36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

403 Walking Surfaces

Requirements in 403 for walking surfaces apply to portions of accessible routes existing between doors and doorways, ramps, elevators, or lifts. The requirements for walking surfaces derive from existing specifications for accessible routes covering floor or ground surfaces, slope, changes in level, and clearances. Revisions made to this section include:

• adding an exception for circulation paths in employee work areas (403.5, Exception)

• removing redundant specifications for protruding objects (403.5.3 in the proposed rule)

• addressing handrails provided along walking surfaces (403.6)

The final rule requires that common use circulation paths within work areas satisfy requirements for accessible routes (203.9). This provision does not require full accessibility within the work area or to every individual work station, but does require that a framework of common use circulation pathways within the work area as a whole be accessible. These circulation paths must be accessible according to requirements for accessible routes and walking surfaces. Section 403.5 includes requirements for the clear width of walking surfaces. The Board has included an exception to section 403.5 which recognizes constraints posed by various types of equipment on the width of circulation paths. Under this exception, the specified clearance for common use circulation paths within employee work areas can be reduced by equipment where such a reduction is essential to the function of the work being performed.

The proposed rule included a requirement that protruding objects not reduce the required clear width of walking surfaces (403.5.3). The Board has removed this requirement as redundant. Section 307, which addresses protruding objects, specifies that such objects not reduce the clear width of accessible routes (307.5).

Comment. Requirements for handrails in the proposed rule applied only to those provided along ramps and stairs. The handrail requirements in section 505 address specifications for continuity, height, clearance, gripping surface, cross section, fittings, and extensions. The Board sought comment on whether these requirements should also be applied to handrails that are provided along portions of circulation paths without ramps or stairs (Question 20). The few comments that addressed this question supported the inclusion of such a requirement.

Response. In the final rule, the Board has included a requirement at section 403.6 that handrails, where provided along walking surfaces not treated as a ramp (i.e., those with running slopes no steeper than 1:20), meet the technical criteria in section 505. The Board has included provisions in section 505 that exempt walking surfaces from requirements for handrails on both sides and from requirements for handrail extensions.

Comment. Section 403.5 specifies a continuous clearance of 36 inches minimum for walking surfaces. Wider clearances are specified for wheelchair passing space (60 inches minimum) and certain sharp turns around narrow obstructions. Several comments urged an increase in the specified clearances for walking surfaces, such as a 48 inch minimum for exterior routes, and an increase in wheelchair passing space to 66 inches.

Response. No revisions have been made to the specified clearance of walking surfaces. The minimum width of exterior routes on public streets and sidewalks will likely be revisited in supplementary guidelines specific to public rights-of-ways that the Board intends to develop. These supplementary guidelines will be proposed for public comment.