Introducing the New and Improved ADA 2010
A dramatic change from the original 1991 Americans with Disabilities Act (ADA) Standards for Accessible Design, the recently released 2010 ADA Standards update by the Department of Justice has been touted by experts as a great boon for accessibility.
Key changes in the latest ADA Standards will impact healthcare design
“The original standards came out very quickly after the initial ADA was passed and there wasn't a lot of time to think everything through,” explains James L. E. Terry, AIA, LEED AP, whose Birmingham, Alabama-based firm, Evan Terry Associates, works extensively with healthcare facilities nationwide as an architecture and access compliance consultant. “So ADA 2010 is essentially an opportunity to put another 20 years of thinking into creating something that works better for everybody, mostly through clarification and cleaning up language that has been difficult to interpret, apply, and enforce.”
Similarly, Cynthia K. Pozolo, AIA, NCARB, LEED AP, vice president, Kahn Detroit Studio Director, Albert Kahn Associates, observes, “The changes were developed with extensive input from the public and practitioners, and are very positive in their clarity and collaborative spirit.
Because they address previous ambiguities, they establish spatial and operational consistencies throughout buildings and facilities.”
While a number of changes-such as stricter reach range requirements, greater toilet room clearances, and clarified language for construction and manufacturing tolerances-are rather significant, the good news is they are quite minor when compared to the 2009 and 2006 International Building Code (IBC), currently in use in most states.
In particular, the IBC contains scoping for accessibility elements, while the widely adopted ICC/ANSI A117.1 2003 spells out the details describing those elements.
“Essentially, those who are already accustomed to complying with the 2009 IBC accessibility rules should have no problem with the 2010 ADA Standards,” assures Duane L. Jonlin, AIA, LEED AP, principal, NBBJ, Seattle.
Another important issue is determining which standards to use for the design of new healthcare projects with the new ADA officially going into effect on March 15, 2012. Private facilities can stick with the old standards on current and upcoming projects as long as a building permit application is submitted before the March 2012 deadline, on the other hand, state and local government hospital projects must begin using the ADA Standards immediately unless the start of physical construction begins prior to March 15, 2012.
Comparison of Single-User Toilet Room Layouts
Plan-2A: 1991 Standards Minimum with In-Swinging Door. 5′-0″ x 8′-6″ 42.50 Square Feet. Diagram courtesy of the U.S. Department of Justice.
Plan-2B: 2010 Standards Minimum with In-Swinging Door. 7′-0″ x 6′-6″ 45.50 Square Feet. Diagram courtesy of the U.S. Department of Justice.
Taking a closer look
Toilet rooms. Delving into some of the 2010 updates relevant to healthcare design, the shape and size of toilet rooms has changed as more space is now required around a toilet fixture. Consequently, the lavatory can no longer intrude into the toilet's 5-foot-wide clear floor space.
“Changes allow for better layouts and area usage without major changes in accessibility,” assures Marian Danowski, AIA, CSI, LEED AP BD+C, associate principal, technical director, Perkins+Will, Washington, D.C. “Clarifying overlap of approaches, turning radius, and door swings will improve designer and builder acceptance and understanding, and, therefore, compliance.”
In addition, Jonlin points out that with an out-swinging door, it is still possible to design a fully compliant toilet room with a reasonably small footprint. In addition, a new “cluster” rule states that if two or more unisex toilet rooms are within sight of one another, then only half of them need to be accessible, while the others can be as small as allowable by the local plumbing code.
Reach range. In the new standards, side reach range decreased from 54 inches to 48 inches, and low reach increased from 9 inches to 15 inches off the floor, so designers now have smaller dimensions to work with when specifying controls such as outlets and light switches.
“This development has recognized that the original dimensions, intended to protect children by placing items out of reach, is an undue burden on others who could not easily reach that high,” explains Danowki's colleague Jonathan Hoffschneider, AIA, LEED AP BD+C, associate principal, senior project manager.
Overall, Hoffschneider also points out that the new ADA does a good job of tailor-making the building standards to the individual needs of both adults and children.
Accessible route through employee work areas. Whereas the 1991 ADA only required accessibility to an employee work area at the doorway itself, the 2010 ADA mandates an accessible route all the way through the area, unless it is smaller than 1,000 square feet. However, common use spaces like break rooms and training rooms still have to meet the full standard.
“This is a pretty big deal, particularly for hospitals, as it will affect things like layouts, level changes, and alarm wiring in larger employee-only areas,” Terry points out.
Overall, the Perkins+Will architects are pleased with the change in that it supports healthcare staff with disabilities. “This will result in a better working environment for the medical staff, which evidence has shown will subsequently raise the quality of patient care,” Hoffschneider claims.
Construction and manufacturing tolerances. While dimensions in the building blueprint can easily be precise and exact, this is much more challenging in the real world of construction. Consequently, a more flexible and much clearer definition of tolerances in the new ADA comes as a welcome change.
“There was a practical need for this,” states Jocelyn Stroupe, IIDA, AAHID, EDAC, director of healthcare interiors, Cannon Design, Chicago. “It's a start and it will make life easier.”
In fact, Danowski claims that acceptance of construction and manufacturing tolerances is essential when renovating spaces for ADA compliance. “The acceptance of construction tolerances in the standards establishes realistic variations in lieu of strict absolutes that often prove difficult, if not impossible to achieve,” she says.
A diagram of the unobstructed side reach from the ADA 2010 Standards for Accessible Design. Diagram courtesy of the U.S. Department of Justice.
On the other hand, while Pozolo is also pleased with the change, she points out that contingency space still needs to be designed into horizontal dimensions as the tolerance and acceptability of installations remains subject to local inspectors. “Oversizing horizontal dimensions will drive up building size and costs unnecessarily,” she cautions, “so this topic warrants further evaluation as ADA 2010 is rolled out.”
Signage requirements. According to Terry, the new standard's more detailed requirements for signage size and placement are quite significant. For example, the minimum character height for overhead visual signs used to be 3-inches tall regardless of where they were mounted, but in the new ADA, the letters must be sized based upon the expected distance for reading them. As for raised letter and Braille signs, the base of all tactile characters must now be between 48 and 60 inches from the ground, instead of centering the whole sign at 60 inches.
“By spelling out specific requirements, the 2010 ADA establishes certain minimums that must be complied with and clarifies some of the requirements that the industry had defined on its own,” observes Danowski. “Putting the requirements squarely in the 2010 ADA will eliminate many questions and eliminate disagreements when the standards are clear.”
Safe harbor provision. Offering some breathing room for healthcare facility renovations, the safe harbor provision in the 2010 ADA states that when spaces are retrofitted, as long as the different elements comply with the 1991 ADA, they don't all have to be updated to conform to the new standards.
“It used to be that the whole space had to be updated, as well as adding an accessible route, but now any parts that meet the 1991 standards won't need to be changed,” says Terry. “This will equate to a significant cost savings.”
“While the new requirements may be better, the old requirements offer what appears to be a reasonable accommodation, so requiring retrofits to conform old requirements to new standards would likely cause undue hardship on facility owners,” Stroupe agrees.
Briefly noting a few other changes pertinent to healthcare facilities, Terry mentions the following:
If stairwells in new facilities are part of a required means of egress, they must comply with accessibility requirements such as handrails, nosings, and treads and risers.
Patient dressing rooms must provide a 30-inch by 48-inch wheelchair clear floor space at the end of a 20-inch by 42-inch bench, making the space a minimum of 40 square feet.
The regulations require a hospital's accessible patient rooms to be “dispersed” among the various departments as opposed to clustering them in one location.
The requirements for handrail profiles are stricter and apply wherever they are specified, (including corridors,) as opposed to only at ramps and stairways.
The ratio for van parking spaces has increased from one van space for every eight standard accessible spaces to one van space for every six accessible parking spaces.
In all facilities, fire alarms no longer have to be upgraded during general renovations unless the alarms are a part of the actual retrofit work for other reasons.
2010 ADA and IBC/ANSI A117.1
Fortunately, as mentioned, the new ADA is much more in sync with the widely utilized IBC/ICC and ANSI Standard, so the overall implications for healthcare design will ultimately not be as dramatic as the 1991 to 2010 differences suggest. At the same time, the IBC does differ from the 2010 ADA in a few places, and in some cases, is actually stricter.
For example, while the new ADA exempts “employee work areas” smaller than 1,000 square feet from needing accessible circulation paths, the IBC only grants this exemption if these spaces are smaller than 300 square feet.
In addition, while the 2010 ADA only requires a horizontal grab bar next to the toilet fixture, ICC/ANSI A117.1 smandates an additional vertical grab bar to be placed on the side wall above the horizontal bar.
One other important distinction is the fact that the IBC is enforced by the local building official, who is empowered to interpret the rules, while the ADA is “enforced” by private lawsuits or by the Department of Justice after an official discrimination complaint has been filed, Jonlin clarifies.
“With each generation of accessibility standards, the cooperation and coordination between the [Department of Justice]/U.S. Access Board and ANSI/ICC is more evident. While acknowledging the complexity of standards development, I think most architects look forward to the day when there is a single applicable standard,” Hoffschneider notes.
In terms of gearing up for the new standards, the ADA has published them in full and made available the document “Guidance on the 2010 ADA Standards for Accessible Design,” both offered as free downloads at: http://www.ada.gov/2010ADAstandards_index.htm. In addition, Terry's firm is offering a free ADA standards comparison spreadsheet, accessible at www.ADAStandardsComparison.com, providing a line-by-line comparison between the two standards. Furthermore, a number of Webinars are currently available, such as the National Association of ADA Coordinators' “ADA, the Next Generation,” www.adawebinars.com. HCD
Barbara Horwitz-Bennett (
www.bhbennett.com) is a frequent contributor to publications and organizations dealing with building and construction. She can be reached at
firstname.lastname@example.org. Healthcare Design 2011 February;11(2):24-30