Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards must be provided positioned for a parallel and toe clearance requirements will cause a approach adjacent to the 36-inch minimum reduction in the sales and inventory space at length of counter. check-out aisles and other sales and service counters. Section 904.4 of the 2010 Standards includes an exception for alterations to sales and Both the 1991 and the 2010 Standards service counters in existing facilities. It permit covered entities to determine whether permits the accessible portion of the counter they will provide a forward or a parallel to be at least 24 inches long, where providing approach to sales and service counters. So a longer accessible counter will result in a any facility that does not wish to provide the reduction in the number of existing counters knee or toe clearance required for a front at work stations or existing mailboxes, approach to such a counter may avoid that provided that the required clear floor or option. However, the Department believes ground space is centered on the accessible that permitting a forward approach without length of the counter. requiring knee and toe clearance is not adequate to provide accessibility because the Section 904.4 of the 2010 Standards also person using a wheelchair will be prevented clarifies that the accessible portion of the from coming close enough to the counter counter must extend the same depth as to see the merchandise or to transact the sales or service counter top. Where business with a degree of convenience the counter is a single-height counter, this that is comparable to that provided to other requirement applies across the entire depth customers. of the counter top. Where the counter is a split-height counter, this requirement applies A parallel approach to sales and service only to the customer side of the counter top. counters also can provide the accessibility The employee-side of the counter top may be required by the 2010 Standards. Individuals higher or lower than the customer-side of the using wheelchairs can approach sales counter top. and service counters from the side, and, assuming the necessary elements, features, Commenters recommended that the or merchandise necessary to complete a Department consider a regulatory alternative business transaction are within the reach exempting small retailers from the new range requirements for a side approach, the knee and toe clearance requirement and needs of individuals with disabilities can be retaining existing wheelchair accessibility met effectively. standards for sales and service counters. These commenters believed that the knee Section 227 of the 2010 Standards clarifies the requirements for food service lines. Queues and waiting lines serving counters 142 - Guidance on the 2010 Standards: Titles II and III Department of Justice