The United States Department of Justice has prepared an excellent document that highlights common errors relating to the Americans with Disabilities Act. Pais Architects in completing ADA compliance surveys have found many of the same items to deficient. There are, however, a few additional mistakes that should be noted. Rather than duplicating US Department of Justice work, we have completed this article as an addendum to their Common ADA Errors and Omissions in New Construction and Alterations. Please click here to access the document.
As a note, not all projects are required to follow the codes listed below, may use a different edition, or may have been modified by an overseeing authority. As such it is important to verify all information and references below are accurate and pertain to your project. Asterisks indicate that additional information is included in the American with Disabilities Act Accessibility Guidelines (ADAAG) Appendix.
Parking
Error/Omission:
There is no accessible parking sign.
The accessible sign is mounted on a short post and is below the height of a parked car.
Result:
A4.6.4 “Signs designating parking places for disabled people can be seen from a driver’s seat if the signs are mounted high enough above ground and located at the front of a parking space.”
Requirement:
4.6.4* “Such signs shall be located so they cannot be obscured by a vehicle parked in the space.”
Accessible Route - Exterior
Error/Omission:
The landing outside the front door is sloped.
Result:
A person in a wheelchair may find it difficult and potentially hazardous to open the door if there is no clear level area in front of the door.
Requirement:
4.13.6 “The floor or ground area within the required clearances shall be level and clear.”
Stairs
Error/Omission:
The distance between the handrails and the walls is not 1-1/2”.
Result:
If the distance is less than required, individuals may have difficulty getting their knuckles in that space and will be unable to grasp the handrail. If the gap is greater than 1-1/2”, people who need to rest their arms on the handrail for support may have their arms slip off the handrail and become trapped.
Requirement:
4.9.4 (3) “The clear space between handrails and wall shall be 1 -1/2 in.”
Error/Omission:
The width of stairs adjacent to areas of rescue assistance are too narrow.
Result:
A4.3.11.3 “A 48 inch wide exit stairway is needed to allow assisted evacuation (e.g., carrying a person in a wheelchair) without encroaching on the exit path for ambulatory persons.
Requirement:
4.3.11.3* “Each stairway adjacent to an area of rescue assistance shall have a minimum clear width of 48 inches between handrails.”
Doors
Error/Omission:
The threshold at the door is too high.
Result:
This error most typically occurs at bathrooms. Having a threshold higher than permitted makes it difficult for an individual in a wheelchair to get over the threshold.
Requirement:
4.13.8* “Thresholds at doorways shall not exceed ¾ in in height for exterior sliding doors or ½ in for other types of doors. Raised thresholds and floor level changes at accessible doorways shall be beveled with a slope no greater than 1:2 (see 4.5.2).”
Error/Omission:
Doors close faster than permitted.
Result:
As the resistance of the door closer may make it difficult to open a door, the speed at which the door closes must be slow enough to permit access.
Requirement:
4.13.10* “If a door has a closer, then the sweep period of the closer shall be adjusted so that from an open position of 70 degrees, the door will take at least 3 seconds to move to a point 3 in from the latch, measured to the leading edge of the door.”
Error/Omission:
The force to open a door is greater than allowed.
Result:
When the opening force is greater than allowed, people with disabilities may be unable to open the door and therefore unable to enter or exit a space.
Requirement:
4.13.11* “(1) Fire doors shall have the minimum opening force allowable by the appropriate administrative authority. (2) Other doors. (a) exterior hinged doors: (Reserved). (b) interior hinged doors: 5 lbf (c) sliding or folding doors: 5 lbf.
These forces do not apply to the force required to retract latch bolts or disengage other devices that may hold the door in a closed position.
Please refer to the appropriate code or authority for the permissible opening force for fire doors. For example the 2006 IBC in section 1008.1.2 specifies, “The opening force for interior side-swinging doors without closers shall not exceed a 5-pound force. For other side-swinging, sliding and folding doors, the door latch shall release when subjected to a 15-pound force. The door shall be set in motion when subjected to a 30-pound force. The door shall swing to a full-open position when subjected to a 15-pound force. Forces shall be applied to the latch side.”
Toilet Rooms and Bathrooms
Error/Omission:
Grab bars in toilet rooms are not installed in the proper locations.
Result:
The placement of the grab bars is important as it allows individuals more easily and safely use a stall. The most common error is placing the side grab bar too close to the back wall and not extending to the 52” dimension, but errors have been found with other grab bar requirements as well.
Requirement:
4.17.6 “Grab bars complying with the length and positioning shown in Fig. 30(a), (b), (c), (d) shall be provided.”
Error/Omission:
Flush controls for toilets and urinals require too much force to operate
Result:
Users with disabilities may not possess the strength to flush the toilet or urinal.
Requirement:
4.16.5* and 4.18.4 Both refer to 4.27.4
4.27.4 “The force to activate controls shall be no greater than 5 lbf.
Error/Omission:
Insufficient knee and toe space is provided under lavatories.
Result:
Wheelchair users are unable to fit underneath the lavatory and may have difficulty using them.
Requirement:
4.19.2 “Provide a clearance of at least 29 in above the finish floor to the bottom of the apron. Knee and toe clearances shall comply with Fig. 31.”
Error/Omission:
Hot water pipes are not insulated or shielded.
Drain pipes are not insulated or shielded.
Result:
The lack or insulation or shielding can lead to burns. This risk is greatest for wheelchair users who have no or limited temperature sensitivity in their legs.
Requirement:
4.19.4 “Hot water and drain pipes under lavatories shall be insulated or otherwise configured to protect against contact. There shall be no sharp or abrasive surfaces under lavatories.”
Error/Omission:
Mirrors are installed too high.
Result:
If the mirror is installed above the required height, the mirror will not be usable for wheelchair users. On common mistake is to install the bottom of the frame rather than the reflecting surface at 40 inches above the finish floor.
Requirement:
4.19.6* “Mirrors shall be mounted with the bottom edge of the reflecting surface no higher than 40 in above the finish floor.”
Mounting Heights
Error/Omission:
Controls intended for use by building are not installed within the permitted reach range.
Public telephones are mounted with controls outside the permitted reach range,
Paper towel and soap dispensers are not installed within the permitted reach range.
Result:
If objects that are intended for occupant use are not installed within the intended reach range, then users in wheelchairs will not be able to use them. A4.27.3 “Electrical receptacles installed to serve individual appliances and not intended for regular or frequent use by building occupants are not required to be mounted within the specified reach ranges.” If a thermostat is installed and is intended to be controlled by the occupant, it would need to be installed within the reach range.
Requirement:
4.27.3 “The highest operable part of controls, dispensers, receptacles, and other operable equipment shall be placed within at least one of the reach ranges specified in 4.2.5 and 4.2.6. Electrical and communications system receptacles on walls shall be mounted no less than 15 in above the floor.”
4.31.3* “The highest operable part of the telephone shall be within the reach ranges specified in 4.2.5 or 4.2.6.
4.2.5* “If the clear floor space only allows forward approach to an object, the maximum high forward reach allowed shall be 48 in (see Fig. 5(a)). The minimum low forward reach is 15 in. If the high forward reach is over an obstruction, reach and clearances shall be as shown in Fig. 5(b).”
4.2.6* If the clear floor space allows parallel approach by a person in a wheelchair, the maximum high side reach allowed shall be 54 in and the low side reach shall be no less than 9 in above the floor (Fig. 6(a) and (b)). If the side reach is over an obstruction, the reach and clearances shall be as shown in Fig 6(c).
Telephones
Error/Omission:
Sufficient space is not provided in front of public telephones.
Result:
People who use a wheelchair will be unable to access the public telephones.
Requirement:
4.31.2 “A clear floor or ground space at least 30 in by 48 in that allows either a forward or parallel approach by a person using a wheelchair shall be provided at telephones.”