopping center are on the same story, an accessible route is required only to that story. If located on multiple stories, an accessible route must connect to each story that contains a sales or rental establishment.
When alterations are made on an upper story of a facility, is vertical access required?
If an alteration includes installation of a stair or escalator where none existed previously and involves major structural modifications, an accessible route between levels served by the stair or escalator is required (unless an accessible route already exists). If alterations are made to a primary function area on an upper floor, an accessible path of travel to the area is required to the extent that the cost is not disproportionate (i.e., more than 20% of the cost of the overall alteration). In any alteration, an accessible route between stories is not required in a facility that qualifies for those exceptions permitted in new construction based on the number of stories or square footage per floor.
When an addition increases the number of stories or square footage beyond the maximum permitted by the exception, is an accessible route between stories required?
If a facility no longer qualifies for the exception for multi-story facilities due to an increase in square footage or stories, an accessible route between stories is required where the work also includes installation of a stair or escalator where none existed previously and major structural modifications are needed (unless a compliant accessible route between stories already exists). The accessible route must connect the levels served by the new stair or escalator. Also, if the addition includes a primary function area, an accessible path of travel to the primary function area is required, including where it involves travel between stories or levels, to the extent the cost does not exceed 20% of the cost of the overall alteration. Compliance in an alteration, including with the requirement for an accessible route between stories, is not required where it is “technically infeasible.” In this case, compliance is required to the maximum extent feasible.