ADA Compliance: Avoiding Common Problems
Complying with the design standards of the Americans with Disabilities Act (ADA) is all in the details. If a grab bar is located half an inch too high, it is technically non-compliant under the 2010 ADA Standards and as such opens the door for a complaint or lawsuit to be served on the unfortunate owner or operator of the facility. A single, out-of-place grab bar may seem insufficient to warrant a complaint, but most properties, upon closer inspection of the details, have more issues. There are three facets of a building's life cycle that have an impact on compliance with ADA: design, construction, and maintenance. There are common problems with ADA compliance in each area.
Digging Into Design Details
The original ADA requirements were embodied in the 1991 ADA Standards for Accessible Design that went into effect back in 1992. Recent changes in the law require that any work (including alterations) after March 15, 2012, must comply with the 2010 ADA Standards. There are several important differences between the two standards, one of which deals with tolerances, i.e., how closely the dimensions of the finished work match the dimensional requirements found in the standards.
The 2010 ADA Standards at Section 104.1.1 — Construction and Manufacturing Tolerances state, "All dimensions are subject to conventional industry tolerances except where the requirement is stated with a range with specific minimum and maximum end points." This means that any criteria that are stated as a range have no tolerance. The range itself, according to the U.S. Department of Justice (DOJ), provides the construction tolerance.
Architectural drawings, specifically detail drawings, should dimension elements not to the end points of the range but incorporate the range into the design. For example, while a water closet centerline dimensioned at 18 inches from the sidewall is compliant (16-18 inches is the range for water closet centerline under the 2010 ADA standards), that dimension leaves no room for construction variations beyond 18 inches. It would be better to dimension the toilet at 17 inches, allowing for an inch of leeway for construction variations.
The 1991 ADA Standards required exactly 18 inches, which, with that Standard's construction tolerance language, was compliant even if it varied sometimes as much as an inch on either side of the 18-inch requirement. In a perfect world, this would not be an issue; in reality, however, construction tolerances need to be taken into account. The waste line may not be exactly where it should be, or the model of water closet may be changed during construction, or the sidewall finish may be changed to a thicker or thinner product due to material availability. There are many possible scenarios for why the water closet centerline may be more than the maximum 18 inches, which means the water closet location is not compliant. But if the water closet was dimensioned at 17 inches, then a construction tolerance is designed into the drawings.
Other design considerations for ADA compliance include dimensioning to finishes. This requires coordination between design drawings and material selection to account for the actual thickness of finish materials. Door maneuvering clearances usually suffer in this case. Plans will show the pull side maneuvering clearance past the latch to a sidewall dimensioned at the required 18 inches for a forward approach. When the constructed condition is surveyed, it is common to find the dimension to the wallboard is 18 inches; however, depending on the selected base molding, the maneuvering clearance may be cut to less than 18 inches.
ADA compliance is designed in the details, and a high level of attention and coordination needs to be incorporated into dimensioning the plans and elevations to provide contractors correct information. Having a design team member with experience or training in the ADA standards, whose sole purpose is checking for accessibility compliance, or using an outside consultant who specializes in accessibility is an important step to achieve compliance.