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Guidance on the 2010 ADA Standards for Accessible Design

The Department of Justice’s explanation of changes to the ADA design standards, with section-by-section analysis and responses to public comments.

AccessibilityAnthropometry & ergonomics
Open original PDF at page 122

Source wording and page order preserved. Drawings and table layouts remain available in the original PDF.

Analysis and Commenta ry o n the 2010 ADAStandards single elements, when considered together, Some commenters opposed requirements amount to an alteration of a room or space for guest rooms accessible to individuals in a building or facility, the entire space shall with mobility disabilities stating that statistics be made accessible. Therefore, under the provided by the industry demonstrate that all 2010 Standards, the alteration requirements types of accessible guest rooms are unused. only apply to specific elements or spaces that They further claimed that the requirements are being altered. So providing the clear floor of the 2010 Standards are too burdensome space at the end of the bench as required by to meet in new construction, and that the the 2010 Standards instead of in front of the requirements will result in a loss of living bench as is allowed by the 1991 Standards space in places of transient lodging. Other would only be required when the bench in the commenters urged the Department to accessible dressing room is altered or when increase the number of guest rooms required the entire dressing room area is altered. to be accessible. The number of guest rooms accessible to individuals with mobility 224 and 806 Transient Lodging Guest disabilities and the number accessible to Rooms persons who are deaf or who are hard of hearing in the 2010 Standards are consistent Scoping. The minimum number of guest with the 1991 Standards and with the rooms required to be accessible in transient IBC. The Department continues to receive lodging facilities is covered by section 224 of complaints about the lack of accessible guest the 2010 Standards. Scoping requirements rooms throughout the country. Accessible for guest rooms with mobility features guest rooms are used not only by individuals and guest rooms with communication using mobility devices such as wheelchairs features are addressed at section 224.2 and scooters, but also by individuals with and section 224.4, respectively. Under the other mobility disabilities including persons 1991 Standards all newly constructed guest who use walkers, crutches, or canes. rooms with mobility features must provide communication features. Under the 2010 Data provided by the Disability Statistics Standards, in section 224.5, at least one Center at the University of California, San guest room with mobility features must also Francisco demonstrated that the number provide communication features. Additionally, of adults who use wheelchairs has been not more than ten percent (10%) of the guest increasing at the rate of six percent (6%) per rooms required to provide mobility features year from 1969 to 1999; and by 2010, it was and also equipped with communication projected that two percent (2%) of the adult features can be used to satisfy the minimum population would use wheelchairs. In addition number of guest rooms required to provide to persons who use wheelchairs, three communication features. percent (3%) of adults used crutches, canes, walkers, and other mobility devices in 1999; 118 - Guidance on the 2010 Standards: Titles II and III Department of Justice

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