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Access Board Holds Public Forum Meeting on Assembly Areas

September 21, 2018

On September 6, the Access Board held a day-long public forum on accessibility of assembly areas. The event brought together experts on the subject and various stakeholders to advise the Board on how to explain and clarify requirements in the ADA Standards in a technical guide it plans to develop on the subject. Accessibility consultants, people with disabilities, architects and designers, engineers, and facility operators participated in the meeting. Attendees included representatives from the Hearing Loss Association of America and other advocacy organizations, the International Code Council, trade associations such as the National Association of Theater Operators and the American Society of Theatre Consultants, seating manufacturers, performing arts facilities, including Carnegie Hall and the Kennedy Center, federal agencies, and other entities.

The Board convened this meeting to collect information and input from the public on access issues and design questions and challenges that are unique to various types of assembly spaces. It will use this information in preparing a technical bulletin on assembly areas as part of its Guide to the ADA Standards, as well as its Guide to the ABA Standards.

In opening the meeting and welcoming attendees, Board Vice Chair Karen Tamley, stated, “We want to hear about access problems that people continue to face in this type of occupancy. We also want input on what is unclear or confusing in following the ADA and ABA Standards in the design and construction of assembly spaces.” The Board also welcomed suggestions on solutions to design challenges and recommended best practices for achieving accessibility to different types of assembly venues.

The discussion that followed identified questions that often arise in meeting requirements for wheelchair spaces, including criteria that can work at cross purposes, such as specifications for integration and for sightlines. It also addressed access issues and compliance concerns relating to companion seating, designated aisle seats, communication access, including assistive listening systems and captioning, and other features of assembly areas. In addition, participants raised issues and questions concerning specific types of seating and assembly venues, including bleachers and telescopic seating, movie theaters, and assembly spaces equipped with dining or work surfaces, such as dinner theaters and lecture halls. They also addressed questions that are driven by new design trends, such as reclining theater seats and tiered seating along stairs or “social stairs.” Common sources of confusion or oversight were highlighted as well, such as calculating sightlines, distinctions between aisles, aisle accessways, and other components of circulation paths, and how egress requirements impact the design of assembly spaces, including the location of wheelchair spaces.

The Board will use this information to prepare a technical bulletin on assembly areas as part of its online guides to the ADA and ABA Standards. These guides currently cover the first five chapters of the standards. They also include a series of eight animations on different topics covered in the standards.

Access Board Information Meeting on Assembly Areas
September 6, 9:30 – 5:00 (ET)
1331 F Street, NW, Suite 800, Washington, D.C.

Issues, Questions, and Best Practices to Address in Technical Guidance on Assembly Areas

Wheelchair Spaces

  • How to balance integration of spaces while achieving adequate sight lines (especially over standing spectators): what are available solutions?
  • Recommend better identification of numbers at wheelchair spaces (e.g., on floor) since it can be unclear when provided on removable seats
  • Many users prefer entry from the back instead of from the side
  • Recommend that some wheelchair spaces be paired to accommodate families and groups needing multiple wheelchair spaces
  • Clarify what is and is not acceptable as “individual, removable” seats (e.g., products that require removing bolts etc.) spaces; consider disallowing types requiring tools for removal
  • Provide recommendations for cup holders, drink rails, and similar amenities, including location to the side instead of in front


  • Determining when spectators are expected to stand or remain seated is challenging, especially since it can vary based on the type of event, performance, or sport. Which condition should one design for? To what degree can one design for all scenarios? Guidance is strongly needed on making this determination.
  • Basis should be on whether line of sight is necessary to view event (e.g., exclude standing for ovations/applause)
  • Include diagrams showing how sightlines are calculated
  • Clarify calculations of sightlines and percentages of viewing angles (some building officials make determinations based on seat count)
  • Consider whether standing is part of participating in an event; also, whether sightline is expected during times when spectators stand
  • Dispersion of wheelchair spaces (e.g., in different quartiles) can lead to placement in less desirable locations
  • How should non-typical seating (e.g., recliner seats) that impact sightlines be addressed?

Companion Seats

  • Recommend that multiple companion seats be available at wheelchair spaces
  • Consider as a best practice features, such as retractable armrests, for those who may wish to transfer from a mobility aid to a companion seat that reclines
  • Clarify both shoulder alignment (horizontal) and vertical alignment (surface of space and companion seat must be at same elevation)
  • Seating for people who are deaf/blind – shoulder-to-shoulder seating not sufficient; need to face each other at 45° angle

Bleachers/ Telescopic Seating

  • Show good examples of designs that satisfy integration, alignment, and sightline criteria – integration can make alignment challenging
  • Wheelchair spaces next to seat attached to deck violate requirement for companion seat to be at same elevation as wheelchair space
  • Address issue of barriers at drop-offs created by wheelchair spaces (code requirements for drop-offs > 30”)
  • Illustrate multiple examples of bleachers and aisle accessways/ aisles in different venues
  • Address questions that arise in the use of temporary bleachers that may have just 2 or 3 rows (often used for parades, little league games, etc.)

Designated Aisle Seats

  • Explain intent and rationale to serve people who are ambulatory but may have difficulty walking between rows of seats (not intended for seats to transfer to from wheeled mobility aids, which block egress routes)
  • How should they be marked? (The ICC A117.1-2009 required the ISA but the next edition (2017) reverted back to the requirement for a “sign or marker.”)
  • Encourage folding armrests on all aisle seats as a best practice
  • If all aisle seats have folding armrests, is designation required? (While there is not a specific exception for these signs, there are for those labelling restrooms, entrances, and check-out aisles when all comply.)
  • Address issues with aisle lighting

Communication Access

Assistive Listening Systems (ALS)

  • Many factors will determine which ALS is best for a facility – explain them
  • Use of multiple systems (e.g., FM and IR) may be advisable
  • Issues with the quality of assistive listening systems
  • ALS system maintenance is important (e.g., checking receiver batteries) and staff training
  • Loop systems provide a better experience for those with telecoil hearing aids and no receiver; however, the ability to use ALS that can also be used for audio description may discourage use of loop systems
  • Neckloops often lack sufficient volume because they require a stronger signal than other receiver types and because of improper set up and equipment testing [briefing paper on subject submitted]
  • See new provisions in the ICC A117.1-2017 for microphone setup (which makes a big difference in the signal quality and should be addressed in guidance)
  • Best practice: install loop systems ticket windows (code requirement) and at concession stands
  • Address effective communication in venues without audio amplification

Captioning and Variable Message Signs

  • Issue in stadiums and arenas: handhelds provided instead of ribbon boards
  • Need further requirements for captioning in venues other than movie theaters (DOJ regulations are in effect for movie theaters.)
  • Technical standards for captioning are needed (e.g., cap height, font, etc.).
  • Captioning needs to be provided in multiple locations in stadiums for visibility; also, on monitors and screens throughout stadiums (especially since ribbon boards can be obstructed), including for emergency communication
  • Concerns expressed about reliability of captioning glasses
  • See requirements for variable message signs in the ICC A117.1

Sign Language Interpretation

  • Need adequate lines of sight to ASL interpreters
  • The ICC A117.1-2017 contains new specifications for sign language interpreter stations

Dinner Theaters

  • Clarify how to apply standards to assembly spaces with dining surfaces (see new language in 802.1 of the ICC A117.1-2017)
  • Seating at tables sometimes oriented 90° toward performance area; address best practices (e.g., space that allows people using wheelchairs to orient toward dining surface and to performance area)

Places of Education

  • Clarify how to apply standards to lecture halls and other assembly areas with fixed work surfaces (see new language in 802.1 of the ICC A117.1-2017; A117.1 Committee consensus was to treat them as assembly seating but to also apply work surface technical criteria)
  • There are significant impacts in treating tiered spaces as work surfaces but not assembly seating (e.g., access to each floor level)
  • Address how presence of fixed or non-fixed seating impacts application
  • It is important to address access to stage equipment used by students; accessible alternatives to counterweight systems are available

Other Topics

  • Address common errors or issues at various types of temporary venues
  • Address best practices to improve the visibility of row and seat signs in dark conditions
  • Provide guidance on access to self-service devices (e.g., ticket purchase machines with touch screens)
  • Excessive opening force of doors to movie theaters
  • Practice rooms in musical institutions have sound lock and acoustical properties that cause access issues at doors (e.g., thresholds)
  • Note building code requirements for additional compliant compartments and access features in restrooms with more than 20 toilet fixtures
  • Address need for adult changing tables, family restrooms

Accessible Routes, Aisles, and Access Accessways

  • Explain difference between aisles and aisle accessways in relation to requirements for accessible routes and wheelchair spaces
  • Achieving proper shoulder alignment can impact aisle accessway

Accessible Means of Egress (AMOE)

  • It is important to show how requirements for AMOE, including those in the referenced IBC, impact design of assembly areas, including location of wheelchair spaces, as they are often not fully understood or properly applied
  • Illustrate examples of AMOE in different types of venues (e.g., theater, bleacher seating, etc.)
  • Some states have different egress requirements (e.g., California requires the same number of AMOE as required MOE)
  • Explain differences between MOE, AMOE, accessible routes in relation to certain types of venues and seating areas (e.g., determining the minimum required route width at court-side wheelchair spaces)

“Social Stairs”

  • Growing use of designs that function as both stairs and seating areas
  • These are unique from assembly seating in that they serve equally as stairs between levels or stories
  • Code references (e.g., “stepped aisles”) will likely lead to designs that do not conform as stairs
  • Unique dangers posed to people with vision impairments; pose significant general safety issues and may violate safety codes
  • Challenges for integrating wheelchair spaces
  • 2018 IBC proposal addresses changes to handrail requirements
  • Some are designed primarily for social gathering instead of as an assembly space
  • Consider scoping impacts if they are considered floor “levels” (i.e., accessible route to each one) v. assembly seating

Assembly Area Meeting Attendees

  • Richard Acree, ADA Inspections Nationwide, LLC
  • Mary Adams, Disability Rights Section, U.S. Department of Justice
  • Brian Bard, U.S. Department of Health and Human Services
  • Ester Baruh, National Association of Theater Operators
  • Jimmy Bell, Access by Design
  • Gail Blankman, Disability Rights Section, U.S. Department of Justice
  • Gene Boecker, CCI for the National Association of Theater Operators
  • Jay Cardinali, Disney Parks
  • Bill Connor, American Society of Theatre Consultants
  • Alexis Daniel, Disability Rights Section, U.S. Department of Justice
  • Sarah DeCosse, Disability Rights Section, U.S. Department of Justice
  • Ida Dugas, Hussey Seating Company
  • McKenzie Elliott, National Association of Theater Operators
  • Tom Ellis, RAS, APA, Accessibility Professionals Association
  • Sloan Farrell, U.S. Department of the Interior
  • Mark Goeller, U.S. Department of Veterans Affairs
  • Kim Goss, Access by Design
  • Peter Huitzacua, Carnegie Hall
  • Teresa Jakubowski, Barnes & Thornburg LLP
  • Edwina Juillet, Fire & Life Safety for People with Disabilities
  • April Kitck, Assistant to Betty Siegel
  • Dominic Marinelli, United Spinal Association
  • Marsha Mazz
  • Maureen McKeron, Universal Design & Consultants
  • Gail Mottola, Let’s Open Doors
  • Beryl Neuman
  • Irene Byrne Ohl, Texas Scenic Co, NE Office
  • Kimberly Paarlberg, International Codes Council
  • Jake Pauls, Jake Pauls Consulting Services
  • Ed Roether, Ed Roether Consulting
  • Betty Siegel, The Kennedy Center
  • Raymond Smith, Raymond Smith Law
  • Veronica Davila Steele, Hearing Loss Association of America, Prince George’s County Chapter
  • Stephen Strobach, Epstein, Becker & Green
  • Steve Terry, ETC
  • Duane Wilson, American Society of Theatre Consultants
  • Keith Wortman

Access Board Members

  • Karen Braitmayer
  • Pat Cannon
  • Gregory Fehribach
  • Marc Guthrie
  • Chris Hart
  • Mathew McCollough
  • Sachin Pavithran
  • Victor Santiago Pineda
  • Howard Rosenblum
  • Debra Ryan
  • Shelley Siegel
  • Karen Tamley

Access Board Staff

  • Bill Botten
  • David Capozzi
  • Aromie Noe
  • Frances Spiegel
  • Scott Windley
  • Dave Yanchulis