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Guidance on the 2010 ADA Standards for Accessible Design

The Department of Justice’s explanation of changes to the ADA design standards, with section-by-section analysis and responses to public comments.

AccessibilityAnthropometry & ergonomics
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Source wording and page order preserved. Drawings and table layouts remain available in the original PDF.

Analysis and Com menta ry on the 201 0 A DAStandards tolerance. Advisory 104.1.1 gives further 106 Definitions guidance about tolerances. Various definitions have been added to the Section 104.2 of the 2010 Standards 2010 Standards and some definitions have provides that where the required number been deleted. of elements or facilities to be provided is determined by calculations of ratios or One commenter asked that the term public percentages and remainders or fractions right-of-way be defined; others asked that result, the next greater whole number of various terms and words defined by the such elements or facilities shall be provided. 1991 Standards, but which were eliminated Where the determination of the required size from the 2010 Standards, plus other words or dimension of an element or facility involves and terms used in the 2010 Standards, be ratios or percentages, rounding down for defined. values less than one-half is permissible. The Department believes that it is not A commenter stated that it is customary in necessary to add definitions to this text the building code industry to round up rather because section 106.3 of the 2010 Standards than down for values less than one-half. provides that the meanings of terms not As noted here, where the 2010 Standards specifically defined in the 2010 Standards, provide for scoping, any resulting fractional in the Department’s ADA regulations, or in calculations will be rounded to the next whole referenced standards are to be defined by number. The Department is retaining the collegiate dictionaries in the sense that the portion of section 104.2 that permits rounding context implies. The Department believes that down for values less than one-half where this provision adequately addresses these the determination of the required size or commenters’ concerns. dimension of an element or facility involves ratios or percentages. Such practice is Scoping and standard with the industry, and is in keeping Technical Requirements with model building codes. 202 Existing Buildings and Facilities 105 Referenced Standards Alterations. Under section 4.1.6(1)(c) of Section 105 lists the industry requirements the 1991 Standards if alterations to single that are referenced in the 2010 Standards. elements, when considered together, amount This section also clarifies that where there is to an alteration of a room or space in a a difference between a provision of the 2010 building or facility, the entire room or space Standards and the referenced requirements, would have to be made accessible. This the provision of the 2010 Standards applies. requirement was interpreted to mean that Department of Justice Guidance on the 2010 Standards: Titles II and III - 73

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