Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards Section-by-Section Analysis with Public Comments Application and Administration properly rests with the covered entity. The purpose of allowing for equivalent facilitation 102 Dimensions for Adults and Children is to encourage flexibility and innovation while still ensuring access. The Department Section 2.1 of the 1991 Standards stated believes that establishing potentially that the specifications were based upon adult cumbersome bureaucratic provisions for dimensions and anthropometrics. reviewing requests for equivalent facilitation The 1991 Standards did not provide specific is inappropriate. requirements for children’s elements or facilities. 104 Conventions Section 102 of the 2010 Standards states Dimensions. Section 104.1 of the 2010 that the technical requirements are based Standards notes that dimensions not stated on adult dimensions and anthropometrics. as a “maximum” or “minimum” are absolute. In addition, technical requirements are also Section 104.1.1 of the 2010 Standards provided based on children’s dimensions and provides that all dimensions are subject to anthropometrics for drinking fountains, water conventional industry tolerances except closets and other elements located in toilet where the requirement is stated as a range compartments, lavatories and sinks, dining with specific minimum and maximum surfaces, and work surfaces. end points. A commenter stated that the 2010 Standards restrict the application of 103 Equivalent Facilitation construction tolerances only to those few requirements that are expressed as an This section acknowledges that nothing absolute dimension. in these requirements prevents the use of designs, products, or technologies as This is an incorrect interpretation of sections alternatives to those prescribed, provided 104.1 and 104.1.1 of the 2010 Standards. that the alternatives result in substantially Construction and manufacturing tolerances equivalent or greater accessibility and apply to absolute dimensions as well as to usability. dimensions expressed as a maximum or minimum. When the requirement states a A commenter encouraged the Department specified range, such as in section 609.4 to include a procedure for determining where grab bars must be installed between equivalent facilitation. The Department 33 inches and 36 inches above the finished believes that the responsibility for determining floor, that range provides an adequate and demonstrating equivalent facilitation 72 - Guidance on the 2010 Standards: Titles II and III Department of Justice