Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards The other issue in the comments represents exceptions covering operable parts intended a misunderstanding of the Department’s only for use by service or maintenance existing regulatory requirements. Employee personnel, electrical or communication common use areas in covered facilities receptacles serving a dedicated use, and (e.g., locker rooms, break rooms, cafeterias, floor electrical receptacles. Operable parts toilet rooms, corridors to exits, and other covered by these new exceptions are exempt common use spaces) were required to from all of the technical requirements for be accessible under the 1991 Standards; operable parts in section 309. The 2010 areas in which employees actually perform Standards also add exceptions that exempt their jobs are required to enable a person certain outlets at kitchen counters; heating, using a wheelchair or mobility device to ventilating and air conditioning diffusers; approach, enter, and exit the area. The 2010 redundant controls provided for a single Standards require increased access through element, other than light switches; and the accessible common use circulation path exercise machines and equipment from all requirement, but neither the 1991 Standards of the technical requirements for operable nor the 2010 Standards require employee parts. Exception 7, in section 205.1 of the work stations to be accessible. Access to 2010 Standards, exempts cleats and other specific employee work stations is governed boat securement devices from the accessible by title I of the ADA. height requirement. Similarly, section 309.4 of the 2010 Standards exempts gas 205 and 309 Operable Parts pump nozzles, but only from the technical requirement for activating force. Section 4.1.3, and more specifically sections 4.1.3(13), 4.27.3, and 4.27.4 of Reach Ranges. The 1991 Standards set the 1991 Standards, require operable parts the maximum height for side reach at 54 on accessible elements, along accessible inches above the floor. The 2010 Standards, routes, and in accessible rooms and spaces at section 308.3, lower that maximum height to comply with the technical requirements to 48 inches above the finish floor or ground. for operable parts, including height and The 2010 Standards also add exceptions, as operation. The 1991 Standards, at section discussed above, to the scoping requirement 4.27.3, contain an exception, “ * * * where the for operable parts for certain elements that, use of special equipment dictates otherwise among other things, will exempt them from or where electrical and communications the reach range requirements in section 308. systems receptacles are not normally intended for use by building occupants,” from The 1991 Standards, at sections 4.1.3, the technical requirement for the height of 4.27.3, and 4.2.6, and the 2010 Standards, operable parts. Section 205.1 of the 2010 at sections 205.1, 228.1, 228.2, 308.3, and Standards divides this exception into three 309.3, require operable parts of accessible 78 - Guidance on the 2010 Standards: Titles II and III Department of Justice