Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards already included in other model accessibility Several commenters concluded that standards and many state and local building alterations of single-user toilet rooms codes and its adoption in the 2010 Standards should be exempt from the requirements is a important part of harmonization efforts. of section 604.3 of the 2010 Standards The Department agrees that the provision because of the significant reconfiguration and of enough clear floor space to permit side reconstruction that would be required, such transfers at water closets is an important as moving plumbing fixtures, walls, and/or feature that must be provided to ensure doors at significant additional expense. The access for persons with disabilities in Department disagrees with this conclusion toilet and bathing facilities. Furthermore, since it fails to take into account several the adoption of this requirement closely key points. The 2010 Standards contain harmonizes with the model codes and many provisions for in-swinging doors, 603.2.3, state and local building codes. Exception 2, and recessed fixtures adjacent to water closets, 604.5.2, Exception 1. These Other commenters urged the Department not provisions give flexibility to create more to adopt section 604.3 of the 2010 Standards compact room designs and maintain required claiming that it will require single-user clearances around fixtures. As with the 1991 toilet rooms to be two feet wider than the Standards, any alterations must comply to 1991 Standards require, and this additional the extent that it is technically feasible to do requirement will be difficult to meet. Multiple so. commentators also expressed concern that the size of single-user toilet rooms would The requirements at section 604.3.2 of be increased but they did not specify how the 2010 Standards specify how required much larger such toilet rooms would have to clearance around the water closet can be in their estimation. In response to these overlap with specific elements and spaces. concerns, the Department developed a An exception that applies only to covered series of single-user toilet room floor plans residential dwelling units permits a lavatory demonstrating that the total square footage to be located no closer than 18 inches between representative layouts complying from the centerline of the water closet. with the 1991 Standards and the 2010 The requirements at section 604.3.2 of the Standards are comparable. The Department 2010 Standards increase accessibility for believes the floor plan comparisons clearly individuals with disabilities. One commenter show that size differences between the two expressed concern about other items that Standards are not substantial and several of might overlap the clear floor space, such as the 2010 Standards-compliant plans do not dispensers, shelves, and coat hooks on the require additional square footage compared side of the water closet where a wheelchair to the 1991 Standards plans. These single- would be positioned for a transfer. Section user toilet room floor plans are shown below. 604.3.2 of the 2010 Standards allows items 94 - Guidance on the 2010 Standards: Titles II and III Department of Justice