One of the guidelines that seem to be misunderstood is for operable parts. This guideline requires that an accessible operable part have a mechanism that allows for operating or use without tight grasping or pinching, twisting of the wrist, with less than 5 lbs of force and to operate using only one hand.
ADA section 309.4 Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.
Why this is required?
There are persons that don’t have proper use of their hands. People with rheumatoid arthritis for example, or cerebral palsy, have a hard time grasping elements. Also, there are people, like amputees, or people that were born without hands or fingers that cannot operate elements which require tight pinching. In addition, some people with disabilities or older people may not have the amount of strength required to operate an element or activate an operable part if the force required is more than 5 lbs. Therefore, the ADA design guidelines provides rules to assist those people to navigate their environment in an equal manner.
Operable parts on accessible elements, accessible routes, and in accessible rooms
and spaces shall comply with with the standards. There are some exceptions which explain that certain operable parts do not have to comply:
1. Operable parts that are intended for use only by service or maintenance personnel
2. Electrical or communication receptacles serving a dedicated use (like a refrigerator)
3. Where two or more outlets are provided in a kitchen above a length of counter top that is uninterrupted by a sink or appliance, one outlet shall not be required to comply
4. Floor electrical receptacles
5. HVAC diffusers
6. Except for light switches, where redundant controls are provided for a single element, one control in each space shall not be required to comply
7. Cleats and other boat securement devices
8. Exercise machines and exercise equipment
9. Operable windows that are only operated by staff and not occupants
There is an advisory that gives us more guidance and explanation;
205.1 General. Controls covered by 205.1 include, but are not limited to, light switches, circuit breakers, duplexes and other convenience receptacles, environmental and appliance controls, plumbing fixture controls, and security and intercom systems.
Operable parts have three requirements:
1) They must be within reach ranges as spelled out in the Section 308
2) They must have a 30″x 48″ clear floor space to reach the operable part as specified on 305. The clear floor space should have a slope no steeper than 1:48 (2%) in all directions.
3) and the operable part should be the type that will not require tight grasping and twisting of the wrist and no more than 5 lbs, like explained before.
Below are some more examples.
Fire Extinguisher cabinet
I get this question a lot about fire extinguisher cabinets:
“Do we mount the cabinet so that the top of the fire extinguisher is between 15″-48″ a.f.f.?”
The answer is no. The reach range is for “operable parts” of fixed elements. So a fire extinguisher would not be the operable part, but the handle to open the cabinet would be. So one should locate the fire extinguisher cabinet door handle between 15″-48″ a.f.f.
Emergency Nurse calling
Another operating mechanism that is confusing is the emergency call button located in medical care facilities and long term care facilities. They are used when a patient or resident needs a nurse. They are typically located next to the toilet and in the shower and they are required to have a string that reaches the floor. The string is used if a patient or resident falls and they need to pull the string if they can’t get up.
In order for the call button to be compliant, it must not only have the string, but it should have a second way of calling the nurse which will not require tight grasping and pulling.
Adjustable mechanism at the hand held shower
One of the operating mechanism that is forgotten is the one required to adjust a hand held shower unit.
Once the height is adjusted, the mechanism to loosen or tighten the adjustable part is not always used again. But the initial action to adjust must meet the requirements. So the adjustable mechanism must also comply.
Need Barrier Free CEUs?
We are giving classes in the following locations:
Thursday August 9th 12:30-1:30 “APPLYING THE ADA AND AVOIDING VIOLATIONS IN ACCESSIBLE DESIGN”
Green CE On Demand Webinar: “Understanding the 2010 ADA Standards for Accessible Design”
Green CE On Demand webinar “How Accessible is Your work place?”
Green CE On Demand webinar “ADA and Residential Facilities”
AIA U online course: “Applying the ADA on Existing and Altered Buildings”
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The 2010 ADA Standards for Accessible Design has a section 217 which tells us which telephones are required to comply with the standards. The ones listed are coin-operated public pay telephones, coinless public pay telephones, public closed-circuit telephones, public courtesy phones, or other types of public telephones.
Most people assume the ones that are required to comply are “pay” telephones
But there are many others that are required to comply that we don’t always think about. As the list above explains, not just pay telephones, but also courtesy phones, and “other types”. Other types will also include emergency calling devices.
Requirements for Accessible Telephones
The ADA section 217 states that the telephones and calling devices that are required to comply should follow section 704
Section 704 tells us the following:
1) At least one of the telephones must be designed for the use by people who are in wheelchairs.
a) A 30″x48″ clear floor space must be provided. The clear floor or ground space shall not be obstructed by bases, enclosures, or seats
b) If the clear floor space is positioned for a parallel approach, it should be located as shown in the figure below
c) If the clear floor space is positioned for a forward approach, it should be located as shown in the figure below
c) Operable parts shall comply with 308 and 309. Telephones shall have push-button controls where such service is available.
d) The cord from the telephone to the handset shall be 29 inches (735 mm) long minimum.
2. The telephones should also be designed for the hearing impaired to have the ability to use it. Some telephones are required to provide volume control and TTY (An abbreviation for teletypewriter)
a) All public telephones are required to have volume controls. Volume controls shall be equipped with a receive volume control that provides a gain adjustable up to 20 dB minimum. For incremental volume control, provide at least one intermediate step of 12 dB of gain minimum. An automatic reset shall be provided.
b) TTYs required at a public pay telephone and shall be permanently affixed within, or adjacent to, the telephone enclosure. Where an acoustic coupler is used, the telephone cord shall be sufficiently long to allow connection of the TTY and the telephone receiver.
Emergency Calling Devices
Emergency calling devices are not specifically scoped in the 2010 ADA Standards. Some have considered these emergency calling devices to be subject as a two-way communication element if they only allow communication between the called and one party. The standards only address two-way communication systems under 230 and 708 where admittance to a building or restricted space is dependent on the two-way communication system. The closest similar device for these emergency calling devices is a “closed circuit telephone” per the definition section of the standards.
Closed circuit telephones must also comply with the requirements listed above and in section 704. But volume control is not a common feature for these devices. The use of the variance process in Texas is the only way you can achieve compliance. In the ADA there is no variance process and therefore when providing devices that are not fully compliant, you can use “equivalent facilitiation” to achieve compliance and documenting this within the owner’s organization.
The telephones that are required to comply are not just the public pay phones that we are used to seeing in public buildings. There are many more types of telephones that are provided in different facilities that require compliance. Airports, Hotels, schools and other places of public accommodations will provide a “courtesy” or “emergency” phones and will also require compliance with the ADA Standards so that persons with different disabilities can also communicate.
Seats are not always required at bathing facilities, but there are some situations that will require showers seats to be added. For instance, a transfer shower always requires a seat. Also, in transient lodging facilities (hotels, halfway houses, dorms), a seat is required not only in transfer showers but also in roll-in showers.
The shower must be permanently attached to the shower and not be movable. The one exception will be at residential facilities which require blocking for future seats.
This article will explain how the seat should be installed and how it affects the location of controls and other elements.
There are two types of showers: Transfer showers and roll in showers. Transfer showers are one’s people with mobility impairment will “transfer” onto. Roll-in showers are the ones that a person in a wheelchair will roll their wheelchair into.
ADA Section 608.4 requires permanent shower seats in transfer showers.
Roll-in showers are not required to provide a shower seat per section 608.4. There are two exceptions where seats are required to be provided in roll-in showers:
Sections 610.3 describes the types of seats allowed at showers. There can be a rectangular seat or an “L-shape” seat:
1) Where a seat is provided, the seat shall extend from the back wall to a point within 3″ of the compartment entry.
This seat did not extend from the back wall to 3″ of the entry
The seat is 9″ away from the entry
Sometimes, the seat is located around a gyp wall and the shower sits back a few inches. So do we consider the wing wall part of the shower when measuring the location of the seat? According to the Texas Department of Licensing, the shower begins at the shower pan and therefore the wing wall is not counted as part of the shower.
2) The top of the seat shall be 17″-19″ above the bathroom finish floor.
3)They can be rectangular meeting figure 610.3.1
This seat is 4″ away from the end wall rather than 1 1/2″ max
4) Or they can be “L-shape” meeting figure 610.3.2
5) The structural strength should be able to sustain 250 lbs of applied force on the seat, fastener, mounting device or support structure.
There are two types of roll in shower configurations allowed by the ADA. The shower seat location in these showers will dictate where the controls and grab bars will be located.
The Standard Roll-in shower with seat:
The alternate shower with a seat. An alternate shower is a combination of a transfer shower and roll in shower, so it is larger in depth than a standard roll-in shower.
The photo above shows an alternate roll-in shower
Depending on where the seat is located, the controls must be located no farther than 27″ away from the seat.
Clear Floor Space
In order to transfer onto the seat, there should be a clear floor space that meets the requirements at 305 parallel to the shower seat. The requirements include the size to be 30″x48″ and that the slope is not steeper than 1:48.
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The 2010 ADA Standards states that only stairs that are part of a means of egress must comply with the ADA sections 504 and 505. That means that grand stairs that are typically found in a lobby of an office building, for example, will not have to comply because typically are not part of a means of egress according to the building code.
ADA 210.1 General. Interior and exterior stairs that are part of a means of egress shall comply with 504
What happens when a stair that is part of a means of egress is getting modified or altered?
According to ADA Section 210 Exception #2, in alterations, existing stairs between levels that are already connected by an accessible route (like an elevator or ramp) is not required to comply with 504, except for the handrails. The handrails will have to be brought up to compliance with ADA section 505.
What if you add a new adjoining stair between floors?
A typical scenario that has been occurring in office buildings is that a tenant will take two floors and create a connection within their suite with an adjoining stair.
If the stair did not exist in the space before, and even if the building core has an elevator, an accessible route will be required in the same area. That means that an elevator or wheelchair lift would also would have to be installed in the suite.
It would not be acceptable to make a person in a wheelchair exit the space and find the elevator in the core and then re-enter the space on the upper floor.
The Texas Department of Licensing and regulation wrote a technical memo to explain their position. Click here for the memo