Accessibility News & Review

This post is part of a series of articles on the new ADAAG-R guidelines.  I will be exploring some of the more notable changes from the current version of the ADA Accessibility Guidelines for Buildings & Facilities (ADAAG).  You can find a complete copy of the new ADA/ABA Accessibility Guidelines (ADAAG-R) on the Access Board’s website.

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Reach Range

Historically, dimensions for reach range have been different depending upon the approach.  Because someone in a wheelchair can reach higher when approaching an object from the side as opposed to directly in front of them, side reach range is currently allowed to be up to 54 inches Above the Finished Floor (AFF) or ground.  Forward reach range is a maximum of 48 inches AFF or ground.  The ADAAG-R limits side reach to 48 inches, the same as the limitation on front reach.

308.3 Side Reach.

308.3.1 Unobstructed.  Where a clear floor or ground space allows a parallel approach to an element and the side reach is unobstructed, the high side reach shall be 48 inches (1220 mm) maximum and the low side reach shall be 15 inches (380 mm) minimum above the finish floor or ground.

In its review of the new ADAAG-R, the Department of Justice (DOJ) observed that, from a cost perspective, it is no more expensive to place controls and operating mechanisms at 48 inches than at 54 inches. More importantly, harmonizing side and front reach ranges eliminates a good deal of confusion over what constitutes a permissible side approach. This is a crucial point. In terms of enforcement of the ADAAG in public accommodations, it is very common for the owner/operator of a restaurant or store to assert that a side approach is possible — and thus place an item or control at 54 inches — when in fact only a front approach is possible.

In addition, the fixed and moveable elements that govern whether a side or front approach is possible are often added to the design or even to the building itself, long after the height of the item in question is determined or the item is installed. With a uniform height for both side and front approach, both design and compliance will be simpler.

Furthermore, the Access Board (the agency that promulgates these guidelines) decided to require 48-inch reach ranges for both side and front approaches after extensive testimony supported the idea that this height limitation was necessary to permit use by people of short stature and many wheelchair-users with limited upper arm strength, as well as people with other types of disabilities and chronic illnesses.

Finally, the 48-inch limitation has been included in the ANSI standard for the past ten years, and harmonizing the requirements for reach ranges is consistent with the the goals of the new ADAAG-R.

The minimum Reach Range for side approach has also been changed to 15 inches AFF or ground, which is also consistent with the minimum Reach Range for forward approach.  The requirements for Reach Range over an obstruction for both approaches have remained essentially unchanged from the current ADAAG, and a discussion about those requirements will be addressed in a future post.  Again, you can view all the new requirements for Reach Range at the Access Board’s website for the new ADAAG-R.

Filed under: Accessibility, Reach Range