Common Errors & Omissions in New Construction and Alterations

Operator

Thank you for standing by for Common Errors in New Construction session. All participants are in the listen only mode. We''ll conduct a question-and-answer session. Instructions will be given then. This conference is being recorded. I would now like to turn the conference over to our host. Go ahead

Jennifer Bowerman

Good afternoon and welcome to Common Errors and Omissions in New Construction and Alterations. This distance learning session is being hosted by the Great Lakes, Mid-Atlantic, Great Plains, Southwest and Pacific Disability and Business Technical Assistance Centers. For those of you that have joined us before, welcome. For those of you who are new to the distance learning session, let me explain today''s format. The first portion of the session is going to be presentation by our guest speaker, and then we will open it up for a question and answer. This session is also being real time captioned on our web site and you can access the Great Lakes chat room through the Web site at www.adagreatlakes.org. In addition, our presenter today is going to be talking about seven cases that you should have received in your packets in advance. If not, you can also download those on the Great Lakes Web site. There is a link right there on the first page to get you to the case studies or examples that we''ll be looking at in a couple minutes. I''d like to remind people that today''s session is very specific to structural access. So we are going to be talking about buildings and facilities. We are excited to have with us today Lois Thibault. She is the Coordinator of Research for the U.S. Access Board. Lois has extensive responsibilities with the Access Board where she coordinates advisory groups and research projects. She provides training to design professionals and technical assistance through the access board, and by profession Lois is an architect. Lois, I would like to turn the session over to you. And first of all, thank you for joining us this afternoon.

Lois Thibault

Thanks, Jennifer and hello to everybody. I''m delighted to have this opportunity to try this approach to online learning, and I''ll be very interested to hear people''s comments at the end. I understand that there has been some concern about the legibility of the drawing, so I will try to give a good deal of detail as we discuss each of them. I wanted to start off with a general introduction to not only the work of the access board, but the focus of this session this afternoon by noting that the guidelines that we write, and writing guidelines is our only business really, cover new construction and alterations in buildings and facilities. We don''t cover those situations with our guidelines that are already covered in either a Department of Justice or department of transportation regulation for existing facilities. Certainly the guidelines are useful as guidance for removing barriers or providing program access in a facility. But they are not referenced as requirements in the same way as they are when you are building a new building, altering one or adding a wing or other addition to a building. So, we are talking mostly here about design and construction issues, and of course we are talking about the ADA Accessibility Guidelines. You will hear me call them ADAAG during the course of this discussion, and I will be referencing various ADAAG paragraphs or provisions as we go through the case studies. Another feature about the work of the Access Board is that because we are dealing with design and construction issues, we also don''t cover things like the operation of a facility, maintaining accessible features, which is again covered by the Justice Department regulation, and sort of a subcategory of that, those issues that might have to do with finishing and furnishing a building. We like to say that our coverage under the ADAAG Accessibility Guidelines is limited to those things that wouldn''t fall out if you turned the building over and shook it a bit like a salt shaker. So we are thinking of fairly fixed elements in a building, not necessarily freestanding tables and chairs, but booths that might be fixed in a restaurant, counters with stools that are fixed to the floor, telephones that are attached to the wall, and not those that are simply furnished as a convenience. In particular, of course, I''ll be talking about those errors and omissions that the Access Board either notices when our staff travels on training or to provide technical assistance and those things that are referred to us for review. You may always send us a plan or a detail, fax it or send it by e-mail. Ask the question, let us know how we can get in touch with you, and our staff will take a look at it. Sometimes we''ll confer and decide on a response, and then give you a buzz and chat about it. So all of these case studies are projects or details from work that has been submitted to us for review, perhaps the architect had a question about a particular issue or felt a little bit uncertain over a specific application. Other places where you might look for common errors and omissions and lists of those are the web site of the U.S. Department of Justice, which has a list of publications that actually includes common errors and omissions under the ADAAG available either on line or as a printed publication. And they are very excellent publication quarterly, I believe, that looks at enforcement issues. One of the very best ways to see where a lot of issues are being raised about difficulties in projects covered by the ADAAG is to look at where there has been either mediation or a court decision in a particular area. Again, this material is available on the Justice Department web site at www.usdoj.gov/crt/ada/adahom1.htm Right now there is a very interesting section on that web site focused on theaters and stadium seating, those raised steeply inclined movie theaters, the multiplexes that we are commonly seeing and which have been the subject of a lot of complaints and some technical assistance from the Justice Department. In order to take a look at these seven case studies with some context, you need to be somewhat familiar with the ADAAG Accessibility Guidelines. I''m going to try and be very careful about referencing specific provisions and assume that not all of you will have copies of the guidelines at your elbow. These case studies were each selected because they show how ADAAG really works and the particular difficulty of working in what is essentially a multi-tasked environment. Most of the errors that we see are those that affect people with mobility impairments and particularly those that affect how they move through space and use elements along a route, whether it is a ramp or a door or a fixture, a drinking fountain, a telephone. Although we can''t ignore things like protruding objects, they are relatively simple to diagnose and are more commonly found, I believe, in the exterior environment on and along sidewalks. By the same token, simple inspection is probably sufficient to reveal communications oversights like the lack of signage identifying where a TTY what might be. But it is assessing the use of a space or area, adding up the effects of a complex of requirements. Door and fixture spaces, the need to transfer from a wheelchair to a shower seat or a toilet fixture. The affects of grab bars, how they relate to work space and other fixtures. How they are used, knee room, turning requirements. Fitting all those things into a small room or space, like a vestibule or a toilet room often result in overlooking one feature or another or one requirement or another. Doing it successfully requires a real understanding of the rationale behind the guidelines, and the recognition that this is a complex environment that must accommodate not just a wheelchair space that''s 30 by 48 at some location, but in fact a sequence of activities approaching opening, entering, transferring, turning or exiting a space. As I noted at the beginning, your primary resource should be the ADAAG accessibility guidelines. So before we start, I wanted to say a few words about important sections of ADAAG that will help you apply its requirements to real built facilities. A couple of provisions at the very beginning in ADAAG before you get into the numbered sequences that start with the 4, deal with something called "equivalent facilitation," which is basically an indication that if you can develop or design an alternative way of providing access that is essentially equivalent to that that is required in the guidelines, that that is certainly acceptable. There is a note about tolerances that says that ADAAG recognizes standard building industry tolerances, and it is this provision that makes it possible to forgive a toilet seat height of say 19 1/4 inches, perhaps, or a dimension from the center line to the wall of slightly over 18-inches or slightly less than 18-inches, since that''s an absolute value. So depending on what trades are involved, say the pouring of concrete is a fairly rough activity which demands a fair degree of tolerance, whereas the finishing of millwork or cabinetry or something like that you can expect a much lesser degree of variance from the dimensions that would be required on a plan. We also have a couple of written resources that might be helpful to you. The Access Board has a technical assistance publication called using ADAAG , which talks a little bit about the way ADAAG is organized into a scoping section which says under what conditions, where, how many of something need to be accessible. And then technical provisions that describe the parameters of that accessibility. The first, scoping, is sort of the obligation. And the second is sort of the recipe of how you get there. One requires accessibility, the other tells you what accessibility consists of in a particular instance, whether it is a telephone or a ramp or some other feature. There is also material in the back of the ADAAG Accessibility Guidelines that is advisory and can be very, very helpful in understanding the rationale behind a provision, how something might be used or just simply providing a little bit more information about installation, operation, and other features of accessibility. Where a provision in ADAAG has appendix information or advisory information, the provision number 4.2, 4.16 will be followed by an asterisk, and you will find that advisory information in the appendix, which are the sections that start with A. So, if there is a note to 4.2, you will find it at A 4.2 in the back. Always begin with the provisions for new construction when you are looking at a feature, a plan, or the physical evidence of a design project. There are several scoping sections in ADAAG . The first being 4.1.2, which provides scoping for site development, the accessible road from the boundary of a project to the entrance, the parking requirements, the relationship between parking spaces that are accessible and accessible entrances and things of that sort. Section 4.1.3 is the new construction scoping for new buildings, and there are provisions for alterations and additions that say first try to apply the new construction criteria, even if you are doing an addition or an alteration. And only when you are unable to satisfy the new construction criteria, because of existing conditions in the building at the site that would constitute technical infeasibility-basically structural or extraordinary site conditions that make it virtually impossible to meet the new construction requirements, then you may default to a lesser set of standard appropriate for alterations. But you must first try-if you are a designer, an architect, an engineer-to incorporate the new construction criteria. We find this very often violated in toilet room design, where it is commonly believed that a smaller sized toilet room described in figure 30 as an alternate is permissible under new construction. And in fact it is not, and it wouldn''t even be permissible in an alteration if it were feasible. It is only when it is not feasible that it is accepted to utilize the lesser standards in the technical provisions under alterations. We have here at the Access Board an ADAAG checklist available. It is a fairly extensive document. It is available free upon request. And, again, it is called an ADAAG checklist. It is basically a tabular version or a chart version of the ADAAG Accessibility Guidelines themselves, and divides the task of analyzing a project or a space into the various types of facilities and elements that it contains, doors, entrances, ramps, stairs and things of that sort. So if you think that would be helpful to you in any of your field work, in reviewing new construction or alterations projects, please call our toll free number which is 1-800-872-2253 and ask for a copy of the ADAAG checklist. Let me move on now to the first of the seven cases that have been posted on the web site. As I said, these are all cases that have arisen out of real projects submitted to the Access Board. (Case 1 www.adagreatlakes.org/training/errors/case1.htm). The first one is a drawing from a design professional who has been asked to add a ramp to an existing swimming pool in order to eliminate a small set of stairs that provides access to the pool area from locker room construction. The ramp is installed here at an angle along an existing wall at its bottom. It is somewhat narrowed by a column, that is the feature with the big X in it at the bottom of the ramp. And at the top, there is a bit of a turn. You come off the upper level platform which used to be the top platform of the stairs, and make a turn to your left about 45 degrees to come down the ramp. There are handrails called for. And in fact, you can see at the top of this drawing where there is an arrow that says down where the stairs have been partially retained as sort of a companion to the new ramp. There are a couple of issues raised by this ramp. The first one, the architect gives us the information that the total rise of these two stairs is 13 inches, and the architect has indicated that the run of the stair will be 13 feet then, which of course gives us a ramp slope of 1:12, which is the maximum permitted. But if you actually look at 4.8.4 in ADAAG , which is the section on ramps, you will see that it requires, under ramp slope and rise, the least possible slope. This means that if you''ve got the space, you need to make a ramp of a somewhat lesser slope. In this situation, it appears that the designer could have made a longer ramp. In fact, it would have been beneficial to do so for a number of reasons. I''ll outline those in a minute. But I wanted to also address landings, which are essential to the adequate functioning of a ramp. Landings are required to be the same width or greater at the ramp run itself, and you must have a ramp at the top and the bottom. You must have a landing at the top and the bottom of every ramp. If you have a long ramp, you will also require intermediate landings. Any time you have a turn in a ramp, you will need to have a level landing. This, by the way, is the reason that helical and curved ramps cannot comply with ADAAG , because they don''t provide those level areas or control of cross slopes. Let''s look at the ramp at the landing at the top of this proposed ramp and notice where the designer has labeled platform. He''s got a small area that communicates with the level area at the top and indicates that it is 60 inches wide, which is certainly more than is required. But the feature that I notice and that makes me wonder whether this in fact is a usable ramp is the other direction of the ramp. Certainly 60 inches is available in the direction of the stairs going down at the top. But at the bottom it is not. And if you imagine approaching along this corridor to the top and then turning on this ramp, notice how it is rather channelized there. There is a partition or a handrail or something like that. In fact, you don''t have the 60 inches of run that you need at the top of the ramp along that level landing. This is less of a problem going down than it would be if you were coming up the ramp, where you want to be able to ascend over the crest of the ramp to the level area before you have to turn so that all four of your scooter or wheelchair wheels will be on level ground at the same time. You wouldn''t be able to do that with this ramp. Additionally, I''m concerned that there is nothing shown in terms of handrail extensions, which certainly would be feasible here. And I think that a building official might have a little bit of concern about the column that intervenes there. My suggestion for fixing this doesn''t really require any more space. I would leave the ramp in essentially the same area, but would fill in that space between the ramp and the wall that contains the column. I would move the ramp down a little bit so that we had some extra length, making sure that there is 60 inches at if bottom for a level landing. And then I would run the landing at the top a little bit farther out so that you have a minimum of 60 inches on the top and the bottom at that 45-degree angle. Then when you are approaching or leaving the ramp, all four of your wheels can roll over that change in elevation at one time. (Case 2 www.adagreatlakes.org/training/errors/case2.htm) the second case study that I wanted to address is case 2, which shows the vestibule at the entrance to a new building. The architect has designed a clear floor space of 30 by 48 inches in the corner of this vestibule as a demonstration that there is sufficient clear floor space for a wheelchair in this space, and that that clear floor space will be free of the swing of either door 1 or door 2. Door 1 opening out to the exterior of the building, door 2 opening into the vestibule itself. The question that I had posed when this was posted on the web site was, are the maneuvering clearances at the doors adequate? Well, they may be. You will notice that there are two Ss, which is the electrical symbol or switch, at the openings to these doorways. If those represent power operating switches to enter and leave this space, this may well be a satisfactory arrangement. Absent those, of course, imagining that you were trying to pull up to door 1 which would be closed, let''s say, and reach the hardware from a wheelchair and pull it open, you would see that this is one of those famous wheelchair traps where you get into something and you can''t actually operate it. This requires you to grab hold of a door hardware and back up at the same time as you are holding it up, a maneuver that is extremely difficult and not really permitted by the ADAAG Accessibility Guidelines. You have of course the second situation. The same situation on door 2, on the approach or pull side. In addition, I think that showing this clear floor space here tucked in this little niche between the column and the wall shows the difficulty of simply applying a requirement and understanding where it comes from. There is in fact no way that a wheelchair could maneuver into that position in the niche. You could pick one up and put it down in that place, but it is highly unlikely that an average standard wheelchair would be able to nudge itself over into that little niche so as to be out of the swing of door 2. So for that reason, I don''t find this a satisfactory arrangement. A little bit more space would make it usable. I think there is the added question here of whether in fact this vestibule falls under the coverage of a niche or a recess. If you look at Figure 4 in ADAAG , you will see that where you have space that is constrained on three sides, you are expected to add 6 inches of maneuvering space in width to the standard wheelchair clear floor space and 12 inches in length to provide for maneuverability. That provision is at ADAAG 4.2.4.2. (Case 3 www.adagreatlakes.org/training/errors/case3.htm) The next figure, Case 3, shows a reception counter in a new suite of offices. The architect has proposed to build the counter at 48 inches high. This is a bowed out counter. It has a double height section. The outer height, which is the public side, is a fairly narrow 48 inch high surface. And then within the reception space, where the work surfaces are, it is at a lesser height, 36 inches, for seated use by a receptionist. Now, the first thing that strikes us, I think about this is not necessarily what ADAAG itself requires in this instance, but what the Justice Department''s implementing regulations generally require of any design in construction. And that is that the accessible features be integrated into those features that are provided, generally for everyone. Just on that count alone, this approach I think really fails. Not only is this alternate access that they proposed around the corner, but it appears to be through a doorway where it probably isn''t even obvious. These dark areas on either end are partitions. The ones that are colored in. And even assuming that, say in an alteration this might be a reasonable approach or in program access in an existing facility, you would certainly have to have some sort of signage which makes it even less integrated, I think, as a solution to access. Now, what apply here in terms of a counter height, we generally refer people to section 7.2 in ADAAG , which is where general office space mercantile and other facilities are described. And it has two paragraphs on counter height. One has to do with counters where cash registers are installed. And clearly it is unlikely that a reception area would have a cash register. And the other talks about places where goods and services would be disbursed. There is also counter requirements for kitchenettes, cafeterias and food service lines in section 5. But page 553 in the ADAAG accessibility guidelines, which is where you would find section 7.2, gives you these two choices for how you would design and construct accessible counters. If it were a counter that had a cash register, at least 36 inches of that counter length would have to be on an accessible route and installed or constructed at a maximum height of 36 inches. Under paragraph 2, which seems to more nearly parallel the situation we are talking about here, it says at ticketing counters, teller stations, registration counters in hotels, very similar use. Other counters that may not have a cash register but where goods and services are sold or distributed, it gives you the option of a portion of the counter at 36 inches, just as if it were a cash register counter. An auxiliary counter at 36 inches, which I think is what the architect was suggesting here, but it does say in close proximity or equivalent facilitation, which is in this case kind of a catch all phrase that suggests either a folding shelf, use of the space at the side of the counter or some other effective means of providing access. Had this counter been open on the side to the front section and not partitioned off as it is shown to be, this might have been a complying installation.

Jennifer Bowerman

Lois, we are coming up on some time constraints

Lois Thibault

Let''s do Case 5 (www.adagreatlakes.org/training/errors/case5.htm ). And let me describe it a bit, because it may be a little less clear than some of the others. This shows a small toilet room with a water closet and grab bars and some maneuvering spaces outlined. A fixture space at the lavatory, a fixture space at the water closet, and a turning circle inscribed within the room. We often get a question about how small a toilet room can be, what''s the smallest toilet room that can be constructed and still meet the requirements in ADAAG. The question that I volunteered when this was posted was is this toilet room as small as it could be? And one of the areas of confusion I think for people in analyzing either plans or actual toilet rooms is understanding what may overlap what in these facilities. Here we show the door swing overlapping the turning space, which is entirely permissible. In fact, the door swings overlap the turning space by a foot. 6 inches more, as far up as the maneuvering space that is shown by the dotted line at the water closet. So it looks as if there is probably another 6 inches in length that could be squeezed out of this room. The second question that was posed was what other maneuvering clearances might need to be checked in this particular room. We have noted the fixture space of the lavatory and the fixture space for the water closet, but what is not shown on this is the required approach space to the door on the pull side, which also may overlap the turning space and any of the fixture spaces. So, in a toilet room, what is permissible is the overlap of the fixture spaces, the overlap of the accessible route, the overlap of the turning space. But what may not overlap is the door swing and the approach to any fixture. That is the door swing may not encroach into that area that you would use to use the water closet or to use the lavatory. The third question posed with respect to this room is what methods of transfer can be accommodated in this plan. There are several ways of transfer from a scooter or a wheelchair to a water closet or toilet. The appendix in ADAAG, which is on page A 9, shows two of them. A side approach, which would require that the wheelchair be in the space now occupied by the lavatory, or a diagonal or front approach, where the wheelchair is arranged at an angle to the water closet and transfer is made using the grab bars. This diagram will accommodate a diagonal approach or a front approach where the wheelchair is at a 90 degree angle to the water closet. But it will not facilitate a side transfer, which is the one most easily used by many people. And in general, in new construction, it is much preferred to provide for both types of transfer to ensure that you serve as many potential users as possible. The last question, question 4, is it okay for the door swing to overlap the turning space? And the answer to that is yes. Jennifer, do you want to open it up for questions? And I will hold the rest of these details for a later session

Jennifer Bowerman

Okay. Again, Lois, if we have any questions that come up that might be pertinent to the other case studies, feel free to throw those back in there.

Caller

My question is, if there is an alteration to a restaurant which would trigger the ADAAG Guidelines, can we require the owner of the restaurant to actually tear down a wall in a toilet or a restroom which is far too narrow for a wheelchair to enter?

Lois Thibault

In general, it is expected that alterations will be relatively consistent in scope with the overall work that is being done. I''m assuming in this case that the owner of the restaurant is spending some considerable sum of money to do general alterations in the restaurant. If this is the case, then the path of travel obligation in ADAAG would kick in, requiring the expenditure of up to 20 percent of the project budget on improving both the path of travel to the portions of the restaurant that are altered, and improvements to the toilet room, drinking fountains, telephones and so on that are along the route or serve the altered area. So, my feeling is that unless this is simply a cosmetic alteration that they are undertaking, that 20 percent of the project budget would probably be sufficient, particularly if there are contractors on the job already to pay for the removal and relocation of a wall to make a toilet room accessible. In a restaurant, there is very little more important to accessibility than having an accessible toilet room

Jennifer Bowerman

Thanks, Lois. Our next question?

Caller

Lee, and my question to you is case 5. Shown there indicates a 15-inch dimension from the wall to the center line of the lavatory, or at least it appears to. And my question is, in order to get the 18-inch clearance, we''d have to probably increase the room. Why is that not addressed or was it?

Lois Thibault

Well, the requirement at the lavatory is for knee room and the 30 inches of width that it requires. So typically, 15 inches to the center line of the drain will give you the required wheelchair space there for ADAAG . Now, some building codes may require more. I know at least one state that has an 18-inch requirement. We do see that they have observed the 18-inch requirement that we have to the center line of the water closet in this room. But from the point of view of ADAAG , all you need to provide under the lavatory is the fixture space for the wheelchair

Caller

Thank you.

Jennifer Bowerman

Our next question? If people would like to go around again, we will take additional questions. Lois, I''ll throw a couple out for you. Actually, this kind of goes back to one of the questions that you and I were talking about earlier. We had a situation where we were looking at transfer shower. It was a 36 by 36 transfer shower that the designer was looking at instead of doing a three wall shower, doing a two wall shower with a additional shower curtain that would extend to two walls. Could you talk a little bit about the response on that?

Lois Thibault

The difficulty in something like that is that you need a surface, of course, for the grab bar, which is absolutely essential for transfer. And then you need a mounting surface and a back for the bench that you are transferring to. So the typical detail shows those on the three walls with the fourth wall open. It is certainly thinkable, I think, that an alternative could be designed that would permit that space to be opened to, say, a larger space as in a gang shower or something like that. It would obviously require a transfer to a stool or a bench that was fixed in the space, that had a back of some considerable height, and that had the same relationship to the control wall, the location of the controls and so on, as there is in the Figure 35 that shows a transfer shower. I guess our question in a situation like this is why would it be necessary to do this? I think devising an alternative of this sort is no more cost-effective than simply framing out that wall and meeting the current requirements in ADAAG . But it is certainly permissible to do other things, as long as you have a clear understanding of how the space and the particular fixture is being used. And I guess the key in this particular instance would be understanding that there must be a back on that bench to provide support for the person who is transferring from a wheelchair onto that bench in the shower.

Jennifer Bowerman

Thanks, Lois. Do we have any additional questions?

Caller

Hi. I was checking on what the status of the updates of the ADAAG are currently.

Jennifer Bowerman

Actually, if we could hold that question to the end. We are going to talk about that as we wrap up the session. Can we take our next question Because we just did talk about the shower rooms, too, Lois if you could go to that case study number 7, because that''s often a question that comes up with the issue of transfer showers and curb ramps and the spacing, especially when a transfer shower is butted up against a wall and the approach to that shower.

Lois Thibault

Yes. (Case 7 www.adagreatlakes.org/training/errors/case7.htm) The difficulty in this figure is the suggestion-and you will see it at the open side of the shower, where the arrows indicate a slope down and away from the shower itself. Because this is a transfer shower, it means that the chair will be pulled up quite close to the opening and perhaps even somewhat into it if there is not much of a curb. And then the grab bars will be used to transfer. A transfer is a very difficult operation under the best of conditions. When you are in a wet environment, you are transferring from your chair into a narrower space that is constrained on three sides and on top of that, it is wet and there is not a flat area for the chair to sit securely on. It can easily lead to a fall and injury. So we do not permit, or ADAAG does not permit a sloped area such as this small ramp or threshold at the entry to the shower. That fixture space that is described by the dotted rectangle must be flat in order to facilitate transfer. Notice that in ADAAG 4.21.7 a half inch curb is permitted in a transfer shower. The assumption being that that is about the maximum that is possible for one''s legs to be pulled up and over some kind of a bump, an impediment in a surface without there being some pain or damage. Perhaps I will go on to the other three questions that are indicated here. One talking about the issue of an alcove, which we addressed already, and vestibules. And it is our view at the Access Board that in most cases in toilet and shower rooms-notice that this one has a bench on its left wall-that people are in general maneuvering in the equivalent to an alcove. It is constrained on three sides. So additional space must be provided. In this case, an additional 6 inches in width between the bench and the open end side of the shower. The controls of course would be much more reachable if there were an overlap in fixture space at both sides of the transfer shower and not just at the bottom side. Now, obviously that would require sliding the shower down a bit, but it appears that there is that kind of space adjacent to this column here. And it may be by sliding the column, the 36 by 36 shower down a bit, you will grab 12 inches of wall space at the top there and then you can center a wheelchair and reach both the controls quite easily and then make the transfer as well. We talked about maneuvering space at the door in some other circumstances and in this case, I think that you would have to agree that you are providing a side approach with the 60 inch turning circle. There should be just barely enough to throw this door open and exit. As far as the drinking fountain on the exterior here out in the corridor, because it is located in the corner, it probably falls outside what we would consider circulation space in that corridor area and would not present a real hazard to travel by users of the building who were blind or had low vision.

Jennifer Bowerman

Do we have another question there?

Caller

Hi, Jennifer, Hi Lois. Rick Edwards here. At the beginning I thought I heard you say that the door could encroach on the turning radius in the water closet. Is that true?

Lois Thibault

It may encroach on the maneuvering space that is required. In other words, that 60 inch circle. It may not encroach on the fixture space, which is typically a rectangular space at either the water closet, at the lavatory or even a bathtub if there were one in a toilet facility.

Caller

Like how much?

Lois Thibault

Well, no overlap is possible at all between the door and the fixture space, but you may overlap-if you look at this case 7, for instance, you will see a completely permissible overlap of the turning circle, the dotted circle and the door swing. And that is entirely within the requirements of ADAAG.

Jennifer Bowerman

Lois, I think that people are getting a little bit confused on the difference between the turning space and the actual clear floor space or sometimes we call it the wheelchair parking space in front of the fixtures, so it might be a terminology issue. One resource that people might also want to look at is the new technical assistance manual that the Access Board had issued that has all new diagrams and does a great job of further illustrating the differences between the turning space or that radius and the clear floor space or the parking spaces.

Lois Thibault

Yes. The ADAAG manual, which is available through all the DBTACs is very complete in the area of toilet and bathing room. It illustrates quite a range of possible approaches. I guess one of the reasons that there is both confusion and difficulty with designing toilet rooms is because of the number of different types of spaces that have to be accommodated and the different rules that apply to each of them. In general, what you have in any small room or space is not only the approach space at the door, which is necessary to open and close or to get your wheelchair out of the way of the door, but you have a required space at the fixture. We call it the fixture space. At the lavatory, at the water closet, at the shower or tub. And in general, that is the space necessary for the wheelchair to occupy, either using the fixture as in a lavatory, where you simply pull up and need to have knee room under it, or in transfer, either onto the water closet or into a transfer shower or into a tub, for instance. And that is the fixture space. So, in addition to the door space, you have got the fixture space, you have got the travel route to and from those areas, and then you have got a requirement in toilet and bathing rooms that you be able to turn around. And that is that 60 inch diameter circle that you see so commonly as a measure of accessibility in toilet rooms. It is that space that can overlap other spaces in a toilet room, the 60 inch circle. But you must be very careful that you don''t have any overlap between the swing of the door and the space required to use a fixture.

Jennifer Bowerman

Thanks, Lois. We are coming up at the end of the hour, so I will throw it back to you in a second for any last final comments. Martha in Illinois asked about the new ADAAG guidelines. For those of you that don''t read the Federal Register on a regular basis, you might be interested to know that the Access Board this morning issued a Notice of Proposed Rulemaking on the ADAAG and the Architectural Barriers Act, updating those accessibility guidelines. So you can either access that through the U.S. Access Board''s website, which is www.access-board.gov, and download it that way, or the hard copies will be coming to the DBTACs within the next couple of weeks or so. You will be able to order a hard copy through your regional DBTAC. We are looking forward to a session, a distance learning session coming up in either February or March. We are actually hoping to move to it February to give people opportunity to participate in the period of public comment. We will do a distance learning session highlighting the proposed changes to ADAAG. From that, Lois, I will throw it back to you if you have any final comments for us.

Lois Thibault

I would like to recommend the new proposal to everybody. And I''m sure that there is a lot of other questions out very sincere and appreciative thank you to you as this is quite a difficult session to do on telephone, and to thank you for the time that you have given us this afternoon.

Jennifer Bowerman

I''m sure that we will have many follow-up questions and hopefully will be able to have you back for an additional follow-up session. For those of you that are interested in the transcript to this session, it will be posted to the ADAAG Great Lakes web site within the coming weeks. Thank you Lois and thank you to all of our sites that have participated today and on behalf of the Great Lakes, Mid Atlantic, Southwest, Great Plains and Pacific DBTACs, thank you for joining us today and hopefully we will have you all back on the line in December where we will feature a session on the ADAAG implication or managed care. Thanks for calling today.