Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards with disabilities, may run afoul of state or to self-park may be a required reasonable local requirements, or may not be needed modification of policy by a covered entity. because many passenger loading zones are typically staffed by doormen or valet parkers. 210 and 504 Stairways The wide range of opinions expressed in these comments indicates that this provision The 1991 Standards require stairs to be is controversial. However, none of these accessible only when they provide access to comments provided sufficient data to enable floor levels not otherwise connected by an the Department to determine that the accessible route (e.g., where the accessible requirement is not appropriate. route is provided by an elevator, lift, or ramp). The 2010 Standards, at sections 210.1 and Valet Parking and Mechanical Access 504, require all newly constructed stairs that Parking Garages. The 1991 Standards, at are part of a means of egress to comply sections 4.1.2(5)(a) and (e), and sections with the requirements for accessible stairs, 208.2, 209.4, and 209.5 of the 2010 which include requirements for accessible Standards require parking facilities that treads, risers, and handrails. In existing provide valet parking services to have an facilities, where floor levels are connected accessible passenger loading zone. The by an accessible route, only the handrail 2010 Standards extend this requirement to requirement will apply when the stairs are mechanical access parking garages. The altered. Exception 2 to section 210.1 of 1991 Standards contained an exception the 2010 Standards permits altered stairs that exempted valet parking facilities from to not comply with the requirements for providing accessible parking spaces. The accessible treads and risers where there is 2010 Standards eliminate this exception. The an accessible route between floors served by reason for not retaining the provision is that the stairs. valet parking is a service, not a facility type. Most commenters were in favor of this Commenters questioned why the exception requirement for handrails in alterations and for valet parking facilities from providing stated that adding handrails to stairs during accessible parking spaces was eliminated. alterations would be feasible and not costly The provision was eliminated because valet while providing important safety benefits. parkers may not have the skills necessary The Department believes that it strikes to drive a vehicle that is equipped to be an appropriate balance by focusing the accessible, including use of hand controls, or expanded requirements on new construction. when a seat is not present to accommodate The 2010 Standards apply to stairs which a driver using a wheelchair. In that case, are part of a required means of egress. Few permitting the individual with a disability stairways are not part of a means of egress. The 2010 Standards are consistent with 90 - Guidance on the 2010 Standards: Titles II and III Department of Justice