ARTICLE

How Far We've Come:

Compliance with New Accessibility Standards

By Kimberly Paarlberg, RA, and Jay Woodward, RA, ICC Senior Staff Architects

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A woman participating in the research study on anthropometrics in the 1950s.
A woman participating in the research study on anthropometrics in the 1950s.

Compliance with the new federal standards for accessibility will be required as of March 15, 2012. The 2009 edition of the ICC A117.1, Accessible and Usable Buildings and Facilities, will be referenced in the 2012 International Building Code. So there will be a learning curve for all architects and contractors in dealing with some of the new requirements. Knowing the history of the standard and the reasons behind revisions will help everyone when determining what is important when dealing with gray areas, alternative approvals, existing building constraints and developing best design practices.

History

I (Kim) recently spent some time in the archives at the University of Illinois in Champaign/Urbana. What motivated my research is the fact that the A117.1 Standard, Accessible and Usable Buildings and Facilities will be 50 years old in 2011. The first A117.1 came out in 1961 and was reaffirmed in 1971.

I looked through the files of the original development committee and the personal files of Dr. Tim Nugent. Nugent served as the first secretariat and then chair of the committee for a number of years. The research that he did with students at the University of Illinois was one of the primary resources for the “building blocks” used to develop the requirements for accessible design. Physical therapists, mechanical engineers and students with disabilities worked together to gather ergonomic research to develop criteria for clear floor space, turning space, reach ranges, ramps, etc. 

I found it interesting that what the students could actually achieve was greater than the suggested minimum requirements. For example, the side reach range measured was 54 inches to 78 inches, with an average of 60 inches (1961 A117.1 Section 3.3.1). The 54 inches that ended up in ADAAG and later editions of the A117.1 as the high end of side reach is what was “comfortable" for all tested subjects. 

Nugent was the founder of the Division of Disability Resources and Educational Services for the University of Illinois. His responsibilities included looking for ways to make the entire campus accessible so students could participate in all activities offered by the University. Given the school had over 200 buildings on over 1000 acres, and has some of the oldest college buildings in the state, this was quite a job assignment. In March the University named a newly constructed residence hall in honor of Nugent - another example of how the work Nugent nurtured continues to grow and expand.

Reasons for the Revisions

The International Code Council (ICC) and the U.S. Access Board continue to work together on coordination and clarifications. Below are the sections dealing with side reach for the 2010 Standard for Accessible Design and the 2009 ICC A117.1. 2010 Standard for Accessible Design The Department of Justice officially published the 2010 Standard for Accessible Design in the Federal Register on Sept. 15, 2010. While a designer can choose to use the new requirements now, compliance isn’t required until March 15, 2012.Click here to see 2010 ADA Standards for Accessible Design and the Guidance.

This federal standard will match the 1998 and 2003 ICC A117.1 revisions that limit the side reach from 15 inches to 48 inches. This is different from the 1991 ADAAG, which allowed for a side reach of 9 inches to 54 inches. Both documents revised the side reach based on statistical data provided by an organization called Little People of America. Their concern was for persons with limited reach having access to controls, ATMs and fuel pumps.

 2010 Standard for Accessible Design

 

308.3 Side Reach.

 

308.3.1 Unobstructed. Where a clear floor or ground space allows a parallel approach to an element and the side reach is unobstructed, the high side reach shall be 48 inches (1220 mm) maximum and the low side reach shall be 15 inches (380 mm) minimum above the finish floor or ground.

EXCEPTIONS:

  1. An obstruction shall be permitted between the clear floor or ground space and the element where the depth of the obstruction is 10 inches (255 mm) maximum.
  2. Operable parts of fuel dispensers shall be permitted to be 54 inches (1370 mm) maximum measured from the surface of the vehicular way where fuel dispensers are installed on existing curbs.

 

308.3.2 Obstructed High Reach. Where a clear floor or ground space allows a parallel approach to an element and the high side reach is over an obstruction, the height of the obstruction shall be 34 inches (865 mm) maximum and the depth of the obstruction shall be 24 inches (610 mm) maximum. The high side reach shall be 48 inches (1220 mm) maximum for a reach depth of 10 inches (255 mm) maximum. Where the reach depth exceeds 10 inches (255 mm), the high side reach shall be 46 inches (1170 mm) maximum for a reach depth of 24 inches (610 mm) maximum.

 

EXCEPTIONS:

  1. The top of washing machines and clothes dryers shall be permitted to be 36 inches (915 mm) maximum above the finish floor.
  2. Operable parts of fuel dispensers shall be permitted to be 54 inches (1370 mm) maximum measured from the surface of the vehicular way where fuel dispensers are installed on existing curbs.
2009 ICC A117.1

The A117.1 development committee strives to clarify requirements as well as address coordination items. I (Jay) wrote about the revisions for side reach in the Significant Changes to the A117.1 Accessibility Standard. Below are some excerpts on side reach.  Revisions to the A117.1 text are shown in legislative (i.e., strike out/underline) format.

308.3 Side Reach.

308.3.1 Unobstructed.Where a clear floor space complying with Section 305 allows a parallel approach to an element and the side reach is unobstructed, edge of the clear floor space is 10 inches (255 mm) maximum from the element, the high side reach shall be 48 inches (1220 mm) maximum and the low side reach shall be 15 inches (380 mm) minimum above the floor.

EXCEPTION: Existing elements that are not altered shall be permitted at 54 inches (1370 mm) maximum above the floor.

 

The intent of the change is to provide clarification as to where the clear floor space must be located to be considered an unobstructed reach to an element or control. The exception limits the high reach for existing elements.

To provide an “unobstructed” reach to an element, the clear floor space must be located within 10 inches horizontally, and any obstruction within that space must be 34 inches or less in height. This will help to distinguish when Section 308.3.1 for the “unobstructed” reach is used and when Section 308.3.2 for the “obstructed high reach” is applicable. By requiring the clear floor space to be located within the 10-inch horizontal distance and unobstructed, most users will be able to reach any element within the normal reach range limits.

The inclusion of this text will help to coordinate with the revised ADA and ABA Accessibility Guidelines. This revision was not intended to create any technical changes but was considered more as a clarification or interpretation of Figure 308.3.1 from the 2003 edition of the standard and Figure 6(b) from the original ADA Accessibility Guidelines (ADAAG). However, this will make it obvious that in order to provide full access to an element a clear floor space must not be located more than 10 inches horizontally from the element.

Adding the text “that are not altered” into the exception helps to clarify and limit the application of the exception. If an existing element is altered, it should comply with the 48-inch height limitation. Earlier editions of the A117.1 standard and the original ADAAG permitted a 54-inch high side reach. Because of this earlier allowance, numerous elements in existing buildings may be located above the 48-inch maximum height that is required by the base paragraph.

308.3 Side Reach.

308.3.2 Obstructed High Reach.Where a clear floor space complying with Section 305 allows a parallel approach to an object element and the high side reach is over an obstruction, the height of the obstruction shall be 34 inches (865 mm) maximum above the floor and the depth of the obstruction shall be 24 inches (610 mm) maximum. The high side reach shall be 48 inches (1220 mm) maximum above the floor for a reach depth of 10 inches (255 mm) maximum. Where the reach depth exceeds 10 inches (255 mm), the high side reach shall be 46 inches (1170 mm) maximum above the floor for a reach depth of 24 inches (610 mm) maximum.

EXCEPTION: At washing machines and clothes dryers, the height of the obstruction shall be permitted to be 36 inches (915 mm) maximum above the floor.

 

The addition of the exception is the primary change within this section. The exception is included to conform to the revised ADA and ABA AG, which allow washers and dryers to exceed the maximum height requirements for obstructed reach. Otherwise, accessible machines would likely provide limited capacity as compared to inaccessible machines. There is slightly different wording between that of the ADA and ABA AG and the A117.1 to match the language in the charging paragraph.

The addition of the exception is also somewhat in recognition of the fact that the typical laundry equipment available on the market is 36 inches in height. It is this recognition of reality that was the basis for the concern that smaller equipment that could meet the 34-inch height limit would affect the capacity of the washer or dryer. With the increased popularity of front-loading machines, which often have the controls located at the front, more options are available that can meet the general reach range requirements without the need to reach over an obstruction. Many of these front-loading machines provide a larger capacity and reduce water usage but may be initially more expensive than the traditional top-loading washer and matching dryer would be. Several additional revisions were made in Section 611 to address the front-loading laundry equipment.

The change from “object” to “element” replaces an undefined term with a term that is defined within the standard. This change should not create any change in application.  It is simply a clarification made for consistency with other parts of the standard. The addition of the phrase “complying with Section 305” was an editorial addition made for consistency and for providing users a link to the requirements that are applicable to that element.

Conclusion

The 2010 Standard and the A117.1 sometimes differ because of style, approach and methods of enforcement.  For example, 2010 Standard, Section 308.3, Exception 1 is dealt with within the text in ICC A117.1, Section 308.3.1.  So, possible code change proposals for fuel dispensers to match the second exceptions in the 2010 Standard for Sections 308.3.1 and 308.3.2 could be submitted to IBC Section 1109.14

2012 IBC

1109.14 Fuel-dispensing systems. Fuel-dispensing systems shall be accessible.

To access code change forms on the ICC website, click here. Deadline for submissions is January 3, 2012.  ICC code development staff is always available to assist you through the process.

 

As always, your articles ideas and submissions are welcome. Send them to foliver@iccsafe.org along with a daytime phone number at which to contact you with questions.