Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards • Employee work areas, or portions of • Machinery and equipment are permitted employee work areas, that are less than to reduce the clear width of common use 300 square feet and are elevated 7 inches circulation paths where the reduction is or more above the ground or finish floor, essential to the function of the work per- where elevation is essential to the func- formed. Machinery and equipment that tion of the space, are exempt. must be placed a certain way to work properly, or for ergonomics or to prevent • Common use circulation paths within workplace injuries are covered by this employee work areas that are less than exception. 1,000 square feet and are defined by permanently installed partitions, counters, • Handrails are not required on ramps, pro- casework, or furnishings are exempt. vided that they can be added in the future. Kitchens in quick service restaurants, cocktail bars, and the employee side of Commenters stated that the requirements service counters are frequently covered set out in the 2010 Standards for accessible by this exception. common use circulation paths in employee work areas are inappropriate, particularly in • Common use circulation paths within commercial kitchens, storerooms, and behind employee work areas that are an integral cocktail bars where wheelchairs would not be component of equipment are exempt. easily accommodated. These commenters Common use circulation paths within further urged the Department not to adopt large pieces of equipment in factories, a requirement that circulation paths in electric power plants, and amusement employee work areas be at least 36 inches rides are covered by this exception. wide, including those at emergency exits. • Common use circulation paths within These commenters misunderstand the exterior employee work areas that are scope of the provision. Nothing in the 2010 fully exposed to the weather are exempt. Standards requires all circulation paths in Farms, ranches, and outdoor mainte- non-exempt areas to be accessible. The nance facilities are covered by this excep- Department recognizes that building codes tion. and fire and life safety codes, which are adopted by all of the states, require primary The 2010 Standards in sections 403.5 and circulation paths in facilities, including 405.8 also contain exceptions to the technical employee work areas, to be at least 36 requirements for accessible routes for inches wide for purposes of emergency circulation paths in employee work areas: egress. Accessible routes also are at least 36 inches wide. Therefore, the Department anticipates that covered entities will be 76 - Guidance on the 2010 Standards: Titles II and III Department of Justice