Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards such as associated grab bars, dispensers, In the NPRM, the Department provided sanitary napkin disposal units, coat hooks, a series of plan drawings illustrating and shelves to overlap the clear floor space. comparisons of the minimum size single- These are items that typically do not affect user toilet rooms. These floor plans the usability of the clear floor space. showed typical examples that met the minimum requirements of the proposed Toilet Room Doors. Sections 4.22.2 and ADA Standards. A commenter was of the 4.22.3 of the 1991 Standards and Section opinion that the single-user toilet plans 603.2.3 of the 2010 Standards permit the shown in the NPRM demonstrated that doors of all toilet or bathing rooms with in- the new requirements will not result in a swinging doors to swing into the required substantial increase in room size. Several turning space, but not into the clear floor other commenters representing industry space required at any fixture. In single- offered criticisms of the single-user toilet user toilet rooms or bathing rooms, Section floor plans to support their assertion that a 603.2.3 Exception 2 of the 2010 Standards 2010 Standards-compliant single-user toilet permits the door to swing into the clear floor room will never be smaller and will likely space of an accessible fixture if a clear floor be larger than such a toilet room required space that measures at least 30 inches by 48 under the 1991 Standards. Commenters inches is provided outside of the door swing. also asserted that the floor plans prepared by the Department were of a very basic Several commenters expressed reservations design which could be accommodated in about Exception 2 of Section 603.2.3. a minimal sized space whereas the types Concerns were raised that permitting of facilities their customers demand would doors of single-user toilet or bathing rooms require additional space to be added to with in-swinging doors to swing into the the rooms shown in the floor plans. The clearance around any fixture will result in Department recognizes that there are many inaccessibility to individuals using larger design choices that can affect the size of a wheelchairs and scooters. Additionally, a room or space. Choices to install additional commenter stated that the exception would features may result in more space being require an unacceptable amount of precision needed to provide sufficient clear floor maneuvering by individuals who use standard space for that additional feature to comply. size wheelchairs. The Department believes However, many facilities that have these that this provision achieves necessary extra features also tend to have ample space flexibility while providing a minimum standard to meet accessibility requirements. Other for maneuvering space. The standard does commenters asserted that public single- permit additional maneuvering space to be user toilet rooms always include a closer provided, if needed. and a latch on the entry door, requiring a larger clear floor space than shown on the Department of Justice Guidance on the 2010 Standards: Titles II and III - 95