Lessons Learned: Common Errors in the Design and Construction of Accessible Lodging Facilities

Lessons Learned: Common Errors in the Design and Construction of Accessible Lodging Facilities

Tuesday, Aug 16, 2016


Greetings, everyone. This is Robin Jones with the Great Lakes ADA Center. Before the start of the session today, I am going to go ahead and run through a couple of the details related to the webinar platform itself before we actually start the session at the top of the hour.

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I am getting some background noise. Is that from -- operator, can you check to see where that background noise is coming from? All participants should be muted except the presenter and myself.

I am showing it was coming from Douglas's line.


Doug, if I could have you mute yourself so I don't get any background noise, please.


Sorry about that.


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Good afternoon, everyone. This is Doug Anderson. I am your presenter for today's program. I appreciate your time. We are going to be walking through some of the typical hotel design and construction issues that, in our firm, we run into. LCM Architects. We are a nationwide accessibility consulting firm established in 1996. We were designed to not only do traditional architecture, but we are also set up to do accessibility consulting, which is not always part of an architectural practice. We have worked throughout the country with different hotel ownership groups, with brands, and also with designers and contractors on consulting on either new construction, alteration, or existing properties.

I also serve as the American Hotel and Lodging Association representative on the ANSI-A 117.1 committee. This is the committee that addresses accessibility issues for the ANSI standards, and this is the section of ANSI that is referenced in the International Building Code for accessibility requirements of Chapter 11. The ANSI standard historically has been the standard that the Access Board has used in coming out with the ADA standards.

I was appointed to the Access Board by President Bush in 2003 and served for two terms, and that span, the time period in which the 2004 ADA guidelines were released, and so that included -- that was what was used then to release the 2010 standards by the Department of Justice.

So, let's start off talking about design issues. Obviously, if something is not designed properly, it's likely that it's not going to get built properly unless someone catches it in the field. So the first step to ensuring that hotels are compliant with the ADA is making sure that all the design issues are in place.

The first thing that I talk about with architects when we start a project is that we really should not be designing to maximums or minimums, or we should really never design the maximums or minimums. The standards, most of the things in the standards, are designed as or stated as maximums or minimums, and sometimes it's stated as a range. And so those are not something that we should be designing to. So an example here is a light switch, and a light switch that's been designed to be at 48 inches above finished floor. Now, one of the things that's stated in the standards, the 2010 standards, is that construction tolerance is not allowed for dimensions stated as ranges. So this light switch I am pointing at the light switch here, and you can see that the centerline of that outlet was designed to be 48 inches. But when you flip that light switch to the up position, you can see that the top of that light switch is actually above 48 inches. And because we don't get a construction tolerance outside this 15- to 48-inch range, this is not compliant with the 2010 ADA standards. You may be a little bit skeptical sitting at your desk saying, well, gee, Doug, that's so close. Why does that make a difference? I have actually been an expert in cases where things as specific as this get called into question as far as compliance, and technically, that is something that's outside the reach range, and you really don't have an argument for that because the dimension that you were shooting for was stated within a range. And so the architect really should have been designing 46 inches, 44 inches. When it comes to a light switch, the performance of the light switch for everyone is not impacted by having it lower, and so you gain nothing by pushing it up to the top of the range.

Another thing that we commonly see in design that is not put together correctly or not designed correctly is passenger loading zones. So, at a passenger drop-off at the entrance to a hotel, you will have a loading zone, either for valet or perhaps for taxis, or just whomever is driving you to the hotel and dropping you off to go check in. Where you have a passenger loading zone, you have to have an axis aisle that serves that loading zone that's marked to discourage parking. Now, it doesn't necessarily require a specific type of striping. You can use maybe a different colored surface or a different type of pavement to try to distinguish between where the vehicle parking place is for the loading zone and where the access aisle is. But it has to be clear that that is provided for drop-off and loading. Here is an image. We have an image showing a striped area with curb ramps on either side. It's clearly not a parking space, and that serves as that loading zone. Quite often the loading zone is identified on the plan or is not planned for in the design, and because of that, they don't get installed, and so it's a deficiency when we are either looking at a completed property or an existing property that's been called into question.

Another design issue -- and it's really more for -- it has to do with exterior accessible route slopes. You are probably all familiar with the fact that a running slope on an accessible route can slope up to 1 and 20 percent before it is considered a ramp--


Doug, I need to have you stop for a second. We've lost some audio. Can you just hold for a second, please?



(Pause in speaking)


Okay. You are good. Go ahead. Sorry about that. We got reconnected.


Yeah, no problem.

Okay. Here we go, folks.

So, the exterior accessibility route slopes tend to be an issue, and we often find these when doing construction reviews throughout the construction process or for additional properties going out and doing assessments of the accessible routes.

A couple of suggestions for the architects is clearly show on your plans where your accessible routes are going to be because on those, the contractor has to be very diligent to make sure that the running slopes and the cross-slopes do not exceed the maximums. So our side-to-side slope is a 1:48 slope maximum, and the running slope is a 1:20 or a 5% slope maximum. Over 1:20, it becomes a ramp, so we want to definitely stay below that 5%. I often encourage architects, where they can, to design the site such that you can avoid a ramp and provide a sloped sidewalk instead of a ramp. It's less expensive, you don't have to pay for handrails, and visually it can be nicer and it can be more accessible for a greater group of users.

So, what you have to keep in mind, though, is on your accessible route, when that accessible route turns, the place where that turn is has to be 1:48 maximum in all directions because the running slope that the person is experiencing as they travel along the sidewalk will now become a cross-slope when they are making that corner. And so for that reason, at any intersections along the accessible routes, we have to make sure that that all flattens out to be level. So very common issue that we find out in the field.

Ramp slopes and handrails. The ramp slopes are: 12 maximum. Again -- are 1:12 maximum. Again, as we talked about in the introduction, we never really want to design a 1:12 if we can help it. That's a maximum, and we want to design it 1:15 or something less than the 1:12 in order to give ourselves some leeway so that in the field the contractor has a reasonable chance of meeting the 1:12 maximum. I have been involved in a lot of cases where I've been sent out to check work that's been done kind of at the, you know, a mediator or a court monitor, you go out and see what's been done, and quite often, the contractor or architect has designed something exactly 1:12, and we find portions of the slope that exceed that 1:12. You can talk about construction tolerance, but there's no consensus or standard for what a construction tolerance is. So you have to be careful with that. The devices generally used to measure slope in the field is a two-foot digital level. While they are accurate, the accuracy really is only to .3%, so you might have something that in actuality is 8.6% -- or 8.3% slope, but the digital level may read it as 8.6%. And an investigator generally is not going to take that accuracy into account in calling that a violation or not calling that a violation, so you have to be very careful with that. Another reason not to design right to the maximum.

I think of this almost like a speed limit. And so we generally, when we drive -- or at least I do -- I see it's a 30 miles per hour is the maximum speed limit, so I drive at 30. Or it's 65 and I drive at 65. And my kids may or may not verify that. But what you are shooting for is to drive that speed but not exceed it. You can't think about the 1:12 maximum in the same way. Let's say that the car recorded your actual running speed and kept track of every time that you can exceeded the 65 miles per hour, and someone could go back and check that and give you a ticket for every time you exceeded the 65 miles per hour. You would not try to drive at 65 miles per hour; you would be driving maybe at 60 or something below that to give yourself a little leeway so you are not violating that and getting excessive tickets. So think about it maybe in that way. When that's the absolute maximum, we really want to avoid that because in a case, you know, a plaintiff, if a complaint is filed, it won't be just that one issue that's looked at. A full assessment of the property will be done, and people will find other errors on the site. Same thing happens with due diligence. An owner, you know, they may never have been served with a complaint, but if they are going to sell the property, usually an assessment is done, including an accessibility assessment, and any noncompliant factors are listed and can reduce the sale price of the property.

This, though, the architect has not just designed to the maximum. They've actually -- there's an error. Instead of showing a 1:12 slope, they are showing a 12% slope, obviously an error. The other thing that we see on this is we've got places where we should have handrail extensions, where they are not shown. Not designing to handrail extensions to extend at least 12 inches beyond the top and the bottom of the ramp is a very common thing that's maybe shown on the plans but maybe not detailed or dimensioned on the plans. So that you make sure you get that minimum of 12 inches there. Curb ramp landings. So your slope requirements are the same as ramps, 8.3% maximum. One thing I like to encourage is you orient the ramps in the direction of the pedestrian flow. You have a couple of diagonal curb ramps shown here. It's not that you can't use a diagonal curb ramp, but it's not as user friendly. And want to be able to line up and have the front wheels of the wheelchair hit the slope so that they're exactly perpendicular to the change in grade at the top of the ramp. You don't want one wheel starting down the ramp before the second wheel, before the other front wheel is on the ramp. That creates an unsafe, unbalanced situation.

With the program shown here, it would be okay if we had a landing in the crosswalk that was 48 inches long. But you can see on the left diagram, we have a crosswalk that's shaded in here, and we don't have a full 48-inch landing that's provided at the bottom of the curb ramp.

On the right here, we need a landing of 36 inches, a minimum at the top of the ramp. This might be a combination ramp where you come onto a level area and turn to your left to go up the ramp. Again, there's not much detail here, and the likelihood of the contractor building a compliant curb ramp would that kind of detail is not very -- I would not be very confident that that would get built correctly.

We have a gutter pan shown in the middle here, and sometimes the gutter pan doesn't get detailed properly. A lot of times it will have the curb ramp, but might say an 8.3% or 1:12 maximum slope. But it may not address the curb ramp, which you have a maximum counter slope of 1:20 on the gutter pan. Sometimes that gets missed.

Door clearances, clearly identifying the minimum dimensions here. Again, these are minimum, 60 by 18 for the pull side of the door. You want to consider things, am I going to have base trim on that wall? I might have 18 inches from the edge of the door to the wall, but what's going to go on that wall? Is there anything that may extend into that that would reduce that 18 inches? So, designing for exactly 18 inches is really not recommended. You quite often have things occur in construction. It can be trim other or things that pull this into question. And so that often either doesn't get dimensioned properly or is just dimensioned to the minimum.

You can -- one thing that is allowed in the 2010 standards is when you take that 18 inches, when you take that measurement, you can take into account a door setback of up to 8 inches. So it's shown in this diagram. If the setback to the face of the door is 8 inches or less, then our clear floor space for that 18 inches on the pull side of that door or 12 inches for the push side can be measured where the green is shown there. Can be measured out away from the face of the door, set back up to 8 inches. Where the recess is greater than 8 inches, then we actually have to measure clear floor space back into the recess. And so again, being careful where we recess a door, making sure that we -- if it's greater than 8 inches, making sure we have our full compliant space provided there.

Another thing that we see in design is not paying attention to the 48 inches for doors, in series, having that clearance outside the door sweep. You see this in vestibules often, either bathrooms or entry vestibules. Really, the risk is someone could come through the door, and we have a condition shown in the upper left hand where both doors are swinging out. So the door that's swinging into the vestibule space, if there's less than 48 inches there, there's a possibility that someone would be inside the vestibule and need to go through the door that swings into the vestibule, and without that 48 inches of space, they might actually get trapped in the vestibule and not be able to go through that door, which cannot -- is never a good situation.

One of the changes in the 2010 standards relates to service desks, and service desks under the 91 standard, it was an allowance for what they called equivalent facilitation, in that if you had a fold-up shelf or something that slid out, you could have a little ledge that could be used for the accessible portions of a service desk. That language was taken out of the 2010 standards, and it was expanded a bit. It went into not just the type of counter that you had as far as not being a little ledge, it talked about that the depth of the accessible portion of the counter needed to be the same depth as the depth for the rest of the customers so that I am not ending up with a little short platform at the front of the desk while everybody else maybe has 18 or 24 inches of depth in the countertop that they are using.

So that's a 36-inch-long minimum and 36-inch maximum height. If you are doing a front approach, it could be 30 inches wide, but then you have to provide accessible knee clearance there. You can do the side approach with a 36-inch width as long as you have a clear floor space. That's 48 inches wide.

Kiosks. We see a lot of kiosks designed for printing out airplane tickets or boarding passes in the lobbies of hotels and making sure that where you are providing a knee space here, we show a front approach to this, and if you are providing, you know, work surface there and providing the knee space there, you need 34-inch maximum height for the work surface and the knee and toe clearance 30 inches wide, and then you can see or I'll tell you about the dimensions here. We have a 17-inch depth for our toe clearance, 8-inch depth for our knee clearance. That's at least 27-inch minimum in height.

Bar seating. Another equivalent facilitation requirement or allowance under the '91 standard, the '91 standard talked about the fact that table seating with a waitress service in a bar area would be equivalent to having a portion of the bar that's lowered. This was changed. That equivalent language came out of the -- was taken out of the 2010 standard, so we need to have -- where we have bar seating, we also need to have accessible seating, and so we need a countertop height, 34 inches maximum, and we need to have at least 17 inches knee and toe clearance that is 30 inches wide that goes under that.

I have a photograph of a regular-height bar, and then at the corner of the bar they've created a round table, really, that drops down to 34 inches that has knee clearance and seats around it. It's kind of a nice way to design an accessible bar. It's not the only way to do it, but I put this photo in here because I thought it was a nicely designed bar. I saw this out in California and thought it was nice.

5% of the seating or standing spaces need to be accessible, so you count up your bar seating. You may only be required to have 1. We generally require that you are providing at least a 60-inch-wide lowered section, even if you are only required to have one wheelchair space. The 60 inches is recommended for companion seating at that lower height.

Dining tables. We rarely see someone thinking about accessible dining tables when they are laying out the furniture for restaurants. A lot of times in very nice hotels they are using very zippy designs for the tables or the seating or the furniture, but the accessible tables need to have the 27-inch knee clearance, knee and toe clearance that goes at least 17 inches underneath the table and is 30 inches wide. And with pedestal tables that have the little cross-pieces below them, those generally do not provide the minimum knee and toe clearance beneath the table to be compliant. So you generally either have, you know, a post-mounted table or you have a -- 17 inches deep, sometimes it's an offset table on a post. Or you are going to end up with a four-leg table. And I've seen -- you know, you can get some very nice accessible tables for dining areas, but you just have to plan for it in advance, and you know, when you are selecting your furniture, it's great to select a furniture line that will have an accessible table that matches the rest of the design for the tables.

Signage. As with all things in a hotel, you know, design drives a lot of the features in a hotel, and so being up-to-date and being competitive with the other companies that are out there, always pushing for newer designs or newer looks, in doing that, you really have to be careful that you are not violating the accessibility requirements. Saw this sign. It's very interesting. We have a white lettering on a white background. It does have the raised character, but it certainly doesn't meet our contrast requirements. Also supposed to be non-glare surfaces on signage, and there's a lot of metallic signage out there. If it's a brushed finish, is it a non-glare? That's kind of a question mark. You could argue that both ways. So you just want to be careful in the finishes that you are choosing and the contrast on the signage.

Proportions are another thing. I have been seeing a lot of very narrow lettering that's tall, and while it might look very sleek, it doesn't meet the ADA character proportion requirements. We have a number of different height/width, stroke rate, height to width ratios we have to be concerned with. In picking out fonts, a whole system of fonts for the building, you really have to be careful that you are not picking something that's going to not be compliant with the standard.

Accessible sinks. I see a lot of these panels that are put in to provide protection against contact with either the drain lines or the supply lines, and that's great, but quite often we see them designed such or installed such that they don't provide the proper knee and toe clearance. And so you really have to provide -- a lot of times architects will just show it in the drawing. They may not provide adequate dimensioning for the contractor to understand exactly where that has to be installed. But I think it's a great design solution. It looks better than the insulation. You just have to make sure that it's designed properly so that you are not violating your knee space with the installation of those. Toilet Centerline. There's been a lot of pandering, a lot of plumbing changes over toilet centerline since 1992. The standard was, as you are probably aware, in the '91 standard, we had an 18-inch centerline, and it was started as an absolute dimension. Now, you would have gotten construction tolerance on that under the '91 standard, but it was stated as an absolute. And you had a lot of arguments with contractors, building code officials, architects, judges, a lot of people, attorneys. So one of the things in the 2010 standard, when that was being rewritten, the Access Board, we wanted to take out exact dimensions to the extent that we could. Pretty Much all of the exact dimensions were taken out and replaced with ranges. Ranges are great, but remember, we don't get a tolerance outside that range.

So toilet centerline is now 16 to 18 inches. When I see these still dimensions at 18 inches, unless there's a state code that obligates you to still meeting the 18 inches, I never recommend designing exactly to 18 inches because you are not going to get a tolerance outside of that. So the range is 16 to 18 inches, and so always say you want to hit 17 inches or dimension to 17 inches, which gives you an inch of leeway on each side.

California, when the ADA was passed, they switched to the 16 to 18, but then the people in California got -- quickly got involved and made sure that that got reduced to 17 to 18 inches. They felt 16 to 18 was too wide a margin. So, in California, you only get a half an inch on each side, and you have to go with the 17.5.

Toilet clearance. One of the big changes in the 2010 standard was the amount of clearance required around a toilet. We used to be able to have a lavatory overlap the clearance around a toilet, and the clearance was a little bit narrow. It was 48 inches instead of 60 inches. So that was a big change, and it had a big impact on hotels, especially on alterations because a lot of existing hotels were designed to meet the '91, and you start moving things around, and now it's an alteration, you have to somehow find 60 inches. So, making sure that we get that full 60 inches, we have a picture here that shows a urinal that's within the 60 inches. It looks like there's a lot of space in that bathroom, but when you scale the distance to that urinal, it's less than 60 inches, so it really needs to make sure that things like that are properly dimensioned on the drawings and also that you've actually got enough space to fit them in there. So we still see that as an issue.

We also see changing tables or things like that extending into that 60 inches, especially in accessible stalls. This is a changing table in the folded up position. There's a lot of controversy and arguments on both sides of the table as to whether you have to consider the changing table in the up or down position when calculating space around the toilet. But I generally would look at it as measuring it in the up position, although there are some states that don't look at it that way, including Texas. But, if you are in a state where you can look at it with a changing table in the up position, you still have to make sure, unless it's recessed into the wall, you have to make sure that that is not going to overhang your required clearance around the toilet.

Grab bars and TP dispensers. So, our minimum rear grab bar is 36 inches. Men mum side wall grab bar is 42 inches. I have started recommending, because of the horizontal positioning of these grab bars, that you start using a 42-inch rear grab bar and a 48-inch-wide side grab bar. The reason I do that is if you are using a 42-inch-long grab bar and it has to be at least 54 inches from the rear wall and 12 inches maximum from the back wall, then you are in a situation where you have an exact dimension. So you are trying to get that grab bar exactly in the right place. Now there's the issue, okay, construction tolerance and if it's off a little bit, you can make that argument. I prefer not to make the argument and just make sure that I am using a longer grab bar and I have a couple inches of leeway at the bar and I don't have to worry about my contractor being so precise out in the field.

Same thing here with a rear grab bar. Have to have 12 inches on the narrow side of the water closet and 24 inches on the wide side of the centerline of the water closet. If I am using a 36-inch grab bar, then I have an exact dimension again. I have to get that exactly in the right place. And you know, in the old standard, it used to be measure out six inches from the corner, and that's where your grab bar would start for your rear grab bar because you were mounting your toilet at 18 inches. Now that the toilet can be 16 to 18 inches, now you have to start taking that into consideration and calculating where the centerline of the toilet is and getting the 12 inches and the 24 inches respectively on that. So it becomes more -- it's more difficult. So that's something that I recommend. The toilet paper dispenser, 7 to 9 inches from the dispenser in front of the bowl. This requires coordination between what's specified for the toilet, you know, how it gets installed, where you are trying to install a recessed toilet paper dispenser it becomes more difficult or challenging in making sure you get that rough-out in the right location such that when the toilet is installed you are going to hit that 7 to 9 inches. A little harder than it sounds. Again, specifying 8 inches to the centerline to give yourself that leeway, you don't get a tolerance outside of that. You know, all of you involved in construction know that where the toilet soil line goes in may be an inch or two off the rear wall, and so even though you are using the specified toilet, the bowl might get pushed out a little further from the rear wall than anticipated, and it can definitely cause a problem. If you've already built a recessed area for your toilet paper dispenser.

Accessible stalls. Some of the common problems we see relate to door locations where they are supposed to be kitty corner from the water closet, and so that 4 inches maximum from the corner being on the corner opposite the water closet, that gets missed.

Toe clearances. Where we don't have toe clearances, we have to increase either the width or the depth of the stall. Sometimes people do full-height partitions without taking that into consideration.

Then we also need to have hardware on both sides of that stall door, and that's something that's not always specified or shown on the drawings.

Ambulatory stalls. We have a range now of 35 to 37 inches for the stall width, and that's good. We don't have to hit the 36 dead on. But we quite often are getting things much in excess of what the start is there. And then, correspondingly, we have the toilet centerline. Instead of a 16 to 18, it's 17 to 19 because of the stall width. We are centering that there in the stall.

So, I am showing a plan here. They are showing a 37-inch-wide clearance on that stall. We really should be designing to the midpoint there. We also should have a 32-inch cleared door, and the plan also is showing a 24-inch door specified for the ambulatory stall.

Okay. Restroom, water closet grab bars. We actually already talked about this. There is an allowance, though, where you have a recessed sink that you can actually use a smaller or shorter grab bar. We'd recommend doing a 30-inch minimum there. You can go down to 24, but we generally would go with a 30 such that you can center that and have a little bit of leeway on both sides of that.

Guest room dispersion is an area where we see a lot of confusion. This can be a challenge with retrofitting existing hotels. But even with new hotels, trying to make sure that we've got an equal mix, considering the number of rooms, the amenities in those rooms. I have a hotel that I am working with, and the system, the computer system only allows them to have 50 different room types, and the way that they classify their rooms, if they try to get an accessible room for each one of the room types that they currently have, it exceeds their maximum number of types they can put into the computer system. So you know, it can be fairly tricky trying to match all of the different types of rooms.

Now, arguably, you might have rooms that are similar that could fall in the same category, and providing one accessible room in that category may meet your requirement. But things that you have to -- factors that you have to consider are room size. You know, if one room is a half a foot, square foot, bigger than another, you know, it may get classified differently, but I wouldn't argue -- I would argue that's not really a dispersion issue distinguishing between those two. Bed size, certainly a factor. Double beds versus a king bed, obviously a big deal, or queen versus king. Those are different bed sizes. Cost, definitely a consideration. You should have a range of options for the cost that you are spending on the rooms. View. A lot of hotels this may not make any difference, if you are in a shopping mall area near the airport your view might not be a consideration and certainly not a cost factor. But when you are in Hawaii, you are going to have a mountain view, you are going to have an ocean view, and you are going to have a resort view. So each of those has a different cost associated with it, and you are going to make sure that you disperse your rooms in those different categories.

Bathroom fixtures. You know, the types of fixtures. You might have rooms with double vanities that have both a soaking tub and a shower. I've even seen hotel rooms with saunas and different things in the master bath. So you have to consider the bathroom fixtures in dispersion of rooms as well and ensuring that if you have a five-fixture bath offered for your Presidential suite, your accessible Presidential suite should have five fixtures. Now, both bathing fixtures don't have to be accessible, but you'd still want to match that to be considered equivalent.

Smoking and nonsmoking, that's becoming less of an issue here in America.

Number of rooms provided, we generally look at it in number of bays. So if we've got a one-bay room, two-bay room, three-bay room, and four-bay room, we want to make sure that we've got comparable accessible room in each of those bay sizes.

And then connecting rooms. Quite often you'll have certain rooms that connect and making sure that we have accessible rooms that have a connecting room is very important. A lot of people travel with attendants or nurses or someone that they need an additional room for, but they want it to be connected to the accessible room. So that's another important consideration.

The '91 versus the 2010 requirement, there was a change in the way the scoping was done between mobility accessible and communication accessible rooms. While they generally end up with the same number of rooms between the '91 and the 2010, the way that they are laid out is different. Under the 1991 standard for a 250-room hotel, you would have 7 mobility-accessible rooms with communication features. That could be any type of bathing fixture. You would have to have a minimum of three roll-in shower rooms, and those, again, would have to have communication features. And then in addition to that, you would have 7 communication accessible rooms just with communication features. So when you add all those together, you get 10 mobility rooms and 17 rooms that have communication features. 2010 split those out. So, we only have 10% overlap with the mobility rooms between the communication and mobility rooms, or you can have minimum of 1 or a maximum of 10 percent. So under 2010, that same size hotel would have 7 tub or transfer showers, 3 roll-in showers, and 17 communication rooms. One of those 17 communication rooms can be located in -- or at least one has to be in a mobility room, but no more than 10% can be in the mobility rooms. So you have more rooms that are involved in your ADA inventory, but a large number of those or a bigger number of those are just going to be rooms with communication features.

Clear floor space at beds. With one bed, we need a 36 by 48-inch space on both sides and 36 inches at the foot. Now, it's true the clear floor space is 30 inches by 48 inches, which is shown on both sides of the bed; however, you have to get to that clear floor space, which means that your route to get to that clear floor space has to be at least 36 inches. You can have some portions of that that pinch down to 30 inches for your footprint, but in general, that's what we are looking for is a 36 by 48 all sides of a single bed.

For two bed, we need a 36-inch-wide route between the beds and at the foot. And this often gets designed to the minimum so that you are trying to get exactly, you know, 36 inches. Here's the one bed. Here's our plans between here. Now, you measure that from box spring to box spring. A lot of questions about is that with bedding? How do you exactly measure that? But how great would it be to have 38 inches there instead of 36 so that if, you know, the bed gets moved a little bit by housekeeping or whatever, you are still hopefully maintaining that clearance there?

Clearance on both sides of the bed, I should have a 30 by 48-inch space shown on here. That 36-wide accessible route has to get you to an accessible space alongside each side of the bed. That's to allow someone to transfer from either their right or left, depending on which side they like to transfer from. If we have two beds, they can choose either the right or the left bed.

Maneuvering clearance at doors sometimes gets overlooked. We've got a room that's connecting room. On the right-hand side, it's showing the bed and a door right by it. We don't have our 18 inches of pull clearance on that door. We have a bathroom in the left-hand picture. We have a door into the bathroom. The bed is extending into this clear floor space for the maneuvering clearance for that door. All those things have to be looked at. I really do encourage architects that when they are laying out their plans in their accessible rooms, just draw that maneuvering clearance right there on that plan. And if you are showing that there, it reminds you and also the contractor that we've got some sacred space here that has to remain clear. And it really does help. You know, I've had architects tell me, you know, yeah, I put that on there. The contractor called, they said hey, we have to move this over a little bit. I pull out my plan, look at it, and I immediately can see, no, you can't move that over because the clearance at that door is going to be violated. So just good practice.

Furniture blocking the route to the curtains. It's not just having the space designed around the bed, but you have to consider the other furniture placement and whether you have space in the room to get to things like a deck or the window shades or things like that. So that is something to consider.

The exterior patios, lanais, decks, having a compliant threshold there is consistent problem. Quite often we -- you know, with the exterior doors, just trying to seal against wind-driven rain and things like that, you end up with window systems or door systems that are not accessible, so that's a particular challenge for guest rooms.

We have a half-inch max. For existing or altered thresholds, we have a three-quarter inch. But for three-quarter inch, in a hotel you might already have three-quarter inch sliding glass threshold, but in new, you are looking at a half inch with a one- to two-bevel maximum quarter-inch max on that. It's tricky to meet, especially with those patio doors.

Totally different in FHA, but we won't get into that today.

Controls all have to be within 15 to 48 inches for the fixtures. So looking at thermostats, light switches, outlets, curtain controls. Outlets are a big thing that is missed quite often we have the outlets lower than the 15 inches. And again, I am going to argue that you really don't want to dimension the outlet at 15 inches. The electrical contractor is going to come in, he is going to mount it 15 inches off the subfloor, come back and put down a layer of gypcrete or carpeting and different floor materials, and pretty soon what was 15 inches to the subfloor is now 13 or 12 inches. Definitely want to avoid that.

No tight grasping, pinching, and twisting of the wrist for operation of the controls.

So, mobility bathrooms. Again, we mentioned before that the '91 we could have a sink that was located within our clearance at the toilet. It could overlap as long as we had accessible knee clearance. We can't do that anymore. In 2010, not only can the sink not be located in that 60-inch-wide toilet clearance, but the sink also has to have comparable countertop space. So you combine those two things, and existing hotels can really be a challenge.

Here is our comparable vanity counter space. You can see on the right we have a picture of a wall-hung sink that has maybe a couple of inches of, you know, level area around the bowl. Really not providing us much space at all to put down our contact case or hair dryer, what have you. And albeit it's messy, the countertop in the same hotel below is 48 inches wide, you know, with a 15-inch bowl recessed into it. And so there's all kinds of countertop space there. You can be as messy as you want to there.

So on the right, then, we show an accessible -- we show an accessible countertop that's the same width as what everybody else gets as far as the accessible width. It doesn't say square inch by square inch it has to be exactly the same. It just says comparable.

Sometimes an existing, we have to get creative. We might have to put some shelving or something in to try to make up for the fact that we just can't fit in a regular width -- or the vanity that's as wide as what everybody else gets in an existing condition. So this particular diagram, actually, there is space off to the right of the sink there. So conceivably this counter could have been run over, but imagine a situation where you have a smaller bathroom, you are trying to meet 60 inches alongside your toilet and get comparable countertop space. This might be something to consider. Department of Justice does acknowledge that type of thing in their guidance of the 2010 standards.

The bathtub seats, it can be removable, but it has to be something that can be securely attached, and there are now height requirements, 17 to 19 inches in the 2010 standards. This, as far as something that attaches securely, that often is missed. A lot of times it sets in place, but it doesn't securely attach. Or we end up with some kind of just bench that sits in there and has no attachment whatsoever.

We talked about knee and toe clearance. Here's another picture of that inside a guest room, where this angled piece is a really nice way to hide the piping, but it's only recessed about 3 inches instead of 8 inches from the front edge of the vanity there. Or the countertop.

Storage. We need clear floor space at storage, need things to be within the reach range, operable parts have to be compliant. Common error, a forward approach is provided where a side approach is needed. If you have to reach back into something, you basically can't reach past your toes for forward reach, so if you have to reach into something, you are going to need a side approach and clear floor space that corresponds to that.

We see the grab bars in accessible bathtubs often drawn wrong or positioned wrong. We are running out of time here, so I don't want to spend too much time on that. Bathtub controls. They have to be on the foot wall. They have to be over, offset so someone can operate those. Quite often, another thing I want to mention, these diverters, it's great to have a diverters between the shower -- diverter between the showerhead and hand wand, which is required, the hose with the shower wand, but a lot of times the little device that raises or lowers that shower want is not accessible. The control cannot be operated without tight grasping, pinching, or twisting of the wrist.

Shower location. We need the shower controls to be within 27 inches of the seat wall. Remember that in a mobility guest room, we have to have a seat. The seat is not optional. We need to have that provided within the reach range. There's requirements for the seat that often get missed. Oftentimes we have dispensers or other things in the shower that are not within reach range of our seat.

A non-positive shutoff is required for handheld spray units so you can shut down a water flow so it's very low flow, doesn't shut off all the way. It causes plumbing problems, but you have to be able to push a button and cut down on the spray of the handheld significantly. A plumber will know what that is.

Mobility guest rooms for showers is one of the places we still have exact dimensions on the 10, 36 by 36. That's measured on the midpoint of the shower, halfway up, not at the cove or the base. We get questions about that a lot. The standard roll-in is minimum of 30 by a minimum of 60 inches, and the ultimate roll-in is a minimum of 60, but the depth is an exact 36. That gets missed a lot. A lot of times that gets put in more than the 36 inches. The rationale there is a person is rolling in, they are grab the grab bar opposite the seat and transferring onto that seat much like someone would in a regular transfer shower. It's really -- the best shower, in my opinion, if you've got the room for it -- because it has the benefits of both a roll-in shower or a transfer shower, so it provides more option for the user. And if you design it correctly, you can actually put a door on these, and I've seen some beautiful alternate roll-in showers, marble, in very high-end hotels, and they compliant. They really can make them look nice.

Non-accessible guest rooms, all passage doors have to provide a 32-inch clear opening, exception being showers. But for toilet compartments, there's not an exception written for that, and so in a non-accessible room, all of the passage doors must be a 3-inch clear opening, and that gets missed often.

All right. We've got some time for construction issues here. These are the major things that we see. Parking. 2% maximum slope in all directions. This is very often violated. We see that all the time. I was talking before about exterior routes. Here we have a sidewalk that's changing directions. While the running slope might be okay at 3.8% or 5% because it's changing directions, that should be leveling out to a 2% maximum slope.

Here we've got curb ramps exceeding 8.3% slope. We also have gutter pans where the ramp slope might be 8.3, but the gutter pan is steeper than 8.3. People forget to put 36-inch landing at the top of a curb ramp, or we don't have proper side flairs on the curb ramp. You can't drive across the slide flairs in a continuous path for a curb ramp. So either we need a route around the top of the curb ramp or we need a different design for the curb ramp.

Ramps. This is a ramp in the Virgin Islands, a hotel, the Department of Justice came in, said hey, tell us how you are doing on your ADA compliance. They realized they had a number of problems, and so they told the DOJ, hey, we've got some problems we are going to work on. So they had me come down before the DOJ came out to inspect, and I put down my level on their ramps and said gosh, guys, this is 9.5% slope here. Well, we designed it to 8.3. It's just off a little bit. Well, okay, I get that, but that's why you don't design to 8.3%. I am not sure how understanding the DOJ was on that issue, but.

Here we have ramps, handrail extensions, so beautiful new ramp here. The handrail extension was not extended past the end of the ramp. You can see there's a little bit of a break here in that handrail. And that whole section of the handrail needs to be beyond the top landing. Or people curve the handrail -- I think this is back to the Virgin Islands, that 12-inch extension, there's a big curve at the end of the handrail, and it doesn't stay perpendicular to the top landing for a full 12 inches.

Entrances. Very often you see with exterior doors for hotels that they slope away from the door at a slope that exceeds 2%, the 2% maximum entrance doors. Protruding objects. These are things that maybe are not always in the design drawings, but hey, we have to put in a machine here for a defibrillator or we have to put in fire extinguisher box or something like that, and it gets slapped up and becomes a protruding object.

We talked about the accessible table issue. Again, pedestal tables generally do not provide accessible knee clearance under them. I've seen some limited exceptions where they do, but in general, they don't.

Food and beverage. This should be a 34-inch buffet height for reach over an obstruction, has to be 34 inches maximum, or for trace line, has to be 34 inches maximum. A lot of times these buffets are designed at 36 inches instead of 34.

This is nice that they thought about putting in an accessible bar, lowered section of the bar, but they did not provide the adequate depth. They made it the same depth as the regular bar. Usually a standard bar does not provide a 17-inch depth to the knee clearance below the bar for stools, so your accessible section of the lower bar is usually going to have to come out further than the rest of the bar.

Door opening force. Typical construction issue. This is far in excess of the maximum five pounds that's allowed. Signs. The new standard went to a range for the sign height. Instead of a 60-inch to the centerline of the sign, we have a 48-inch minimum to the bottom lowest line of text or 60-inch max bottom of the highest line of text. So we find people installing 60 inches to the bottom or getting this confused. Again, we've got a range now, so we want to design to the middle of that range and not to the upper part of that.

Our sink height. Sink height, top of the sink is expressed in a range. So 34 inches is the maximum height. There is no tolerance outside of this. And you know, cabinetmakers often will design this to be 34 inches exactly, but when it gets installed in the field, it might get shimmed or there might be some inconsistencies in the floor. The floor might be sloped for drainage or things like that. And so you end up with greater than 34 inches. So again, make sure we are not designing to the maximums.

Mirror height, reflecting surface. You can see in this situation it's really not possible to get that mirror all the way down because of the backsplash on the sink. So that's -- back splash on the sink. So that's something the coordination between those two things has to be looked at. Another thing we often see is a beveled edge to the glass. 40 inches should be to the top of the bevel in that situation. So something to be careful of.

Maximum rim height for a urinal, where you have more than one urinal, you need an accessible one, and so 17 inches is the maximum there. That's almost always wrong. We looked at this in design, but this happens in construction also, even if it's designed properly. We don't have the door opposite kitty corner from where the toilet is. It can be a problem.

We also find that we don't have hardware on both sides of the doors. So we've got a lock on the inside of the stall, but that look usually requires pinching to use it as a handle to close the door. So that is something that is not compliant.

Ambulatory stall width. Again, that's a range, so you have to be within that range, no tolerance. You often see those well outside that range.

60-inch minimum width. Again, that's minimum. And we often find 58, 59 inches, something, certainly not at 59 inches, and then also you have to be concerned with toe space if you don't have toe space then you need another 6 inches there of width.

Toilet paper dispenser location. This can be a little bit tricky. As I mentioned before, we might have the plumbing go in for the toilet at a slightly off from the back wall for a floor mount toilet. And a recessed place for the toilet paper dispenser. Making sure we get that 7 to 9 inches can be harder than it seems like it should be.

Flush valve on the wide side. This is just a detail issue that has to be paid attention to. And so this gets missed. With a tank, it's not as big a deal. With the type of flush valve that's shown here, it's a little bit more difficult to try to fix this problem.

The 16 to 18-inch centerline. Again, there are challenges in meeting that if you are trying to hit 18 inches exactly. Which this is an existing condition that probably was originally built to hit 18 and was off. But getting it to that centerline certainly takes attention during construction.

Grab bar mounting. Where you use those minimum-size grab bars, we find this all the time, instead of 54 inches, the grab bar is at 52 inches from the rear wall. Or we've got a toilet mounted at 18 inches, and so the rear wall grab bar should come out 42 inches from the corner and be no more than 6 inches on the other side, and we are off by 2 inches here. So save yourself some headaches and spend a little bit more on grab bars.

Maneuvering clearances at doors. Doors that are designed for the minimums. Here's an entry door to the hotel room, it's 17 inches. Should have been 18 inches. It just, during construction, was off a little bit. 12 inches for push side of the door is a condition where we needed the 12 inches and we ended up with about 10 and a half inches here. It might have been what they chose for finishing the wall. It might have been a combination of construction factors that linked up to provide that or cause that issue.

Guest room doors thresholds. Again, they are supposed to be a half-inch max height, beveled at 1:2 max. Find all sorts of different conditions out there. These two were existing conditions that were found, but this is commonly an issue.

The guest room door security latch should be 48 inches maximum, and quite often we find those higher. Now, you can install a secondary latch at a lower height, and that's acceptable, but that's obviously -- this obviously is way above the maximum.

The rods that we have for pulling the curtains open and closed, they require tight grasping, twisting, pinching of the wrist, or they are too high. We need loops or an auto control. Here's the problem with the room outlets I told you about. It was probably installed at 15 inches to the subfloor, and once the carpeting and other things went in, we ended up with less than the 15 inches.

48 inches maximum to operable parts. Here we have a couple of conditions where, obviously, they are off. This one the thermostat is off by quite a bit. I do see thermostats dimensioned in plans 48 inches to the centerline of where that box is, and that's almost always thermostats have controls either on the top or above the centerline of the unit. So it's really not a good idea to do that. 48 inches maximum to the top of the box maybe, but definitely not to the centerline.

All right. 36-inch-wide route to the 30 by 48-inch clear floor space not provided. Happens often.

The safe. We need our safe to have a 30 by 48-inch clear floor space and be within the 15 to 48-inch reach range. Here is a drawer safe which is a nice, convenient way to tuck away your safe, but as you can see, it's well below the 15-inch minimum height.

Our 36-inch-wide route to features. We have furniture that block these things. A lot of times it's either dressers or chairs or all sorts of things that get positioned in the wrong place.

Connecting door maneuvering clearance. We have a whole bed head board system that is blocking the clearance for the 18 inches for the pull side of the connecting door. Plus the couch and the lamp.

Grab bar clearances. We need at least 12 inches above grab bars, and I have a picture here that shows a towel bar that's above the grab bar. Often we find picture frames or other things above grab bars that block that. Guest room hooks for bathrooms like robe hooks or things like that should be maximum of 48 inches. You can have a lower and a higher one, but you have to make sure that you've got an accessible one someplace.

Our alternate roll-in shower. I talked about the fact that the depth is supposed to be a 36-inch exact. You know, sometimes in talking about not designing to minimums or maximums, people think, okay, we are going to make this well beyond 36 inches so that we don't have it less than 36 inches. And then they go overboard. So we miss the 36-inch exact dimension. This is difficult with tile. These things are getting roughed in, hitting exactly 36 inches. That's why you need construction tolerance. It's too bad that we don't have a -- you know, some kind of standard shown for a tolerance, what's allowed with tile. If you look in the handbook, construction tile, inset mortar, you are looking around a half inch. But you know, you are never going to get someone, you know, Justice Department or someone to appoint it to come out with a standard list of tolerances that are allowed.

The width of showers is supposed to be, for roll-in, it's a 60-inch minimum width. We find these often less than the 60 inches. A lot of times they get built out stud to stud at 60, and then once they are tiled, they are two inches less than that.

Towels and sundries within reach range. Obviously, we don't have the proper clearance around this toilet, but other issues are that we have a rack that's above the toilet, so the towels are not within the reach range. All kinds of problems with this. We have the phone not 12 inches above the grab bar. The grab bar -- we could go on for a while.

Guest room sinks. The knee clearance underneath the sink, a lot of times this panel gets attached right to the front of the apron instead of being further back.

Clearance at the toilet, 60 inches. Here we've got 58 and a half. Brand-new installation design. Something happened during construction, and it was designed to be exactly 60 inches. And it ended up less than that.

Shower and tub seats have to be within 3 inches of the opening of the shower. These come in standard sizes, so if you are building a nonstandard shower, you might run into instances of not getting the right seat. Obviously you can't just have a chair in there.

The slide bar. I mentioned the fact that the controls for tightening the cradle for the shower wand are not accessible. A lot of times we see knobs for those. Or the bottom of the shower slide bar is higher than 48 inches. We see that a lot also. Has to be down lower.

No grab bars over seats. We need to have -- so that when we lean back on the seat we are not getting a grab bar in our back. So where we have a shower seat, we want to make sure that the grab bar is not over that. You can probably see the other issue here, obvious issue here, is that our controls and shower wand and things like that are greater than 27 inches from the rear wall. So it's obviously a big issue.

Shower seats should be an inch and a half max from the side wall, and then the orientation has to be correct. That little L should be back in the corner instead of at the entrance side.

Shower equipment, 27 inches maximum from the seat wall. I don't recommend centering the plumbing fixture at 27 inches because when you spin that handle from hot to cold, chances are a portion of that handle is going to be on the wide side of the centerline of that fixture of that mixer, and so that's going to be outside that reach range.

Pool lifts. We run into slope issues for where your pool lift is. It's supposed to be at a 2% maximum slope there. Here's a condition to look at with your eyes, it looks pretty good, but with a smart level, we are at 3.2%. And then a route around the pool, having a 36-inch-wide route that's no greater than 2% maximum slope. This often gets blocked by chairs or things like that, or we end up with excessive slopes.

House phones. These often are not down with their operable controls within the 48-inch reach range.

And I am very sorry we had that little break, and I didn't leave very much time for questions. So I guess I'll open it up if there are any questions I can answer.


Hi, Doug. Yes, and we do apologize because we did lose that time there that interfered with ability for us to have additional time, but there's a couple questions here, Doug. One is somebody was remarking on the template that you showed in one of your images about measuring threshold, and they were wondering where you would get something like that.


I think I got that from Evan Terry. Hate to advertise for competitors, but it's a really nice product.


So it's something that Evan Kerry and associates out of Birmingham, Alabama, sell?


I think you can buy it from their website, yes.


It's Evan Terry and Associates, it's in Birmingham, Alabama. You can Google and just find their company, and as Doug said, it's available on their website.

We have a question here that when a restaurant shares a sidewalk, their ease of access, do they have shared responsibility with the city? So if the restaurant or hotel would share a sidewalk with the city, is it shared responsibility for that sidewalk, or whose responsibility is it?


Well, obviously, the hotel, being a public accommodation, have obligations to meet the ADA standards. If they are using for designing space, they are going to -- arguably, they should have a portion of the exterior designing that is accessible. -- dining that is accessible. Obviously, you are going to have a route issue there. You know, there's probably something in the agreement with the city. It should be meeting those slope requirements. You know, here in Chicago, they are compounding things about modifying sidewalks because of vaulted basements and other things, so you know, the feasibility may be limited for leveling those sidewalks, but I would think the city is going to tell you hey, that's your problem. You know, you fix the slope issues if there's a problem there. That's probably going to come down to what is technically feasible.

Robin, would you have anything to add to that on your -- from your perspective?


No, I would agree with you 100%. That's usually how we look at the agreements that are in place. Always goes back to what did the city have in place when they made agreements of you using public sidewalk area or sharing public sidewalk space. It goes back to the developer who developed it also.


Yeah. Thanks.


Great. Thank you. I do want to remind people that our next session is September 27. Please note the change in date. Typically the ADA Audio Conference Series is held on the third Tuesday of the month, but our speakers for next month's session needed to make a change, so it will actually be held the last Thursday of the month on September 27, and we'll focus on Rights of Air Travelers with Disabilities and the Air Carriers Access Act. So if you are interested, you can register at www.ada-audio.org.

We want to thank Doug for his time and expertise today. And Doug, I am not sure if you are open to people contacting you if they have questions, additional questions? If you would want to share your contact information?


Yeah. So, my email address is danderson@lcmarchitects.com, and Anderson is spelled with an o-n. So feel free to email me. Thank you for participating. Appreciate it. And thank you, Robin.


We really appreciate it. I did put your email into the chat area for people if you want to take a look at that as well. And I know Doug personally, and I know that he would be more than happy to assist you if he is able to or give you some clarification if you would need it.

Those of you that are participating, you will receive an email asking you to complete an evaluation. Your feedback is very valuable to us. It will also give you information about obtaining your certificate of attendance as well as the archive of this particular session. So again, we apologize for the sound problems that we experienced early on in the session. It did impact our ability to do it. But Doug, I applaud you for finishing a hundred or so slides in that period of time, and not having to go too fast, which was very good. So I am sure our captioner appreciated that as well.




Again, everyone, have a good day, and thank you very much for your participation. You can hang up your phone. If you are on the webinar platform, you can just close out the browser and that will shut down the platform. So again, thank you very much. Have a good day.


Thanks all. Bye.


Ladies and gentlemen, thank you for participating in today's conference. This does conclude today's program. You may all disconnect. Everyone have a great day. Speakers, please stand by.