Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards requirements for the number and types of elevated play structures based on the number ground level play components required to be of elevated play activities, but asserted that on accessible routes. When elevated play transfer steps have not been documented as components are provided, an accessible an effective means of access. route must connect at least fifty percent (50%) of the elevated play components. The 2010 Standards recognize that play Section 240.2.1.2, provides an exception structures are designed to provide unique to the requirements for ground level play experiences and opportunities for children. components if at least fifty percent (50%) of The 2010 Standards provide for play the elevated play components are connected components that are accessible to children by a ramp and at least three of the elevated who cannot transfer from their wheelchair, play components connected by the ramp are but they also provide opportunities for different types of play components. children who are able to transfer. Children often interact with their environment in ways The technical requirements at section 1008 that would be considered inappropriate for include provisions where if three or fewer adults. Crawling and climbing, for example, entry points are provided to a soft contained are integral parts of the play experience for play structure, then at least one entry point young children. Permitting the use of transfer must be on an accessible route. In addition, platforms in play structures provides some where four or more entry points are provided flexibility for creative playground design. to a soft contained play structure, then at least two entry points must be served by an Accessible Play Components. Accessible accessible route. play components are required to be on accessible routes, including elevated If elevated play components are provided, play components that are required to be fifty percent (50%) of the elevated connected by ramps. These play components components are required to be accessible. must also comply with other accessibility Where 20 or more elevated play components requirements, including specifications for are provided, at least twenty five percent clear floor space and seat heights (where (25%) will have to be connected by a provided). ramp. The remaining play components are permitted to be connected by a transfer A commenter expressed concerns that the system. Where less than 20 elevated play general requirements of section 240.2.1 components are provided, a transfer system of the 2010 Standards and the advisory is permitted in lieu of a ramp. accompanying section 240.2.1 conflict. The comment asserts that section 240.2.1 of A commenter noted that the 2010 Standards the 2010 Standards provides that the only allow for the provision of transfer steps to requirement for integration of equipment is Department of Justice Guidance on the 2010 Standards: Titles II and III - 159