Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards This commenter’s interpretation and “comparable” vague and expressed concern understanding are consistent with the about confusion the new requirement would Department’s position in this matter. Section cause. This commenter suggested that the 215.4 of the 2010 Standards requires that phrase “equal area in square inches” be used guest rooms required to have communication instead of comparable vanity space. features be equipped with a fire alarm system complying with section 702. Communication In some circumstances, the addition of accessible guest rooms are required to a shelf in an existing facility may be a have all of the communication features reasonable way to provide a space for described in section 806.3 of the 2010 travelers with disabilities to use their toiletries Standards including a fire alarm system and other personal items. However, this is a which provides both audible and visible determination that must be made on a case- alarms. The exception to section 215.1 of by-case basis. Comparable vanity countertop the 2010 Standards, which applies only to space need not be one continuous surface fire alarm requirements for guest rooms with and need not be exactly the same size as the communication features in existing facilities, countertops in comparable guest bathrooms. exempts the visible alarm requirement until For example, accessible shelving within such time as the existing fire alarm system reach of the lavatory could be stacked to is upgraded or replaced, or a new fire alarm provide usable surfaces for toiletries and system is installed. If guest rooms in existing other personal items. facilities are altered and they are required by section 224 of the 2010 Standards to Shower and Sauna Doors in Transient have communication features, such guest Lodging Facilities. Section 9.4 of the 1991 rooms are required by section 806.3 to have Standards and section 206.5.3 of the 2010 all other communication features including Standards both require passage doors in notification devices. transient lodging guest rooms that do not provide mobility features to provide at least Vanity Counter Space. Section 806.2.4.1 32 inches of clear width. Congress directed of the 2010 Standards requires that if vanity this requirement to be included so that countertop space is provided in inaccessible individuals with disabilities could visit guests transient lodging guest bathrooms, in other rooms. See H. Rept. 101-485, pt. 2, comparable vanity space must be provided in at 118 (1990); S. Rept. 101-116, at 70 (1989). accessible transient lodging guest bathrooms. Section 224.1.2 of the 2010 Standards adds a new exception to clarify that shower and A commenter questioned whether in sauna doors in such inaccessible guest existing facilities vanity countertop space rooms are exempt from the requirement for may be provided through the addition of a passage doors to provide at least 32 inches shelf. Another commenter found the term of clear width. Two commenters requested 124 - Guidance on the 2010 Standards: Titles II and III Department of Justice