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Title II Technical Assistance Manual

Note: This technical assistance document is based on the 1991 ADA Regulations and Standards.  It has not been revised by the Department of Justice as of 2023 to reflect the changes in the 2010 ADA rules.

II-6.3200 Elements.

II-6.3200 Elements. The following requirements apply in new construction, unless otherwise indicated.

1) Van parking.

1) Van parking

ADAAG: One in every eight accessible spaces must be wide enough and high enough for a van lift to be deployed. The space must be marked as "van accessible" with a supplementary sign. Alternatively, "universal parking" is permitted, in which all spaces can accommodate van widths (§4.1.2(5)(b)). UFAS: Van parking is not required. Universal parking is not addressed.

2) Valet parking

ADAAG: Facilities with valet parking must have an accessible passenger loading zone on an accessible route to the exterior of the facility (§4.1.2(5)(e)).

UFAS: No requirements for valet parking.

3) Signs

ADAAG:

* Signs designating permanent rooms and spaces (men's and women's rooms; room numbers; exit signs) must have raised and Brailled letters; must comply with finish and contrast standards; and must be mounted at a certain height and location (§4.1.3(16)(a)).

* Signs that provide direction to or information about functional spaces of a building (e.g. "cafeteria this way;" "copy room") need not comply with requirements for raised and Brailled letters, but they must comply with requirements for character proportion, finish, and contrast. If suspended or projected overhead, they must also comply with character height requirements (§4.1.3(16)(b)).

* Building directories and other signs providing temporary information (such as current occupant's name) do not have to comply with any ADAAG requirements (§4.1.3(16)).

* Has requirements not only for the standard international symbol of accessibility, but also for symbols of accessibility identifying volume control telephones, text telephones, and assistive listening systems (§§4.1.2(7); 4.30.7).

UFAS:

* Signs designating permanent rooms and spaces must be raised (Braille is not required) and must be mounted at a certain height and location (§4.1.2(15)).

* All other signs (including temporary signs) must comply with requirements for letter proportion and color contrast, but not with requirements for raised letters or mounting height (§4.1.2(15)).

* Requires only the standard international symbol of accessibility (§4.30.5).

4) Entrances

ADAAG: At least 50 percent of all public entrances must be accessible with certain qualifications. In addition, there must be accessible entrances to enclosed parking, pedestrian tunnels, and elevated walkways (§4.1.3(8)).

UFAS: At least one principal entrance at each grade floor level must be accessible. In addition, there must be an accessible entrance to transportation facilities, passenger loading zones, accessible parking, taxis, streets, sidewalks, and interior accessible areas, if the building has entrances that normally serve those functions (§4.1.2(8)) . (This latter requirement could result in all entrances having to be accessible in many cases.)

5) Areas of rescue assistance or places of refuge ADAAG: Areas of rescue assistance (safe areas in which to await help in an emergency) are generally required on each floor, other than the ground floor, of a multistory building. An accessible egress route or an area of rescue assistance is required for each exit required by the local fire code. Specific requirements are provided for such features as location, size, stairway width, and two-way communications. Areas of rescue assistance are not required in buildings with supervised automatic sprinkler systems, nor are they required in alterations (§4.1.3(9)).

UFAS: Accessible routes must serve as a means of egress or connect to an accessible "place of refuge." No specific requirements for places of refuge are included. Rather, UFAS refers to local administrative authority for specific provisions on location, size, etc. UFAS requires more than one means of accessible egress when more than one exit is required (§4.3.10).

6) Water fountains

ADAAG: Where there is more than one fountain on a floor, 50% must be accessible to persons using wheelchairs. If there is only one drinking fountain on a floor, it must be accessible both to individuals who use wheelchairs and to individuals who have trouble bending or stooping (for example, a "hi-lo fountain" or fountain and water cooler may be used) (§4.1.3(10)). UFAS: Approximately 50% on each floor must be accessible. If there is only one fountain on a floor, it must be accessible to individuals who use wheelchairs (§4.1.3(9)).

7) Storage and shelves

ADAAG: One of each type of fixed storage facility must be accessible. Self-service shelves and displays must be on an accessible route but need not comply with reach-range requirements (§4.1.3(12)).

UFAS: Has the same requirements as ADAAG for fixed storage, but does not contain the reach requirement exemption for self-service shelves and displays (§4.1.2(11)).

8) Volume controls

ADAAG: All accessible public phones must be equipped with volume controls. In addition, 25%, but never less than one, of all other public phones must have volume controls (§4.1.3(17)(b)).

UFAS: At least one accessible telephone must have a volume control (§4.1.2(16)(b)).

9) Telecommunication Devices for the Deaf (TDD's)

ADAAG: One TDD (also known as a "text telephone") must be provided inside any building that has at least one interior pay phone and four or more public pay telephones, counting both interior and exterior phones. In addition, one TDD or text telephone (per facility) must be provided whenever there is an interior public pay phone in a stadium or arena; convention center; hotel with a convention center; covered shopping mall; or hospital emergency, recovery, or waiting room (§4.1.3(17)(c)).

UFAS: No requirement for TDD's.

10) Assembly areas

ADAAG:

* Wheelchair seating: Requirements triggered in any assembly area with fixed seating that seats four or more people. The number of wheelchair locations required depends upon the size of the assembly area. When the area has over 300 seats, there are requirements for dispersal of wheelchair seating. ADAAG also contains requirements for aisle seats without armrests (or with removable armrests) and fixed seating for companions located adjacent to each wheelchair seating area (§4.1.3(19)(a)).

* Assistive listening systems: Certain fixed seating assembly areas that accommodate 50 or more people or have audio-amplification systems must have permanently installed assistive listening systems. Other assembly areas must have permanent systems or an adequate number of electrical outlets or other wiring to support a portable system. A special sign indicating the availability of the system is required. The minimum number of receivers must be equal to four percent of the total number of seats, but never less than two (§4.1.3(19)(b)). UFAS:

* Wheelchair seating: No requirements for wheelchair seating are triggered, unless the assembly area has 50 or more seats. Seating must be dispersed and provide comparable lines of sight (§4.1.2(18)(a)).

* Assistive listening systems: Assembly areas with audio-amplification systems must have a listening system that serves a reasonable number of people, but at least two. If it has no amplification system or is used primarily as meeting or conference room, it must have a permanent or portable system. No special signs are required (§4.1.2(18)(b)).

11) Automated teller machines (ATM's)

ADAAG: Where ATM's are provided, each must be accessible, except that only one need comply when two or more ATM's are at the same location. Accessible machines must have, among other features, accessible controls and instructions and other information accessible to persons with sight impairments (§4.1.3(20)).

UFAS: No requirements for ATM's.

12) Bathrooms

ADAAG: Every public and common use bathroom must be accessible. Generally only one stall must be accessible (standard five-by-five feet). When there are six or more stalls, there must be one accessible stall and one stall that is three feet wide (§§4.1.3(11); 4.22.4).

UFAS: Same general requirements but no requirement for an additional three-foot-wide stall (§§4.1.2(10); 4.22.4).

13) Detectable warnings

ADAAG: Required on curb ramps, hazardous vehicular areas, and reflecting pools, but not on doors to hazardous areas. The warnings must be truncated domes (§4.29).

UFAS: "Tactile warnings" (uses different terminology) required only on doors to hazardous areas. Must be a textured surface on the door handle or hardware (§4.29).

14) Carpet and carpet tile

ADAAG: Same standards for carpet and carpet tile: maximum pile height of 1/2" (§4.5.3).

UFAS: Carpet must have maximum pile height of 1/2". Carpet tile must have maximum combined thickness of pile, cushion, and backing height of 1/2" (§4.5.3).

15) Curb ramps

ADAAG: Curb ramps must have detectable warnings (which must be raised truncated domes) (§4.7.7).

UFAS: No requirement for detectable warnings on curb ramps.

16) Elevator hoistway floor designations and car controls

ADAAG: Must have raised and brailled characters (§§4.10.5; 4.10.12).

UFAS: Must have raised characters; no requirement for Braille (§§4.10.5; 4.10.12).

17) Visual alarms

ADAAG: Contains details about features required on visual alarms for individuals with hearing impairments, including type of lamp, color, intensity, and location. Flash rate must be at a minimum of 1Hz and maximum of 3Hz (§4.28.3).

UFAS: Contains much less detail. Allows faster flash rate of up to 5Hz (§4.28.3).

18) Elevators and platform lifts in new construction and alterations

ADAAG: The elevator exemption for two-story places of public accommodation or commercial facilities does not apply to buildings and facilities subject to title II. Therefore, elevators are required in all new multilevel buildings or facilities, but vertical access to elevator pits, elevator penthouses, mechanical rooms, and piping or equipment catwalks is not required. Platform lifts may be used instead of elevators under certain conditions in new construction and may always be used in alterations (§4.1.3(5)). Individuals must be able to enter unassisted, operate, and exit the lift without assistance (4.11.3).

UFAS: Has same general requirement for elevators and exceptions similar to those in ADAAG. Platform lifts may be substituted for elevators in new construction or alterations "if no other alternative is feasible" (§4.1.2(5)). Lifts must facilitate unassisted entry and exit (but not "operation" of the lift as in ADAAG) (§4.11.3).

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