Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards able to satisfy the requirement to provide Visible Alarms. Section 215.3 of the 2010 accessible circulation paths by ensuring that Standards provides that where employee their required primary circulation paths are work areas in newly constructed facilities accessible. have audible alarm coverage they are required to have wiring systems that Individual employee work stations, such as a are capable of supporting visible alarms grocery checkout counter or an automobile that comply with section 702 of the 2010 service bay designed for use by one person, Standards. The 1991 Standards, at section do not contain common use circulation paths 4.1.1(3), require visible alarms to be provided and are not required to comply. Other work where audible fire alarm systems are areas, such as stockrooms that typically have provided, but do not require areas used only narrow pathways between shelves, would by employees as work areas to be equipped be required to design only one accessible with accessibility features. As applied to office circulation path into the stockroom. It would buildings, the 1991 Standards require visible not be necessary to make each circulation alarms to be provided in public and common path in the room accessible. In alterations use areas such as hallways, conference it may be technically infeasible to provide rooms, break rooms, and restrooms, where accessible common use circulation paths in audible fire alarm systems are provided. some employee work areas. For example, in a stock room of a department store Commenters asserted that the requirements significant existing physical constraints, such of section 215.3 of the 2010 Standards would as having to move walls to avoid the loss of be burdensome to meet. These commenters space to store inventory, may mean that it also raised concerns that all employee work is technically infeasible (see section 106.5 areas within existing buildings and facilities “Defined Terms” of the 2010 Standards) must be equipped with accessibility features. to make even the primary common use circulation path in that stock room wide The commenters’ concerns about section enough to be accessible. In addition, the 215.3 of the 2010 Standards represent 2010 Standards include exceptions for a misunderstanding of the requirements common use circulation paths in employee applicable to employee work areas. work areas where it may be difficult to Newly constructed buildings and facilities comply with the technical requirements for merely are required to provide wiring so accessible routes due to the size or function that visible alarm systems can be added as of the areas. The Department believes that needed to accommodate employees who these exceptions will provide the flexibility are deaf or hard of hearing. This is a minimal necessary to ensure that this requirement requirement without significant impact. does not interfere with legitimate business operations. Department of Justice Guidance on the 2010 Standards: Titles II and III - 77