Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards elements, along accessible routes, and in will be burdensome for small businesses to accessible rooms and spaces to be placed comply with. These comments argued that within the forward or side-reach ranges the new reach range requirements restrict specified in section 308. The 2010 Standards design options, especially in residential also require at least five percent (5%) of housing. mailboxes provided in an interior location and at least one of each type of depository, The Department continues to believe that vending machine, change machine, and gas data submitted by advocacy groups and pump to meet the technical requirements for others provides compelling evidence that a forward or a side reach. lowered reach range requirements will better serve significantly greater numbers Section 4.2.6 of the 1991 Standards specifies of individuals with disabilities, including a maximum 54-inch high side reach and individuals of short stature, persons with a minimum 9-inch low side reach for an limited upper body strength, and others unobstructed reach depth of 10 inches with limited use of their arms and fingers. maximum. Section 308.3.1 of the 2010 The change to the side-reach range was Standards specifies a maximum 48-inch high developed by the Access Board over side reach and a minimum 15-inch low side a prolonged period in which there was reach where the element being reached for extensive public participation. This process is unobstructed. Section 308.3.1, Exception did not produce any significant data to 1, permits an obstruction that is no deeper indicate that applying the new unobstructed than 10 inches between the edge of the clear side-reach range requirement in new floor or ground space and the element that construction or during alterations would the individual with a disability is trying to impose a significant burden. reach. Changes in the side-reach range for new construction and alterations in the 2010 206 and Chapter 4 Accessible Routes Standards will affect a variety of building elements such as light switches, electrical Slope. The 2010 Standards provide, at outlets, thermostats, fire alarm pull stations, section 403.3, that the cross slope of walking card readers, and keypads. surfaces not be steeper than 1:48. The 1991 Standards’ cross slope requirement Commenters were divided in their views was that it not exceed 1:50. A commenter about the changes to the unobstructed side- recommended increasing the cross slope reach range. Disability advocacy groups and requirement to allow a maximum of ½ inch others, including individuals of short stature, per foot (1:24) to prevent imperfections in supported the modifications to the proposed concrete surfaces from ponding water. The reach range requirements. Other commenters Department continues to believe that the stated that the new reach range requirements requirement that a cross slope not be steeper Department of Justice Guidance on the 2010 Standards: Titles II and III - 79