Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards A commenter stated that the Department’s options for providing access. The Department drawings suggest that the fan coil units for recognizes that relocating mechanical heat and air conditioning are overhead, chases in multi-story facilities may be difficult while the typical sleeping room usually or impossible to accomplish. While these has a vertical unit, or a packaged terminal issues do not exist in new facilities, altered air conditioning unit within the room. The existing facilities must comply with the 2010 Department’s drawings are sample plans, Standards to the extent that it is technically showing the layout of the space, relationship feasible to do so. When an alteration of elements to each other, and required cannot fully comply because it is technically clear floor and turning spaces. It was not the infeasible to do so, the alteration must still intent of the Department to provide precise be designed to comply to the greatest extent locations for all elements, including heating feasible. and air conditioning units. Commenters noted that on some of the Commenters noted that in guest rooms with Department’s plans where a vanity is located two beds, each bed was positioned close adjacent to a bathtub, the vanity may require to a wall, reducing access on one side. more maintenance due to exposure to water. Another commenter stated that additional The Department agrees that it would be housekeeping time is needed to clean the advisable that items placed next to a bathtub room when beds are placed closer to walls. or shower be made of materials that are not The 2010 Standards require that, when two susceptible to water damage. beds are provided, there must be at least 36 inches of clear space between the beds. The plans provided in the NPRM showed two bed arrangements with adequate clear width complying with the 1991 Standards and the 2010 Standards. Additional space can be provided on the other side of the beds to facilitate housekeeping as long as the clear floor space between beds is at least 36 inches wide. Commenters stated that chases in sleeping room bathrooms that route plumbing and other utilities can present challenges when modifying existing facilities. In multi-story facilities, relocating or re-routing these elements may not be possible, limiting 126 - Guidance on the 2010 Standards: Titles II and III DDeeppaarrttmmeenntt ooff JJuussttiiccee