Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards Aisle Stairs and Ramps in Assembly a handrail may be provided at either side Areas. Sections 4.1.3 and 4.1.3(4) of the or within the aisle width when handrails are 1991 Standards require that interior and not provided on both sides of aisle ramps. exterior stairs connecting levels that are not Section 505.3 states that, in assembly areas, connected by an elevator, ramp, or other handrails need not be continuous in aisles accessible means of vertical access must serving seating. comply with the technical requirements for stairs set out in section 4.9 of the 1991 222 and 803 Dressing, Fitting, and Locker Standards. Section 210.1 of the 2010 Rooms Standards requires that stairs that are part of a means of egress shall comply with Dressing rooms, fitting rooms, and locker section 504’s technical requirements for rooms are required to comply with the stairs. The 1991 Standards do not contain accessibility requirements of sections 222 any exceptions for aisle stairs in assembly and 803 of the 2010 Standards. Where these areas. Section 210.1, Exception 3 of the types of rooms are provided in clusters, five 2010 Standards adds a new exception that percent (5%) but at least one room in each exempts aisle stairs in assembly areas cluster must comply. Some commenters from section 504’s technical requirements stated that clothing and retail stores would for stairs, including section 505’s technical have to expand and reconfigure accessible requirements for handrails. dressing, fitting and locker rooms to meet the changed provision for clear floor space Section 4.8.5 of the 1991 Standards exempts alongside the end of the bench. Commenters aisle ramps that are part of an accessible explained that meeting the new requirement route from providing handrails on the side would result in a loss of sales and inventory adjacent to seating. The 2010 Standards, at space. Other commenters also expressed section 405.1, exempt aisle ramps adjacent opposition to the changed requirement in to seating in assembly areas and not serving locker rooms for similar reasons. elements required to be on an accessible route, from complying with all of section The Department reminds the commenters 405’s technical requirements for ramps. that the requirements in the 2010 Standards Where aisle ramps in assembly areas serve for the clear floor space to be beside the elements required to be on an accessible short axis of the bench in an accessible route, the 2010 Standards require that dressing, fitting, or locker room apply only the aisle ramps comply with section 405’s to new construction and alterations. The technical requirements for ramps. Sections requirements for alterations in the 2010 505.2 and 505.3 of the 2010 Standards Standards at section 202.3 do not include provide exceptions for aisle ramp handrails. the requirement from the 1991 Standards Section 505.2 states that in assembly areas, at section 4.1.6(1)(c) that if alterations to Department of Justice Guidance on the 2010 Standards: Titles II and III - 117