36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)
Chapter 5: General Site and Building Elements
Chapter 5 provides technical criteria for parking spaces (502), passenger loading zones (503), stairways (504), and handrails (505).
502 Parking Spaces
Section 502 addresses car parking spaces and van parking spaces. Substantive changes pertain to the:
In the final rule, the Board has clarified how parking spaces and access aisles are to be measured.
Where parking spaces are marked with lines, the width of parking spaces and access aisles is to be measured from the centerline of the markings (502.1). However, at spaces or access aisles not adjacent to another parking space or access aisle, width measurements are permitted to include the full width of the line defining the parking space or access aisle (502.1, Exception).
Comment. The proposed rule specified that car and van spaces be at least 8 feet wide and that access aisles be at least 5 feet wide for car spaces and at least 8 feet wide for van spaces. These specifications are consistent with the original ADAAG. However, that document also recognized an alternative "universal" design under which all spaces are designed to be accessible for vans or cars by incorporating additional space in the parking space instead of the access aisle. Under this design,parking spaces are at least 11 feet wide and access aisles at least 5 feet wide. Commenters requested that this design be recognized in final rule, at least for the portion of spaces required to be van accessible. Comments pointed out certain benefits of the alternative design, such as access aisles that are less likely to be mistaken for another parking space.
Response. The final rule includes specifications for alternative van parking spaces based on the "universal" design specifications (502.2). Van spaces are required to be at least 11 feet wide and to have an access aisle at least 5 feet wide. An exception allows van spaces to be 8 feet wide where the access aisle is at least 8 feet wide, which is consistent with the specifications of the proposed rule and the original ADAAG.
Comment. Requirements for access aisles in section 502.3 address width, length, marking, and location. Two spaces are permitted to share an access aisle. The proposed rule, consistent with the original ADAAG, allowed access aisles to be provided on either side of the parking space. Many commenters urged the Board to revisit this issue, particularly with respect to van parking. The lift provided on vans is typically located on the passenger side. It is important, especially where front-in only parking is provided, that the access aisle be located on the passenger side of van spaces.
Response. The Board has included a requirement that where angled spaces are provided, the access aisle must be located on the passenger side of van spaces (502.3.4). Otherwise, this provision permits access aisles to be located on either side of the space since drivers can pull in or back into spaces as needed.
To harmonize the guidelines with the ANSI A117.1‒2003 standard, the Board has added clarification that access aisles are not permitted to overlap vehicular ways (502.3.4).
Comment. The proposed rule removed a requirement that the access designation for van parking include the term "van accessible" to clarify that both car and van drivers can use such spaces, as was the original intent of ADAAG. Many commenters strongly opposed this change. While some may have misinterpreted it as removal of the requirement for van accessible spaces, others considered this designation important in encouraging car drivers to use other accessible spaces over those designed to accommodate vans.
Response. The Board has restored the requirement that the designation of van spaces include the term "van accessible" (502.6). This designation is not intended to restrict the use of spaces to vans only, but instead to identify those spaces better suited for vans. An advisory note to this effect is included in the final rule.
Comment. The proposed rule removed language in the original ADAAG that vehicles parked in accessible spaces not reduce the clear width of connecting accessible routes. The Board had considered this requirement redundant in view of specifications for accessible routes in section 402. Many commenters disagreed and urged that such a requirement be restored in the final rule. Some comments pointed out that the ANSI A1171.1 standard, like the original ADAAG, specifies that "parked vehicle overhangs shall not reduce the clear width of an accessible route."
Response. The Board has added a requirement that spaces and access aisles be designed so that parked vehicles "cannot obstruct the required clear width of adjacent accessible routes" (502.7). A typical design solution where accessible routes run in front of spaces is the provision of wheel stops that help prevent encroachment into the accessible route.
503 Passenger Loading Zones
Few comments addressed the technical requirements for passenger loading zones, and no substantive changes to them have been made. For consistency with the ANSI A117.1 standard, the Board has clarified in the final rule that access aisles required at passenger loading zones are not permitted to overlap vehicular ways (503.3).
504 Stairways
Section 504 covers stairways, including treads, risers, nosings, and handrails. This section requires that landings subject to wet conditions be designed to prevent the accumulation of water (504.7). In the final rule, the Board has revised this requirement to apply to stair treads, as well as landings. No other substantive changes have been made to this section.
505 Handrails
Specifications for handrails in section 505 apply to those provided at ramps, stairs, and along walking surfaces. Revisions made to this section concern:
Handrails are required along both sides of ramps and stairs. The Board has included a requirement (403.6) that handrails, where provided along walking surfaces, comply with section 505, as discussed above. The term "walking surfaces" applies to portions of accessible routes that are not treated as ramps because the running slope is less than 1:20. Consistent with this change, provisions in section 505 have been modified to specifically reference walking surfaces, including the general charging statement at 505.1. Walking surfaces are not subject to requirements for handrails on both sides (505.2) or handrail extensions (505.10).
In the final rule, an exemption from the requirements for stairways, including handrails, has been included for aisle stairs in assembly areas (210.1, Exception 3). An exception from the requirement for handrails on both sides for aisle ramps and aisle stairs has been revised for consistency. Specifically, the reference to aisle stairs in this exception has been removed as redundant.
Specifications for ramps require handrails only at ramps with a rise greater than 6 inches (405.8). Curb ramps are not subject to handrail requirements. The Board has removed as redundant an exception in the handrail section for ramps with a rise of 6 inches maximum (505.2, Exception 2).
The guidelines require handrails to be continuous within the full length of stair flights and ramp runs (505.3). The Board has added clarification, consistent with the original ADAAG, that the inside handrail at switchback or dogleg stairs and ramps be continuous. This change was made for consistency with the ANSI A117.1 standard.
Comment. The proposed rule specified that gripping surfaces be continuous and unobstructed by elements, including newel posts (505.6). An exception permitted brackets and balusters attached to the bottom of a handrail provided they did not obstruct more than 20% of the handrail length, their horizontal projection was at least 2 ½ inches from the bottom of the handrail, and their edges had a radius of at least c inch. Comments from the handrail industry, including manufacturers, trade associations, and others, indicated that these stipulations would effectively prohibit many common fabrication methods and would be unduly costly and burdensome on the industry while promising limited access benefits. Specifically, these comments indicated that many materials currently used will not meet the minimum c inch radius specifications. In addition, commenters claimed many current mounting brackets do not meet the 2 ½ inch minimum requirement for horizontal projections below the handrail, which is inconsistent with the 1 ½ inch minimum specified by model building codes. They also would preclude use of panels below handrails, which have become popular in meeting code requirements that prohibit openings in railings through which a 4 inch sphere can pass. Manufacturers stated that they have not received complaints about sharp edges and that some railing cross sections have been used for many years without injury. Opposing comments referred to ergonomic studies which support a 2 ¼ inch clearance below the handrail.
Response. The Board has revised some of the specifications for gripping surfaces in section 505.6 in order to accommodate a wider range of handrail materials and designs. The revised provisions prohibit obstructions on the top and sides of handrails, while the bottom may be obstructed up to 20% of the handrail length. This is generally consistent with the proposed rule. The Board believes that such a requirement will still permit popular designs such as panels under handrails so long as they are not directly connected to the entire length of the bottom of the handrail gripping surface. The requirement that horizontal projections occur 2 ½ inches minimum below the bottom of gripping surfaces has been changed to 1 ½ inches, consistent with model building codes and industry practice. In addition, the Board has added an exception for handrails along walking surfaces that permits obstructions along the entire bottom length that are integral to crash rails and bumper guards (505.6, Exception 1). Another exception, consistent with the ANSI A117.1‒2003 standard and recommended by a comment to the draft of the final guidelines, allows the distance between horizontal projections and the gripping surface bottom to be reduced by c inch for each ½ inch of additional handrail perimeter dimension exceeding 4 inches (505.6, Exception 2). A requirement that bracket or baluster edges have a radius of c inch minimum has been removed. A similar specification for handrail surface edges in section 505.8 has been replaced with a requirement for "rounded edges."
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