Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards residence halls and dormitories and other One commenter supported the provisions of types of student housing. Requirements for section 804 of the 2010 Standards but sought housing at a place of education covered by clarification whether this section applies the title II rule are included at § 35.151(f). to residential units only, or to lodging and office buildings as well. Section 212 makes Kitchens and Kitchenettes. Section section 804 applicable to all kitchens and 4.34.2 of the UFAS requires a clear turning kitchenettes in covered buildings. space at least 60 inches in diameter or an equivalent T-shaped turning space in Residential Facilities. Section 4.1.4(11) kitchens. Section 4.34.6 requires a clearance of the UFAS contains scoping requirements between opposing base cabinets, counters, for the new construction of housing. Under appliances, or walls of at least 40 inches the 1991 title II regulation, state and local except in a U-shaped kitchen where the governments had the option of complying minimum clearance is 60 inches. with the UFAS or the 1991 Standards. After the compliance date for the 2010 Standards, Section 804 of the 2010 Standards provides state and local governments will no longer technical requirements for kitchens and have the option of complying with the UFAS, kitchenettes. Section 804.2.1 requires that but will have to use the 2010 Standards for pass through kitchens, which have two new construction and alterations. entries and counters, appliances, or cabinets on two opposite sides or opposite a parallel Sections 233.1, 233.2, 233.3, 233.3.1, wall, provide at least 40 inches minimum and 233.3.2 of the 2010 Standards clearance. Section 804.2.2 requires that differentiate between entities subject U-shaped kitchens, which are enclosed to the United States Department of on three continuous sides, provide at least Housing and Urban Development (HUD) 60 inches minimum clearance between regulations implementing section 504 of the all opposing base cabinets, countertops, Rehabilitation Act of 1973 and entities not appliances, or walls within kitchen work subject to the HUD regulations. The HUD areas. Kitchens that do not have a cooktop regulations apply to recipients of federal or conventional range are exempt from the financial assistance through HUD, and clearance requirements but still must provide require at least five percent (5%) of dwelling an accessible route. units in multi-family projects of five or more dwelling units to provide mobility features If a kitchen does not have two entries, the and at least two percent (2%) of the dwelling 2010 Standards require the kitchen to have units to provide communication features. 60 inches minimum clearance between The HUD regulations define a project unique the opposing base cabinets, counters, to its programs as “one or more residential appliances, or walls. structures which are covered by a single 146 - Guidance on the 2010 Standards: Titles II and III Department of Justice