Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards rather than the one hundred percent (100%) toilet compartments and 17 to 19 inches in required by the 1991 Standards, are required ambulatory accessible toilet compartments. to be accessible by section 213.2, Exception 4 of the 2010 Standards. Section 216.8 of Water Closet Clearance. Section 604.3 of the 2010 Standards requires that accessible the 2010 Standards represents a change single-user toilet rooms must be identified in the accessibility requirements where a by the International Symbol of Accessibility lavatory is installed adjacent to the water where all single-user toilet rooms are not closet. The 1991 Standards allow the accessible. nearest side of a lavatory to be placed 18 inches minimum from the water closet Hospital Patient Toilet Rooms. An centerline and 36 inches minimum from exception was added in section 223.1 of the the side wall adjacent to the water closet. 2010 Standards to allow toilet rooms that However, locating the lavatory so close to are part of critical or intensive care patient the water closet prohibits many individuals sleeping rooms to no longer be required to with disabilities from using a side transfer. provide mobility features. To allow greater transfer options, including side transfers, the 2010 Standards prohibit Water Closet Location and Rear Grab lavatories from overlapping the clear floor Bar. Section 604.2 of the 2010 Standards space at water closets, except in covered allows greater flexibility for the placement residential dwelling units. of the centerline of wheelchair accessible and ambulatory accessible water closets. A majority of commenters, including persons Section 604.5.2, Exception 1 permits a who use wheelchairs, strongly agreed with shorter grab bar on the rear wall where there the requirement to provide enough space for is not enough wall space due to special a side transfer. These commenters believed circumstances (e.g., when a lavatory or that the requirement will increase the usability other recessed fixture is located next to of accessible single-user toilet rooms by the water closet and the wall behind the making side transfers possible for many lavatory is recessed so that the lavatory does individuals who use wheelchairs and would not overlap the required clear floor space have been unable to transfer to a water at the water closet). The 1991 Standards closet using a side transfer even if the water contain no exception for grab bar length, closet complied with the 1991 Standards. In and require the water closet centerline to be addition, many commenters noted that the exactly 18 inches from the side wall, while additional clear floor space at the side of the the 2010 Standards requirement allows the water closet is also critical for those providing centerline to be between 16 and 18 inches assistance with transfers and personal care from the side wall in wheelchair accessible for persons with disabilities. Numerous comments noted that this requirement is Department of Justice Guidance on the 2010 Standards: Titles II and III - 93