Accessibility News & Review

This post is part of a series of articles on notable changes in the new 2010 ADA Standards for Accessible Design (ADAAG) and the impending 2012 Texas Accessibility Standards (TAS). You can find a complete copy of the new Standards on the Access Board’s website. You can download a copy of the draft 2012 TAS on the TDLR website.

=====================================

In the first segment of this series, I dealt with the scoping requirements for toilet rooms. In the following segments, I will discuss the technical specifications for specific elements in toilet rooms insofar as they differ from the current ADAAG and TAS standards. These segments will each discuss one major element.

Finally, because some jurisdictions adopt IBC along with Chapter 11 (and by reference ANSI A117.1), I will also note where there may be differences between these codes and standards.
=======================================
Mirrors: Scoping

Almost all accessibility standards, codes and guidelines scope mirrors in the same manner. The 2010 ADA Standards and the 2012 TAS state:

213.3.5 Mirrors. Where mirrors are provided, at least one shall comply with 603.3.

IBC 2003, 2006 and 2009 echoe this requirement:

1109.2. At least one of each type of fixture, element, control or dispenser in each accessible toilet room and bathing facility shall be accessible.

Note that in each of the standards above, mirrors, per se, are not required in toilet rooms; however, if they are provided at least one must be accessible.

As in the 1994 TAS, the 2012 Texas Accessibility Standards further stipulate:

213.3.5. Accessible mirrors shall be provided at locations that are consistent with the location of other mirrors in the same room.

In other words, if you provide nonaccessible mirrors above lavatories, you can’t simply install an accessible full-length mirror on the wall in lieu of providing an accessible mirror above lavatories.

As a side note, instead of leaving well enough alone ANSI A117.1 (2009) oversteps its boundaries by sneaking in some new scoping of its own in 603.3:

Mirrors are not required over lavatories or counters if a mirror is located within the same toilet or bathing room and mounted with the bottom edge of the reflecting surface 35 inches maximum above the floor.

As you can see, this contradicts the 2012 TAS, making it pretty much irrelevant in Texas.

Unfortunately, I’ve discovered that the scoping and technical requirements for mirrors in each of these guidelines are limited to sections regarding toilet rooms. There is no scoping for mirrors outside of toilet rooms in the 2010 ADA Standards nor the 2012 TAS; neither are there scoping requirements in IBC 2003, 2006 or 2009 for mirrors above sinks, lavatories or counters in other types of rooms (like kitchens, classrooms and breakrooms, for example). While ANSI A117.1 (2003) includes the word “sinks” in Section 603.3, it is not a scoping document and nowhere actually specifies when and where mirrors above sinks are actually required. In practice, however, you should mount mirrors above sinks required to be accessible in compliance with the standards.
=======================================

Mirrors: Technical Requirements

In all of the standards, codes and guidelines noted above, accessible mirrors located above lavatories or countertops (and sinks) are required to be installed with the bottom edge of the reflecting surface 40 inches maximum above the finish floor or ground. Accessible mirrors not located above lavatories or countertops are generally required to be installed with the bottom edge of the reflecting surface 35 inches maximum above the finish floor or ground. An advisory in the 2010 ADA Standards and echoed in the 2012 TAS note when a single accessible full-length mirror is provided, the top edge of mirrors should be 74 inches minimum from the floor or ground to accommodate both people who are ambulatory and people who use wheelchairs. [See Section 603.3 in the 2010 ADA Standards, 2012 TAS, and all ANSI A117.1]
=======================================

Conclusion

Here is my personal “compliance plus” commentary on the subject. Mirrors are a relatively inexpensive fixture, but if you want to accommodate the most people for the money, install just one full-length mirror complying with these standards in the toilet room. If you want to place mirrors above lavatories, then you must provide an accessible mirror above the accessible lavatory. If that is the only mirror in the room, make sure the top of the reflective surface is at least 74 inches AFF. You can always install an accessible mirror above the accessible lavatory and another accessible full-length mirror on a wall.

Please post any comments you have on my blog at www.Kenotten.com in the “Leave A Reply” section at the end of the post.

In the next segment we’ll discuss lavatories!

========================================
You can also follow me @kenotten on Twitter.

Filed under: Mirrors, New ADA Guidelines | No Comments »

Friends,

Okay, my foray into the world of blogging got off to a splash last year, then hit a “diversion”, lets say. After developing facility assessment software for conducting ADA inspections through Otten Consulting Group, we spun our technology into a separate company called FREDAsoft, LLC. FREDA is an acronym for Facility REporting and Data Analytics, and utilizes tablet PC’s to collect facility condition data (Roofs, Structural, MEP, Life Safety, ADA, Energy etc.) and Captial Asset/Inventory data in the field, then synchronizes the information to the “cloud” where the data is processed, checked (QA/QC), and re-presented in the form of online and printable reports. Clients are then able to use the technology under a “Software As A Service” (SaaS) offering to continually analyze and manage the data. Pretty exciting stuff!

OCG used the software to successfully assess more than 700 locations across the country for a Fortune 500 big box retailer, and after spinning off FREDA we were honored this year to have our technology selected by another Fortune 500 company to assess nearly 3,000 of its quick service restaurants across the US and Canada.

This week we were awarded a contract with another Fortune 500 chain of retail stores! Suffice it to say that I’ve been busy working with our fine staff at FREDAsoft, and spending a bunch of time with the software developers at our development offices in Portland, Oregon.

We also recently contracted with a major US oil and gas company for ADA consultation, and are filling the hoppers with work for 2012. Nevertheless, it is time for me to focus again on some core business issues, and starting next week I plan to commence blogging again on topics regarding the ADA, Texas Accessibility Standards, IBC/ANSI A117.1 and state & local accessibility codes across the country.

The impending 2010 ADA Standards for Accessible Design and subsequent adoption of new 2012 Texas Accessibility Standards will provide more meat that I can barbeque, so hang on tight! For those of you who twitter, you can also follow me at @kenotten.

See you next week!

Filed under: Uncategorized | No Comments »

I received this little notice in my inbox this afternoon:

The Federal Register has advised that the US Department of Justice Final Regulations for Titles II and III of the ADA will be published on September 15, 2010. They will be published together in a Separate Part of the Federal Register (Part #2). The specific effective date for each title will be contained in the published rule.

Try as I may, I could find no additional (or even corroborating) information on either the Federal Register nor the Justice Department’s websites. If true, more announcements will dribble out next week from many quarters.

According to statements released by the Justice Department in July, this “final rule” will be effective six months from the date of publication in the federal register. Later reports however clarified this to mean the new regulations would become a legal option after six months, but not a mandate until 18 months after the effective date. Quick calculation: buildings and facilities can be legally designed and constructed using the new ADA/ABA guidelines after March 15, 2011, but won’t be required to use these new guidelines until March 15, 2012.

More to come.

Filed under: New ADA Guidelines | No Comments »

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.
=====================================

In the first segment of this series, I dealt with the scoping requirements of toilet rooms. In the following segments, I will discuss the technical specifications for specific elements in toilet rooms insofar as they differ from the current ADAAG and TAS standards. These segments will each discuss one major element.
=======================================

Doors to Toilet Rooms

Let me begin by noting that doors to toilet rooms must comply with all of the requirements for doors in general, including having level landings on both sides of the door; compliant maneuvering clearance on both sides of the door (specific to the direction of travel to the door and, in some cases, whether the door has a latch, closer or both); compliant clear opening width; compliant opening force and sweep periods if there is a closer; compliant hardware (including deadbolts and other locks); compliant thresholds; and compliant room designation signage.

Door Swings. In the current version of the ADAAG (and TAS), doors (entry doors, toilet compartment doors etc.) are not permitted to swing into the clear floor spaces for any fixture required to be accessible. In June of 2003, the Texas Department of Licensing and Regulation issued Technical Memo 03-02 allowing doors in single-user toilet rooms (and bathing rooms) to swing into required fixtures so long as there is a 30×48 clear floor space beyond the arc of the door swing.

This exception is derived from language in the new ADA/ABA Guidelines which still prohibit doors to swing into the clear floor space of a required fixture, but by exception what I have described above and another similar exception for private toilet rooms. Private toilet rooms (single occupant toilet rooms accessed only through a private office and not for common or public use) qualify for the exception noted above, and also for the following exception: a door can swing into the clear floor space of a required fixture if the door swing can be reversed in the future (consistent with the concept of “adaptability”). Once the door is reversed, it must meet all the requirements for accessible doors, cannot reduce the required width of an accessible route, and must not violate other building or life safety codes.

603.2.3 Door Swing. Doors shall not swing into the clear floor space or clearance required for any fixture. Doors shall be permitted to swing into the required turning space.

EXCEPTIONS: 1. Doors to a toilet room or bathing room for a single occupant accessed only through a private office and not for common use or public use shall be permitted to swing into the clear floor space or clearance provided the swing of the door can be reversed to comply with 603.2.3.

2. Where the toilet room or bathing room is for individual use and a clear floor space complying with 305.3 is provided within the room beyond the arc of the door swing, doors shall be permitted to swing into the clear floor space or clearance required for any fixture.

Advisory 603.2.3 Door Swing Exception 1. At the time the door is installed, and if the door swing is reversed in the future, the door must meet all the requirements specified in 404. Additionally, the door swing cannot reduce the required width of an accessible route. Also, avoid violating other building or life safety codes when the door swing is reversed.

Filed under: Accessibility, Doors, New ADA Guidelines | No Comments »

As part of the administration’s commemoration of the 20th anniversary of the Americans with Disabilities Act (ADA), President Obama announced yesterday (July 26, 2010) the publication of two final rules that will amend the Department of Justice’s regulations implementing Title II and Title III of the ADA. These two rules will be published concurrently in the Federal Register.

The Department of Justice also issued the same notice to the public. While I have not seen it published in the fedral register yet, it appears that the publishing of such is imminent. This “final rule” will be effective six months from the date of publication in the federal register.

Here is a portion of the notice from DOJ:
===============================
The Department of Justice (Department) is issuing this final rule in order to adopt enforceable accessibility standards under the Americans with Disabilities Act of 1990 (ADA) that are “consistent with the minimum guidelines and requirements issued by the Architectural and Transportation Barriers Compliance Board” (Access Board), 42 U.S.C. 12186(c), and to update or amend certain provisions of the title III regulation so that they comport with the Department´s legal and practical experiences in enforcing the ADA since 1991.

The Department has conducted the periodic review that is required by the Regulatory Flexibility Act and has made a regulatory assessment of the costs and benefits of any significant regulatory action as required by the Regulatory Flexibility Act, as amended by the Small Business Regulatory Enforcement Fairness Act of 1996.

This rule adopts ADA Chapter 1, ADA Chapter 2, and Chapters 3 through 10 of the Americans with Disabilities Act and Architectural Barriers Act Accessibility Guidelines (2004 ADA/ABA Guidelines), which were published by the Access Board on July 23, 2004, and are codified at 36 CFR part 1191, app. B and D (2009). Because the Department is adopting ADA Chapter 1, ADA Chapter 2, and Chapters 3 through 10 of the 2004 ADA/ABA Guidelines as part of the 2010 ADA Standards for Accessible Design (2010 Standards), on the effective date of the final rule, these guidelines will cease to be mere guidance and instead will have legal effect.

Concurrently with the publication of the final rule for title III, the Department is publishing a final rule amending its ADA title II regulation. The title II regulation covers State and local government entities, adopts ADA Chapter 1, ADA Chapter 2, and Chapters 3 through 10 of the 2004 ADA/ABA Guidelines as its standards for title II entities, makes amendments to the title II regulation for consistency with the title III regulation, and makes amendments that reflect the Department´s experience of years of enforcement of the ADA.

The Justice Department also announced that it will publish four new ADA proposals addressing the accessibility of websites, the provision of captioning and video description in movies shown in theaters, accessible equipment and furniture, and the ability of 9-1-1 centers to take text and video calls from individuals with disabilities. The proposals were in the form of advance notices of proposed rulemaking published on July 26, 2010 (the anniversary of the signing of the ADA) which provide information on these ADA issues and ask questions seeking comments and information from the public.

Subscribe to Accessibility News & Review by Email

Subscribe in a reader

Filed under: Accessibility, New ADA Guidelines | No Comments »

The Department of Justice (DOJ) is moving to issue final rules that would update its ADA regulations, including standards governing the construction and alteration of facilities covered by the law. On April 26, DOJ submitted final rules to the Office of Management and Budget (OMB) for approval. If cleared within OMB’s standard 90-day review period, DOJ may publish the updated regulations in late July or early August. In my previous post regarding these new guidelines, I suggested that DOJ was shooting for the July 26th anniversary date of the ADA.

DOJ’s new rules will update its ADA regulations for state and local governments under title II and those for public accommodations and commercial entities covered by title III. The pending regulations will implement new ADA standards for title II and title III facilities that are closely based on updated guidelines previously issued by the Board. This final rule will also establish an effective date for compliance with the new guidelines. [When the original ADAAG was published on July 26, 1991 (a year after the ADA became law), it established an effective date for public entities of January 26, 2002, a six-month window.]

The final rules will also revise or supplement other sections of DOJ’s regulations, including those covering existing facilities, service animals, policies and programs, maintenance of accessible features, auxiliary aids and services, and effective communication. DOJ had planned to issue the regulations in early 2009 but delayed publication in order to give officials of the incoming Obama Administration an opportunity to review them.

For more information, visit DOJ’s website. Visitors to the site can subscribe to email updates from DOJ on this and other Department activities.

DOJ’s standards apply to all facilities covered by the ADA except transportation facilities, which are subject to standards issued by the Department of Transportation (DOT). DOT has already implemented updated ADA standards for transportation facilities. Similar standards are also in place under the Architectural Barriers Act (ABA) for most federally funded facilities. Housing facilities covered by the ABA currently remain subject to earlier standards pending the adoption of new standards by the Department of Housing and Urban Development. Further information on the status of ADA and ABA standards is available on the Board’s website .

Subscribe to Accessibility News & Review by Email

Subscribe in a reader

Filed under: Uncategorized | No Comments »

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.
=====================================

Let me begin by saying that, even before the ADA/ABA standards become enforceable, incorporating some of the new requirements into design standards now (or at least having them at the ready) may be prudent.  In Texas, some of these differences may be reasonable bases for requesting variances.

This first segment will deal with scoping requirements, since these are generally what drive compliance.

=======================================

213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603. Where bathing rooms are provided, each bathing room shall comply with 603.

EXCEPTIONS: 1. In alterations where it is technically infeasible to comply with 603, altering existing toilet or bathing rooms shall not be required where a single unisex toilet room or bathing room complying with 213.2.1 is provided and located in the same area and on the same floor as existing inaccessible toilet or bathing rooms.

The notable change here is that a single-user toilet room is now explicitly allowed during alterations in lieu of altering existing toilet rooms where doing so would be technically infeasible. The option is available so long as the single-user toilet room is on the same floor and in the same area as the existing nonaccessible toilet rooms. Of course, in Texas one will still need to secure a variance to do this, so we won’t see anything effectively changing at TDLR because of this exception. Please note though that this option is NOT available in new construction.

=======================================

213.2.1 Unisex (Single-Use or Family) Toilet and Unisex Bathing Rooms. Unisex toilet rooms shall contain not more than one lavatory, and two water closets without urinals or one water closet and one urinal. Unisex bathing rooms shall contain one shower or one shower and one bathtub, one lavatory, and one water closet. Doors to unisex toilet rooms and unisex bathing rooms shall have privacy latches.

We presume the logic behind defining Unisex toilet and bathing rooms by fixture count is to prevent owners from simply re-labeling existing multi-user toilet rooms as “Unisex” to avoid altering both toilet rooms in a pair, especially in light of the exception just noted in 213.2 above.  Plumbing code disallows a reduction in fixture count below current code requirements during alterations, so the tendency might be for some owners to leave all existing fixtures in place, claim technical infeasibility and alter only one of the toilet rooms, re-label it “Unisex” and thereby avoid the expense of making the second toilet room accessible.

Remember, Texas accessibility laws are far more proactive than those in most other states. The variance process in Texas makes it difficult for an owner to simply claim technical infeasibility, making this definition for us more academic than effectual.

This definition is also consequential in occupancies where plumbing code may only require one toilet room (for example, where the occupancy is under 15), or where plumbing code explicitly allows single-user toilet rooms (assembly and mercantile occupancies, for example).

=======================================

213.3.1 Toilet Compartments. Where toilet compartments are provided, at least one toilet compartment shall comply with 604.8.1. In addition to the compartment required to comply with 604.8.1, at least one compartment shall comply with 604.8.2 where six or more toilet compartments are provided, or where the combination of urinals and water closets totals six or more fixtures.

This change is huge. We are all familiar with the requirement to provide an ambulatory toilet compartment (by the way, stalls are now referred to as “compartments”) when the number of toilet compartments in a toilet room exceeds five, but now the basis for requiring an ambulatory compartment is when the combination of urinals and water closets exceeds five.

Consider the men’s toilet room with four urinals and two toilet compartments: in the new ADA/ABA, each of the toilet compartments would have to be accessible, one as a standard accessible compartment, and one as an ambulatory compartment. This is a change worth knowing if you are planning a large renovation and your building have multiple toilet rooms on each floor.

So, what exactly is a toilet compartment? The following Advisory clarifies this issue and offers some other helpful definitions.

=======================================

Advisory 213.3.1 Toilet Compartments. A toilet compartment is a partitioned space that is located within a toilet room, and that normally contains no more than one water closet. A toilet compartment may also contain a lavatory. A lavatory is a sink provided for hand washing. Full-height partitions and door assemblies can comprise toilet compartments where the minimum required spaces are provided within the compartment.

Note first that a toilet compartment is something that is “…located within a toilet room”. Next, note that a toilet compartment can be comprised of full-height walls and a standard 3’-0” door. This might seem to some like a toilet room within a toilet room, but according to this advisory, it is not because it is “located within a toilet room”. Notice also that this toilet compartment “…may contain a lavatory” and “…normally contains no more than one water closet.”

I’m not sure of too many scenarios where a toilet compartment would need more than one water closet, but I’m going to venture a guess here.  I have seen scenarios where a special toilet compartment designed for special needs students was placed within a toilet room. The compartment included two water closets, one with grab bars and one without, and could have easily included a lavatory had they chosen to install one. I evaluated it according to the standards for toilet rooms, since it looked and qualified as a room in its own right. But now, with this advisory, I know that this space only needs to comply with the requirements for toilet compartments.

A notable difference is that in toilet rooms, a turning space is required; in stalls or compartments, one is not. [Visual Alarms are required in all common-use rooms and spaces, so a separate visual alarm would be required in a toilet “compartment” with full-height walls if audible alarms are present.]

More importantly, this definition clarifies the misunderstanding that a toilet compartment becomes a toilet room just because it has full-height walls. If it is in a toilet room, it is a compartment.

Before I move on, let me also point out that lavatories are clearly defined as those fixtures used for hand-washing, and this differentiates them from sinks (which are designed or intended to be used for other uses in addition to washing hands.)

=======================================

213.3.3 Urinals. Where more than one urinal is provided, at least one shall comply with 605.

Basically, if there is only one urinal, it no longer must be a compliant urinal.

=======================================

213.3.4 Lavatories. Where lavatories are provided, at least one shall comply with 606 and shall not be located in a toilet compartment.

In the Texas Accessibility Standards (TAS 4.22.6), this restriction has always been present, so for us in Texas the change is of little consequence.

=======================================

213.3.7 Coat Hooks and Shelves. Where coat hooks or shelves are provided in toilet rooms without toilet compartments, at least one of each type shall comply with 603.4. Where coat hooks or shelves are provided in toilet compartments, at least one of each type complying with 604.8.3 shall be provided in toilet compartments required to comply with 213.3.1. Where coat hooks or shelves are provided in bathing facilities, at least one of each type complying with 603.4 shall serve fixtures required to comply with 213.3.6.

Accessible shelves are newly specified, as heretofore they generally fell into the storage category and were simply required to be located on an accessible route within accessible reach ranges. The new requirement specifies a minimum location above the finish floor of 40 inches.

Well, that is all for this segment. Next time we will look at some of the specific dimensional requirements for the elements within toilet and bathing rooms. Let me know if you have any insights into today’s article. If I’ve missed or misinterpreted something, I would like to clean it up right away.

Subscribe to Accessibility News & Review by Email

Subscribe in a reader

Filed under: Accessibility, New ADA Guidelines | No Comments »

The Access Board held an audio presentation today regarding sidewalks and intersections, and during the call someone asked if there was any word on a date for adoption of the new ADA-ABA guidelines (ADAAG-R).

One of the presenters commented that talk around the water cooler in DC has the Department of Justice targeting July 26th (the anniversary of the ADA) to issue a notice adopting the new guidelines.  Of course, this is unofficial and pure speculation, but its speculation from individuals fairly close to the situation.

If this indeed happens, these new standards may become enforceable before the end of the year.

I will let you know as more information is released.

Ken

Subscribe to Accessibility News & Review by Email

Subscribe in a reader

Filed under: Accessibility, New ADA Guidelines | No Comments »

On Monday, December 7, 2009 the US Department of Justice (DOJ) issued its Statement of Regulatory Priorities for 2010.  In that Regulatory Plan, DOJ stated that it “is planning to revise its regulations implementing titles II and III of the Americans With Disabilities Act (ADA). ”

The Plan went on to state:

In June 2008, the Department has published proposed rules to revise its regulations implementing titles II and III of the ADA to amend the ADA Standards for Accessible Design (28 CFR part 36, appendix A) to be consistent with the revised ADA accessibility guidelines published by the U.S. Architectural and Transportation Barriers Compliance Board (Access Board) on July 23, 2004.  During FY 2010, the Department expects to complete its work on these regulations and to further amend the Department’s regulations to implement the ADA Amendments Act of 2008, which took effect on January 1, 2009.

The timetable associated with this action indicates “Final Action” in March of 2010.  While this is not a mandatory deadline and should be seen as a projection only, it offers some degree of hope to all who have been awaiting something more definitive in regards to adoption of the new ADA/ABA Guidelines.

I guess one can officially hold their breath and cross their fingers now!  And while you are at it, you may want to call Otten Consulting Group and schedule yourself for one of our AIA approved CE seminars on Accessibility (I would recommend the seminar covering The New ADAAG-R Guidelines).

(800) 776-4ADA
(713) 975-1029

Filed under: Accessibility, New ADA Guidelines | No Comments »

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.

=====================================

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 | No Comments »