General Issues

The ADAAG Review Advisory Committee recommended significant changes to the format and style of ADAAG. In fact, their recommendations completely reorganize much of ADAAG. The changes were recommended to provide a guideline that is organized and written in a manner that can be more readily understood, interpreted and applied. The recommended changes would also make the arrangement and format of ADAAG more consistent with model building codes and industry standards. This will make it easier for designers of the many facilities that will be required to comply both with the ADAAG and the locally adopted codes to understand how to comply with both sets of provisions. Changes include:

  • removal of text language that is non-mandatory in nature for inclusion as advisory information nearby the text it comments on;
  • inclusion in written text of requirements otherwise provided only in figures;
  • clearer delineation between scoping requirements, which indicate what has to be accessible, from technical requirements, which specify how access is to be achieved;
  • organizing technical sections into chapters according to the type of element or space;
  • streamlining the guidelines by integrating special occupancy chapters (except for transportation facilities) into the main body of the document;
  • revising the substance of scoping and technical provisions to better meet the needs of people with disabilities, to recognize technological developments, and to reconcile differences from national consensus standards; and
  • utilizing a decimal-based, numeric-only numbering system, consistent with that used by the model codes and utilizing, to the extent possible, identical chapter and section numbers as ICC/ANSI A117.1 for the comparable subject matter.

Some changes are recommended in order to make the provisions in ADAAG more technically consistent with model building codes and industry standards. The advisory committee coordinated closely with the American National Standards Institute (ANSI) A117 Committee, which was in the process of updating its standard. This is a national consensus standard that provides technical requirements for accessible buildings and facilities. The Council of American Building Officials (CABO) was represented on the advisory committee. CABO, which functions as a coordinating body among model code organizations, serves as the Secretariat for the A117 Committee. CABO has been incorporated into the International Codes Council (ICC). While ADAAG requirements derive in large part from an earlier version of the ANSI standard, there are considerable differences between them. Both the advisory committee and the ANSI committee sought to reconcile these differences to harmonize the revised ADAAG with the ICC/ANSI A117.1-1998 standard.

The Board reviewed all recommendations from the advisory committee and has adopted most of them with some changes of its own. In addition, the Board has developed new figures to illustrate various provisions and provided new advisory notes that provide information currently contained in the appendix to ADAAG. In removing non-mandatory information from the text of the guidelines, the advisory committee made various recommendations on information that should be included in advisory notes. The Board has taken these recommendations into account in developing advisory notes for this proposed rule.

The application and scoping requirements (Chapters 1 and 2) for facilities covered by the ADA have been used as the basis for updating application and scoping requirements for facilities subject to the ABA. The technical requirements of this rule, as revised according to the advisory committee recommendations, are referenced by both scoping documents.

In addition, the Board has included scoping and technical requirements for accessible residential facilities. These requirements are based on updated provisions for residential facilities contained in the ICC/ANSI A117.1-1998 standard. These requirements represent an addition to ADAAG, which currently does not address such facilities. Also, they will serve to update requirements for dwelling units in the minimum guidelines for federally funded facilities upon which UFAS is based.