Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards 225 and 811 Storage this requirement as too burdensome to retail and other entities and claimed that significant Section 225 of the 2010 Standards provides revenue would be lost if this requirement that where storage is provided in accessible were to be implemented. spaces, at least one of each type shall comply with the 2010 Standards. Self- Other commenters raised concerns that service shelving is required to be on an section 225.2.2 of the 2010 Standards accessible route, but is not required to scopes only self-service shelving whereas comply with the reach range requirements. section 4.1.3(12)(b) of the 1991 Standards These requirements are consistent with the applies to both “shelves or display units.” 1991 Standards. Although “display units” were not included Section 225.3 adds a new scoping in the 2010 Standards under the belief that requirement for self-storage facilities. displays are not to be touched and therefore Facilities with 200 or fewer storage spaces by definition cannot be “self-service,” both will be required to make at least five percent the 2010 Standards and the 1991 Standards (5%) of the storage spaces accessible. should be read broadly to apply to all types of Facilities with more than 200 storage spaces shelves, racks, hooks, and similar self-service will be required to provide ten accessible merchandising fittings, including self-service storage spaces, plus two percent (2%) of the display units. Such fixtures are permitted to total storage spaces over 200. be installed above or below the reach ranges possible for many persons with disabilities Sections 225.2.1 and 811 of the 2010 so that space available for merchandising is Standards require lockers to meet used as efficiently as possible. accessibility requirements. Where lockers are provided in clusters, five percent (5%) but 226 and 902 Dining Surfaces and Work at least one locker in each cluster will have Surfaces to comply. Under the 1991 Standards, only one locker of each type provided must be Section 226.1 of the 2010 Standards require accessible. that where dining surfaces are provided for the consumption of food or drink, at least Commenters recommended that the five percent (5%) of the seating spaces Department adopt language requiring public and standing spaces at the dining surfaces accommodations to provide access to all self- comply with section 902. Section 902.2 service shelves and display areas available requires the provision of accessible knee and to customers. Other commenters opposed toe clearance. 140 - Guidance on the 2010 Standards: Titles II and III Department of Justice