2019 California Standards for Accessible Design Guide (effective January 1, 2020 with July 1, 2021 amendments)
PATH OF TRAVEL.
[DSA-AC] An identifiable accessible route within an existing site, building or facility by means of which a particular area may be approached, entered and exited, and which connects a particular area with an exterior approach (including sidewalks, streets, and parking areas), an entrance to the facility, and other parts of the facility. When alterations, structural repairs or additions are made to existing buildings or facilities, the term “path of travel” also includes the toilet and bathing facilities, telephones, drinking fountains and signs serving the area of work.
[ADA Title II §35.151(b)(4)(ii)] A “path of travel” includes a continuous, unobstructed way of pedestrian passage by means of which the altered area may be approached, entered, and exited, and which connects the altered area with an exterior approach (including sidewalks, streets, and parking areas), an entrance to the facility, and other parts of the facility.
(A) An accessible path of travel may consist of walks and sidewalks, curb ramps and other interior or exterior pedestrian ramps; clear floor paths through lobbies, corridors, rooms, and other improved areas; parking access aisles; elevators and lifts; or a combination of these elements.
(B) For the purposes of this section, the term “path of travel” also includes the restrooms, telephones, and drinking fountains serving the altered area.
[ADA Title III §36.403(e)] Path of travel.
1) A "path of travel" includes a continuous, unobstructed way of pedestrian passage by means of which the altered area may be approached, entered, and exited, and which connects the altered area with an exterior approach (including sidewalks, streets, and parking areas), an entrance to the facility, and other parts of the facility.
2) An accessible path of travel may consist of walks and sidewalks, curb ramps and other interior or exterior pedestrian ramps; clear floor paths through lobbies, corridors, rooms, and other improved areas; parking access aisles; elevators and lifts; or a combination of these elements.
3) For the purposes of this part, the term "path of travel" also includes the restrooms, telephones, and drinking fountains serving the altered area.
ETA Editor's Note
CBC Chapter 11B does not apply the same qualification as ADA for imposing the responsibility to make the path of travel to an addition or alteration accessible, implying that existing barriers to accessibility must be mitigated, subject to codified hardship and/or safe harbor limitations. ADA imposes the responsibility when an alteration or addition to a public accommodation or commercial facility includes or affects an area containing a primary function. Lacking this qualification, the CBC Chapter 11B scoping is more inclusive. However, the CBC scoping is interpreted and enforced by Local Building Officials and other Authorities Having Jurisdiction, whereas the ADA scoping is not. Therefore, in cases where the CBC scoping for mitigation of existing path of travel barriers as part of a building alteration or addition is not enforced, or is enforced to a lesser degree than the ADA obligation would require, the ADA obligation remains in effect, if the alteration or addition meets the ADA primary function qualification.
It is also important to note that ADA Title III imposes a perpetual obligation for public accommodations to mitigate existing barriers to the extent readily achievable, not merely limited to those on an accessible path of travel, and not tied to other alterations or additions.
In order to mitigate existing barriers, it is first necessary to identify them. The subject of who is responsible for doing this is not addressed directly by CBC or ADA, and it is perhaps the most common failing for public accommodations. Design professionals frequently note "Existing Accessible Parking," "Existing Accessible Toilets," and similar, which Authorities Having Jurisdiction take to imply that they are compliant. The failure to mitigate existing barriers that are overlooked by this practice can be, and frequently is, an ADA violation. It is also inconsistent with the intent of CBC Chapter 11B.
The ADA path of travel requirements are included in this Guide following those of CBC Section 11B-202.4.
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