Detectible Warning Depth

Question:  What is the depth requirement for detectable warnings at curb ramps?

The Americans with Disabilities Act Accessibility Guidelines (ADAAG) written by the U.S. Architectural and Transportation Barriers Compliance Board (Access Board) and published July 26, 1991, includes the following section:

4.29 Detectable Warnings.

4.29.5 Detectable Warnings at Hazardous Vehicular Areas.

“If a walk crosses or adjoins a vehicular way, and the walking surfaces are not separated by curbs, railings, or other elements between the pedestrian areas and vehicular areas, the boundary between the areas shall be defined by a continuous detectable warning which is 36 inches wide, complying with 4.29.2.”

The Americans with Disabilities Act (ADA) recognizes and protects the civil rights of people with disabilities and is modeled after earlier landmark laws prohibiting discrimination on the basis of race and gender.  To ensure that buildings and facilities are accessible to and usable by people with disabilities, the ADA establishes accessibility requirements for sate and local government facilities, places of public accommodation, and commercial facilities.  Under the ADA, the Access Board has developed and continues to maintain design guidelines for accessible buildings and facilities; these guidelines are known as the ADAAG.  ADAAG covers a wide variety of facilities and establishes minimum requirements for new construction and alterations.

The Revised Draft Guidelines for Accessible Public Rights-of-Way, written by the Access Board and published November 23, 2005, includes:

Chapter R3 Technical Provisions.

R304 Detectable Warning Surface.

R304.1.4 Size.

“Detectable warning surfaces shall extend 24 inches minimum in the direction of travel and the full width of the curb ramp (exclusive of flares), the landing, or the blended transition.”

Now we have a 36 inch requirement in a 1991 Access Board guideline and a 24 inch requirement in an 2005 Access Board guideline.  The Access Board is the U.S. Government agency responsible for writing the design guidelines for buildings and facilities to be in compliance with the ADA.  

In the opinion of ACCESS, the 24 inch detectable warning depth is in compliance with the ADA Compliance.

The above are opinions of Hank Falstad, AIA, Managing Senior Associate of Access Technologies Services, Inc. (ACCESS).  See our web site for additional information:  http://www.accessts.net/.

Is There a Location Requirement for Toilet Seat Cover Dispensers in the Wheelchair Accessible Toilet Compartment?

The answer is yes and no.  ADAAG; Final Rule Section 604 deals with water closets and toilet compartments.  Section 604.7 deals with dispensers, but specifically mentions only toilet paper dispensers.  So the answer is no if one is looking for a specific section for toilet seat cover dispensers.

One has to look at other applicable sections for the answer.  Section 308 Reach Ranges is applicable, plus section 609 Grab Bars / 609.3 Spacing Requirements above and below the grab bar.  Section 308 states that the maximum unobstructed reach range is 48 inches above finish floor, so ACCESS says the designed unobstructed reach range should be 45 inches above finish floor to the center of the opening of the toilet seat cover dispenser.  When the toilet seat cover dispenser is surface mounted, Section 609.3 Spacing comes into play:

609 Grab Bars.

609.3 Spacing.

“The space between the grab bar and projecting objects below and at the ends shall be 1 ½ inches minimum.  The space between the grab bar and projecting objects above shall be 12 inches minimum.”

If the seat cover dispenser is recessed into the wall, the dispenser would not be considered a “projecting object” and Section 609.3 would not apply.

Let us know your comments here or you can post them on our FaceBook http://www.facebook.com/pages/Access-Technologies-Services-Inc/268659564730.  You can reach us at hfalstad@accessts.net or contact us at (702) 649-7575.

The above are opinions of Hank Falstad, AIA, Managing Senior Associate of Access Technologies Services, Inc. (ACCESS).  See our web site for additional information:  www.accessts.net.

How Does One Design Space for an Accessible Refrigerator / Freezer?

The answer is found in the ADAAG; Final Rule, written by the Access Board, published July 23, 2004, with an effective date of September 21, 2004. 

ADAAG Chapter 2: Scoping Requirements is silent on the refrigerator / freezer.  The answer is found in Section 804.6.6:

804 Kitchens and Kitchenettes.

804.6.6 Refrigerator/Freezer.

804.6.6 Refrigerator/Freezer.

“Combination refrigerators and freezers shall have at least 50 percent of the freezer space 54 inches maximum above the finish floor or ground.  The clear floor or ground space shall be positioned for a parallel approach to the space dedicated to a refrigerator/freezer with the centerline of the clear floor or ground space offset 24 inches maximum from the centerline of the dedicated space.”

1.
In the opinion of ACCESS, to meet the freezer space 54 inch maximum height requirement, a side-by-side unit is required.

2. The clear floor space from Section 305 is 30 by 48 inches minimum and requires a parallel approach.  This will require both doors to open 180º.

3. The actual clear floor space will be greater than 48 inches because the centerline of the dedicated space is required to be offset by 24 inches, so it must be offset for both the freezer and the refrigerator.

4. The manufacturer recommends a 2 inch clearance at the back of the unit, and a 1 inch clearance on both sides of the unit.

There is no way a clear floor space for a refrigerator / freezer placed in the corner will work!

A similar answer is found in ICC/ANSI A117.1-2003 Commentary in Section 804.6.6 and Figure C804.6.6:

Chapter 8 Special Rooms and Spaces.

804 Kitchens and Kitchenettes.

804.6 Appliances.

804.6.6 Refrigerator/Freezer.

“Combination refrigerators and freezers shall have at least 50 percent of the freezer compartment shelves, including the bottom of the freezer, 54 inches maximum above the floor when the shelves are installed at the maximum heights possible in the compartment.  A clear floor space, positioned for a parallel approach to the space dedicated to a refrigerator/freezer, shall be provided.  The centerline of the clear floor space shall be offset 24 inches maximum from the centerline of the dedicated space.”

The above are opinions of Hank Falstad, AIA, Managing Senior Associate of Access Technologies Services, Inc. (ACCESS).  See our web site for additional information:  www.accessts.net

You can post any comments here or on our FaceBook page at http://www.facebook.com/pages/Access-Technologies-Services-Inc/268659564730.  You can also contact us at hfalstad@accessts.net or call us at (702) 649-7575.  We look forward to hearing from you.

Where is the dimension for peep holes in accessible doors and voice holes in glass dividers?

The answer is found in the ADA Accessibility Guidelines for Buildings and Facilities, written by the Architectural and Transportation Barriers Compliance Board (Access Board), published July 26, 1991; Section A4.2.4 Clear Floor or Ground Space for Wheelchairs.

4.2 Space Allowance and Reach Ranges.

A4.2.4 Clear Floor or Ground Space for Wheelchairs.

“The wheelchair and user shown in Figure A3 represents typical dimensions for a large adult male.”

A similar figure is found in ICC/ANSI A117.1-2003 Commentary, Section 102 Anthropometric Provisions:

102 Anthropometric Provisions.

“The technical criteria in this standard are based on adult dimensions and anthropometrics.” 

Also, Figure C102(a) shows eye level at 43 – 51 inches. 

So, in the opinion of ACCESS, the design for eye level should be 47 inches above finish floor to the centerline of the peep hole, or 46 inches when measured from the bottom of the door. 

The distance from the centerline of the eye to the mouth is approximately 3 inches; therefore in the opinion of ACCESS, the centerline of the speaker hole in the glass design dimension should be 44 inches above finish floor.

If you have any comments or thoughts on the above posting, please post here or on our FaceBook page at http://www.facebook.com/pages/Access-Technologies-Services-Inc/268659564730.  Or you can contact us at hfalstad@accessts.net or call us at (702) 649-7575.

Hank

The above are opinions of Hank Falstad, AIA, Managing Senior Associate of Access Technologies Services, Inc. (ACCESS).  See our web site for additional information:  www.accessts.net.

In a shopping center, where is the shortest accessible route to an entrance?

This design guideline comes from the ADAAG; Final Rule, published July 23, 2004, with an effective date of September 21, 2004.  ACCESS uses ADAAG; Final Rule Section 208.3.1:

208 Parking Spaces.

208.3 Location.

208.3.1 General.

“Parking spaces complying with 502 that serve a particular building or facility shall be located on the shortest accessible route from parking to an entrance complying with 206.4.  Where parking serves more than one accessible entrance, parking spaces complying with 502 shall be dispersed and located on the shortest accessible route to the accessible entrances.”

Shopping centers could be small strip centers with 50 parking spaces, or large shopping centers with 2,000 or more parking spaces.  Some shopping centers will have a fire lane along the sidewalk in front of the stores.  Some shopping centers will have parking along the sidewalk in front of the stores – this is where the accessible parking must be located to comply with 208.3.1, in the opinion of ACCESS.  The logic behind that opinion by ACCESS is that the distance from the parking space to the entrance is the same for both the general public and one who is handicapped.  Therefore, there is no discrimination based upon the Americans with Disabilities Act Section 36.202(b).

Title III Nondiscrimination on the basis of Disability by Public Accommodations and in Commercial Facilities.

Subpart B General Requirements.

36.202 Activities.

36.202(b) Participation in unequal benefit. 

“A public accommodation shall not afford an individual or class of individuals, on the basis of a disability or disabilities of such individual or class, directly, or through contractual, licensing, or other arrangements, with the opportunity to participate in or benefit from a good, service, facility, privilege, advantage, or accommodation of a place of public accommodation that is not equal to that afforded to other individuals.”

Any questions?  Post them here or on our FaceBook page at http://www.facebook.com/pages/Access-Technologies-Services-Inc/268659564730#!/.  You can also contact us at hfalstad@accessts.net or call us at (702) 649-7575.  We look forward to hearing from you.

Hank

The above are opinions of Hank Falstad, AIA, Managing Senior Associate of Access Technologies Services, Inc. (ACCESS).  See our web site for additional information:  www.accessts.net.

How Much Maneuvering Clearance is Require?

This past week we were finishing a 15-hour training program for three of our new ADA audit architects.  They each have over 20years of architectural experience. 

We were on-site looking at entry doors into the transient lodging mobility rooms.  The push and pull maneuvering clearance came into question because that maneuvering clearance was not parallel with the door.  Let's answer that first question of why do we need maneuvering clearance.  The answer is we need to get the wheelchair up to the door hardware to open that door.  The opening of the door will be either a push or a pull.  When the wall adjacent to the latch side of the door is not parallel, we have  a recessed wall condition.  When the recess is less than 8 inches deep in either the push or pull, then one has a compliance.  The maneuvering clearance table (404.2.4.1) will give one the minimum maneuvering clearance parallel to the doorway beyond the latch side.

In this situation, there was compliance on the 12 inch push side but not on the 18 inch pull side.

Any questions?  You can leave your comment here or post them on our FB page at http://www.facebook.com/pages/Access-Technologies-Services-Inc/268659564730.  You can also contact us at hfalstad@accessts.net or call us at (702) 649-7575.  We look forward to hearing from you.

Hank

The above are opinions of Hank Falstad, AIA, Managing Senior Associate of Access Technologies Services, Inc. (ACCESS).  See our web site for additional information:  www.accessts.net.

Is a Shower Seat Required for All Roll-in Showers?

This past week we were finishing a 15 hour training program for three of our new ADA audit architect.  They each have over 20 years of architectural experience.  We were on-site looking at a roll-in shower and the question was asked is a shower seat required? 

A shower seat is a requirement of the 2009 International Building Code (IBC) in section 11076.1.1 and says, "shall include a permanently mounted folding shower seat."

The Access Board final rule in section 608.4 says, "A folding seat shall be provided in roll-in type showers." 

Here we have IBC and ADAAG in agreement on the requirement for a folding seat.  IBC has greater clarity in that it must be a permanently mounted folding set.  All the templates used by ACCESS in our detail ADA building audits and detail ADA building plan checks include the accessibility requirements of the ADA, IBC and ICC/ANSI A117.1.

So the answer is the shower seat is a requirement of the ADA, IBC and ICC/ANSI A117.1 and all have to be reviewed to obtain total accessibility compliance.

Give us your comments here or on our FaceBook at http://www.facebook.com/pages/Access-Technologies-Services-Inc/268659564730#!/.  You can also contact us at hfalstad@accessts.net or call us at (702) 649-7575.  We look forward to hearing from you.

Hank

ACCESS ADA Audit Training

This past week we were finishing a 15 hour training program for there of our new ADA audit architects.  They each have over 20 years of architectural experience.  It was a 5 story, 300 room transient lodging facility.  I know you want to know how they didn't.  I would say very well, actually.

The trainees found over 175 items that were not in ADA compliance and the building is maybe 15 years old.  So, the question is how could this happen?  Very easily, we see it all the time, but if you are pointing that finger looking for answers, here is where you want to start:

1. The architects understanding of the ADA law.
2. Building officials do not inspect for ADA items, only code.
3. Owner does not want to spend the money for ADA compliance.
4. The contractor understanding of the ADA law.

In the real world, it's usually a combination of all of the above.  The architect is going to design it like he did his last job; the building official will be saying I do not do ADA; to the it's always a money issue and a reliance on his architect and contractor; and to the contractor his sub-contractors are gong to build it like they built their last job.  That is why 90% of our buildings are not ADA compliant and the ACCESS "Watchdogs in Wheelchairs" are on a mission to change that 90% to 50% in the next 10 years.

Leave us your comments here or on our FaceBook page at http://www.facebook.com/pages/Access-Technologies-Services-Inc/268659564730.  You can also contact us at hfalstad@accessts.net or call us at (702) 649-7575.

Hank