36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)
Chapter 3: Building Blocks
Chapter 3 contains basic technical requirements that form the "building blocks" of accessibility as established by the guidelines. These requirements address floor and ground surfaces (302), changes in level (303), wheelchair turning space (304), clear floor or ground space (305), knee and toe clearance (306), protruding objects (307), reach ranges (308), and operable parts (309). They are referenced by scoping provisions in Chapter 2 and by requirements in subsequent technical chapters (4 through 10).
Most comments addressed requirements for reach ranges and operable parts. Substantive revisions made in the final rule include:
lowering the maximum height for side reaches from 54 to 48 inches (308.3.1)
adding an exception from requirements for obstructed side reaches to accommodate the standard height of laundry equipment (308.3.2, Exception 1)
Section 302 requires floor or ground surfaces to be stable, firm, and slip resistant and provides specifications for carpets and surface openings.
Comment. Slip-resistance is based on the frictional force necessary to keep a shoe heel or crutch tip from slipping on a walking surface under conditions likely to be found on the surface. The Board was urged to reference specifications and testing protocols for slip resistance, in particular those developed by Voices of Safety International.
Response. Historically, the Board has not specified a particular level of slip resistance since it can be measured in different ways. The assessed level (or static coefficient of friction) varies according to the measuring method used. It is the Board’s understanding that various industries each employ different testing methods and that there is no universally adopted or specified test protocol. The final rule does not include any technical specifications or testing methods for slip resistance as recommended by comments. The Board has chosen not to reference specifications that have not been vetted by the model codes community or developed through established industry procedures governing the adoption of consensus standards and specified test methods. The final rule includes exceptions developed in a separate rule making on recreation facilities that exempts animal containment areas and areas of sports activity from the requirements for floor or ground surfaces.
Section 303 addresses vertical changes in level in floor or ground surfaces. No changes have been made to this section. Exceptions for animal containment areas and areas of sports activity established in rulemaking on recreation facilities are included in the final rule.
Minimum spatial requirements are specified for wheelchair turning space. This section permits either a 60 inch diameter circle or a T-shaped design. Objects that provide sufficient knee and toe clearance can overlap a limited portion of the turning space.
Comment. Comments urged that the minimum dimensions for turning space be increased to better accommodate scooters and motorized wheelchairs. Recommendations ranged from 64 to 68 inches for the diameter of circular space and the overall dimensions of the T-shaped space. The overlap of this space by other elements should be prohibited or further restricted according to some of these comments because knee and toe clearances do not accommodate the front tiller of scooters.
Response. The lack of consensus on the dimensions for larger turning space and the absence of supporting data points to the need for research on the spatial turning requirements for scooters and other powered mobility aids. The Board believes that such research is needed before any changes to the long-standing criteria for turning space are made. The Board is sponsoring a long-term research project on scooters and other powered mobility aids through the Rehabilitation Engineering Research Center on Universal Design.
Section 305 provides requirements for the basic space allocation for an occupied wheelchair. Few comments addressed this section, and no substantive changes have been made.
Section 306 defines the minimum clearances for knees and toes beneath fixed objects. Few comments addressing this section were received. The only changes made to this section are editorial in nature for purposes of clarity.
Objects mounted on walls and posts can be hazardous to persons with vision impairments unless treated according to the specifications in section 307 for protruding objects. Objects mounted on walls above the standard sweep of canes (i.e., higher than 27 inches from the floor) and below the standard head room clearance (80 inches), are limited to a 4 inch depth. Objects mounted on posts within this range are limited to a 12 inch overhang.
Comment. Several commenters called for the 27 inch triggering height to be reduced. Recommendations ranged from 15 to 6 inches. Comments also recommended that post-mounted objects be held to the requirements for wall-mounted objects.
Response. Post-mounted objects are common along sidewalks, street crossings, and other public rights-of-way. The Board intends to develop guidelines specific to public rights-of-way in a separate rule making. This other rulemaking will address and invite comment on protruding objects in public rights-of-way. With respect to the mounting height above which requirements for protruding objects apply (27 inches), the Board believes research is needed to further assess this specification. No substantive changes have been made to the provisions for protruding objects in the final rule.
Accessible reach ranges are specified according to the approach (forward or side) and the depth of reach over any obstruction. The proposed rule, consistent with the original ADAAG, specified maximum heights of 48 inches for a forward reach and 54 inches for a side reach. In the final rule, the maximum side reach has been lowered to the height specified for forward reaches. Exceptions to this requirement and a related provision for reaches over obstructions have been added for gas pumps, laundry equipment, and elevators.
The ADAAG Review Advisory Committee’s report, upon which the proposed rule was largely based, recommended that the side reach range, including obstructed reaches, be changed to those required for forward reaches. This recommendation was based on a report from the Little People of America which considered the 54 inch height beyond the reach for many people of short stature. The advisory committee also considered the 48 inch maximum for side reaches as preferable for people who use wheelchairs. The Board proposed retaining the 54 inch side reach maximum pending further information on the need for, and impact of, such a change in view of its application to a wide and varied range of controls and elements. However, the Board acknowledged that the ANSI A117.1‒1998 standard included such a change, which would mitigate the impact of similar action by the Board in view of new codes based on the ANSI A117.1 standard.
Comment. Several hundred comments, almost a fifth of the total received in this rule making, addressed the merits of lowering the side reach maximum. The vast majority urged lowering the side reach, consistent with the advisory committee’s recommendation. Most of these comments were submitted by persons of short stature and disability groups. These commenters, as well as the ANSI A117 Committee and the Little People of America, stated that the unobstructed high reach range requirement should be lowered to 48 inches to help meet the needs of people of short stature, people with little upper arm strength and movement, and people with other disabilities. This change would enhance consistency between the guidelines and other codes and standards. Comments called attention to difficulties people encounter accessing ATMs, vending machines, and gas pumps. Various trade and industry groups opposed lowering the side reach range due to concerns about the impact and cost on various types of equipment, including those highlighted by other comments as difficult to reach. In particular, gas pump manufacturers outlined the difficulties in designing a fuel dispenser that would meet the 48 inch requirement. Gas pumps are often located on curbs at least 6 inches high for safety reasons. In addition, safety and health regulations require distance between the electronics of the pump and the dispenser. Comments from the elevator industry noted that a 48 inch maximum height would adversely impact the design of elevator controls.
The Board held a public meeting in October, 2000 to collect further information on this issue. Persons of short stature and disability groups reiterated the need for lowering the side reach to 48 inches. ATM manufacturers noted that they could meet the 48 inch maximum height for most new models of ATMs. Gas pump manufacturers demonstrated the difficulties in meeting the 48 inch height requirement in view of their current designs and safety and health design requirements. The gas pump manufacturers impressed upon the Board the great difficulty of installing a redesigned gas pump on an existing curb. They contended that although it would be possible to redesign gas pumps to be 48 inches to the highest operable part, even when installed on a curb, such gas pumps would have non-uniform fittings. They noted that installing them would be costly and could necessitate removing the entire curb.
Response. The maximum side reach height has been lowered from 54 to 48 inches. An exception is provided for the operable parts of fuel dispensers, which are permitted to be 54 inches high maximum where dispensers are installed on existing curbs. This exception responds to industry’s concern regarding costs associated with alterations and will permit the existing stock of gas pumps that are currently within 54 inches to be used. In addition, certain exceptions are provided for elevators in section 407, consistent with the ANSI A117.1 standard.
Comment. Requirements for side reaches over an obstruction in 308.3.2 limit the height of the obstruction to 34 inches maximum. A major manufacturer of laundry equipment indicated that this specification would significantly impact the standard design of clothes washers and dryers, which have a standard work surface height of 36 inches. Complying with a 34 inch maximum height would decrease machine capacity and involve substantial redesign and retooling to develop compliant top loading and front-loading machines.
Response. An exception has been added that permits the top of washing machines and clothes dryers to be 36 inches maximum above the floor.
Specifications for operable parts address clear floor space, height, and operating characteristics. Operable parts are required to be located with the reach ranges specified in 308. In addition, they must be operable with one hand and not require tight grasping, pinching, twisting of the wrist, or more than 5 pounds of force to operate.
Comment. The proposed rule included an exception from the height requirements in 309.3 for special equipment and electrical and communications systems receptacles. This exception’s coverage of various operable parts was considered to be too broad.
Response. This exception has been revised to specifically cover operable parts that are "intended for use only by service or maintenance personnel," "electrical or communication receptacles serving a dedicated use," and "floor electrical receptacles." However, since such equipment may merit exception from other criteria for operable parts besides the height specifications, this exception has been recast as a general exception from section 309 and has been relocated to the scoping requirement for operable parts in Chapter 2 (see section 205.1, exceptions 1, 2, and 4).
Comment. Gas pump manufacturers indicated that the safety requirements for the operation of gas pump nozzles effectively preclude a maximum operating force of 5 pounds.
Response. An exception has been added to 309.4 that permits gas pump nozzles to have an activating force greater than 5 pounds.
Comment. The Board sought comment on whether the maximum 5 pounds of force was appropriate for operating controls activated by a single finger, such as elevator call and control panel buttons, platform lift controls, telephone key pads, function keys for ATMs and fare machines, and controls for emergency communication equipment in areas of refuge, among others. Usability of such controls also may be affected by how far the button or key must be depressed for activation. Specifically, the Board asked whether a maximum 3.5 pounds of force and a maximum 1/10 inch stroke depth provide sufficient accessibility for the use of operable parts activated by a single finger (Question 18) and whether there were any types of operable parts that could not meet, or would be adversely affected by such criteria (Question 19). The few comments received on this issue were evenly divided on the merits of adding these specifications. Comments noted that they would pose problems for fare machines and interactive transaction machines designed to withstand vandalism and misuse, various types of plumbing products, dishwashers and laundry machines, and amusement games and attractions. The elevator industry indicated that the noted specifications would not pose a problem in the design of elevators.
Response. Due to the limited support expressed and the potential impacts raised by commenters, a maximum 3.5 pounds of force and a maximum 1/10 inch stroke depth for operable parts activated by a single finger has not been included in the final rule.
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