Ramps and Curb Ramps

Wednesday, September 20th, 2017

ADA Section 405 Ramps and 406 Curb Ramps

We all know that one of the ways that people in wheelchairs maneuver between changes in level greater than 1/2″ is by using a ramp. When an accessible route crosses a curb, it requires a “curb ramp”. There is confusion between requirements for ramps vs. curb ramps. Let’s see if we can make it more clear:

1. The first thing to remember is that curb ramps are also ramps. The main difference is that a “curb ramp” is located at a curb and a “ramp” is located elsewhere (like along the route to the front door, or on the interior of the building)

The curb ramp is the one that crossed a curb at the parking spaces. The ramp in the background is part of the entry and does not cross the curb


2. Both ramps and curb ramps require a maximum running slope of 1:12 and a maximum cross slope of 1:48 (per 405.2 and 405.3)

Cross slope

running slope


3. Both ramps and curb ramps require that the surface be stable, firm and slip resistant and should not have changes in level at ramp runs. (per 405.4)


4. Both ramps and curb ramps require a minimum clear width of 36″ (per 405.5). The width is measured inside the handrails if they are provided.


5. and Both ramps and curb ramps and their landings require that they do not accumulate water. (per section 405.10)


The curb ramp shows water accumulated

The curb ramp shows water accumulated

Those are the only requirements that they share. There are other requirements that only apply to Ramps and some that only apply to Curb Ramps.

ADA Section 405 Ramps

Besides all the items listed above, ramps have other requirements.  These requirements only apply to ramps and NOT to curb ramps:
1. Only a ramp cannot have a vertical rise greater than 30″ without a landing.  In other words, if a ramp rises more than 30″ it must have a landing before the next run begins (per section 405.6)
2. Only a  ramp requires flat landing at the top and bottom of the ramp run (per section 405.7).  Flat can be no steeper than 1:48 that is 60″ deep and the width of the ramp (like the figure shown above).  Only a ramp requires a 60″x60″ landing when it changes direction
3) Only a ramp ramp requires handrails on both sides (except if the rise is less than 6″).
4) Only a ramp requires edge protection if there is a drop off on either side of the ramp. So even if a curb ramp is higher than 6″ in vertical rise, it will not require handrails.

ADA Section 406 Curb Ramps

Curb ramps have the following unique requirements that regular ramps do not require:
1. Only a curb ramp requires that the bottom of the ramp have a slope no steeper than 1:20.  This is called a counter slope.  (Per section 406.2).  A regular ramp will require a landing at the bottom with a slope no steeper than 1:48 in all directions.
2. Only a curb ramp requires its side have flares if located along a walkway.  The flared sides are not required, but if they are provided they must comply with section 406.3
Flare sides are recommended if the curb ramp is located within a path of travel. This would prevent any tripping.  Since the flared sides are not “required” a parallel curb ramp is allowed to be used.


this curb ramp is parallel with the curb and no flares are required

3. Only a curb ramp requires a 36″ deep landing at the top.  The slope of that landing is not specified and it would depend on where is it located.  For example, if the curb ramp terminates at a sidewalk that is parallel to the ramp, then the slope could be as steep as 1:20 (5%).  But if it is located so that the ramp and the walkway are perpendicular, then the landing must not have a slope steeper than 1:48 since it will also be part of the cross slope of the sidewalk. (per 406.4)
4. Curb ramps and the flared sides cannot project onto a vehicular way or parking spaces and access aisles. (per section 406.5)

this curb ramp did not require the flared sides_ and the one_s provided project onto the vehicular way

5.  A diagonal curb ramp will require a counter close 48″ in length and located outside of the traffic area (per section 406.6)
6. When curb ramps are located in a traffic island or median, then the landing must not interfere with another curb ramp.  A 48″ space along the direction of travel must also be provided (per section 406.7)

Curb Ramps at Public Rights of Way

 If you are wondering why we haven’t mentioned detectable warnings (i.e. contrasting color and texture/truncated domes), it is because curb ramps do not require them anymore.  Some Departments of Transportation in different States have adopted a Public Right of Way Guidelines that give us a scoping for when the detectable warnings are required.
Basically any curb ramp located inside the property line will not require detectable warnings.
Any curb ramp that is located in the public right of way will require a portion of the ramp to have detectable warnings.  The bottom 24″ of the curb ramp must have the truncated domes and the contrasting color.
Check your municipality on what they have adopted to see if their curb ramps need it.

Helping Houston

Abadi Accessibility will be donating 5% of the fees received in the month of September to help the victims of hurricaine Harvey.  Thank you for your assistance!
Need Barrier Free CEUs?
September 18-  TAID Day of Education: “Common mistakes in the Texas Accessibility Standards” at the Dallas Market Center
Save the dates: October 24 and 25th- “Barrier Free Design Room by Room” 2 hr Barrier Free HSW class at Inspire! 2017, Dallas Texas
Online courses:
Green CE On Demand webinar “How Accessible is Your work place?”
Green CE On Demand webinar “ADA and Residential Facilities”
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:
book cover
If you have any questions about these or any other topics, please feel free to contact me anytime.
Marcela Abadi Rhoads, FAIA RAS #240
Abadi Accessibility
214. 403.8714

The Requirements for Accessible Mezannines

Tuesday, June 6th, 2017
When determine an accessible route between levels, a question frequently comes up about mezzanines or half levels.  The question is, do you need an accessible routes to mezzanines?
First we have to define what a mezzanine is. According to the 2010 ADA Standards a mezzanine is defined as:
An intermediate level or levels between the floor and ceiling of any story with an aggregate floor area of not more than one-third of the area of the room or space in which the level or levels are located. Mezzanines have sufficient elevation that space for human occupancy can be provided on the floor below.
So a floor or story that is only one-third the size of the area below it will be considered a mezzanine. Generally, an accessible route must connect each story and mezzanine.  But there are exceptions.
Generally, an accessible route must connect each story and mezzanine. However, there are exceptions.
In a privately owned multi-story building, per ADA section 206.2.3 an accessible route is not required if:
a) the building has less than three stories OR
b) if the building has more than three stories but each story is less than 3,000 s.f. per story.
This only applies if the building is not a “shopping center, a shopping mall, the professional office of a health care provider, a terminal, depot or other station used for specified public transportation, an airport passenger terminal, or another type of facility as determined by the Attorney General.”
In a publicly funded multi-story building, an accessible route is not required if it is a two story building and one of the stories has an occupant load of five or fewer persons.
But since a story is not a mezzanine, there is also an exception specifically for mezzanines: Per ADA section 206.2.4 exception 3,  If you have a one story building and it has a mezzanine within (per the definition of a mezzanine), then no accessible route will be required to the mezzanine.

The photo above shows a one story building, and even though it is a shopping center, the second story is actually a mezzanine and will not require an accessible route to it. It is advisable that a route be provided, since a person with disabilities might want to shop on the mezzanine and should not be denied access.
The second story in this “one story” fitness center shown in the photo above is less than one-third of the space below and therefore is considered a mezzanine. An accessible route to the mezzanine is not required
Mezzanines in Restaurants and Cafeterias
According to ADA Section 206.2.5  an accessible route shall be provided to all dining areas, including raised or sunken dining areas, and outdoor dining areas.  But if there is a dining area located on a mezzanine that contains less than 25% of the total combined area for seating, and if the same decor and services are provided in an accessible part of the restaurant, then an accessible route is not required to the mezzanine.
Mezzanines as part of a work area
A “work” area is where employees perform work.  Even though the work area is not open to the “public” it is not entirely exempted from the Standards.  According to the ADA a work area is required to have an approach, the ability to enter and to exit.
So what happens when you have a mezzanine within a work area that is used for work?  If it is a one story building and the work area on the second level is less than one-third the area below, then it will not require an accessible route up to it.
The photo above is a one story warehouse with a mezzanine for storage. Even though the space above is a “work” area, because it is a mezzanine it does not require an accessible route.
Note: A mezzanine that is used to house mechanical equipment is always exempted no matter how large it is.

Employee Work Areas

Monday, May 2nd, 2016
A work place can be complicated to understanding as it pertains to the requirements for accessibility. Some spaces in work areas are exempted while some require full access.  Because the ADA requires that a person with disabilities is given the same opportunity to seek employment, an employer may not decide that his establishment will not employ persons with disabilities, and therefore will not make the work areas accessible. So what does the ADA require the employer to provide?
This newsletter will  give an overview of what requirements exist in the ADA about work areas and when the ADA Standards apply.

Work Areas

According to the ADA the definition of an employee work area is:
Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.
Work Area Equipment. Any machine, instrument, engine, motor, pump, conveyor, or other apparatus used to perform work. As used in this document, this term shall apply only to equipment that is permanently installed or built-in in employee work areas. Work area equipment does not include passenger elevators and other accessible means of vertical transportation.
Per the 2010 ADA Standards for Accessible Design:
203.9 Employee Work Areas. Spaces and elements within employee work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area.
An example of a work area that only requires an approach, enter and exit would be a janitor’s closet.  Elements within the janitor’s closet such as the faucet for the mop sink will not be required to comply.
An exam room is partially a “work” area and partially a “patient” area.  The area that is only used by the doctor (the sink) will be exempted from having to comply.
Employee work areas, or portions of employee work areas, other than raised courtroom stations, that are less than 300 square feet and elevated 7 inches or more above the finish floor or ground where the elevation is essential to the function of the space shall not be required to comply with these requirements or to be on an accessible route.

This toll booth is less than 300 s.f. and elevated more than 7″ a.f.f. and therefore do not require an accessible route to it or the ability to approach it and enter it.

The Standards sometimes provide additional guidance through “advisories”.  These are NOT requirements, but they are suggestions that might make your design a better one.  Below are some of the advisories on work areas:

Advisory 203.9 Employee Work Areas. Although areas used exclusively by employees for work are not required to be fully accessible, consider designing such areas to include non-required turning spaces, and provide accessible elements whenever possible. 

Under the Title I of the ADA, employees with disabilities are entitled to reasonable accommodations in the workplace; accommodations can include alterations to spaces within the facility. Designing employee work areas to be more accessible at the outset will avoid more costly retrofits when current employees become temporarily or permanently disabled, or when new employees with disabilities are hired. 


In addition to approach, enter and exit, the employee work area shall also comply with the following sections of the ADA Standards: 206.2.8, 207.1, and 215.3. These will be explained in detail below.

206.2.8 Employee Work Areas. Common use circulation paths within employee work areas shall comply with 402.


The circulation path should meet the requirements for ADA Section 402 which includes a minimum 36″ width along the circulation path.


1. Common use circulation paths located within employee work areas that are less than 1000 square feet (93 m2) and defined by permanently installed partitions, counters, casework, or furnishings shall not be required to comply with 402.2.


This employee work area is less than 1,000 s.f. and therefore the step is allowed

Common use circulation paths located within employee work areas that are an integral component of work area equipment shall not be required to comply with 402.3.

This commercial kitchen has equipment that is an integral part of the work area.  The 36″ min. circulation path in this space is not required to comply due to the location of the work area equipment.

Advisory 206.2.8 Employee Work Areas

Exception 2. Large pieces of equipment, such as electric turbines or water pumping apparatus, may have stairs and elevated walkways used for overseeing or monitoring purposes which are physically part of the turbine or pump. However, passenger elevators used for vertical transportation between stories are not considered “work area equipment” as defined in Section 106.5.


An accessible route/circulation path up to the elevated walkway used to monitor work area equipment is not required to be provided.

Common use circulation paths located within exterior employee work areas that are fully exposed to the weather shall not be required to comply with 402.


A dumpster is considered an extension of a work area.  Although a circulation path within the work area might be required, because the dumpster is located on the exterior and fully exposed to the weather, a circulation path will not be required.

Advisory 206.2.8 Employee Work Areas Exception 1. Modular furniture that is not permanently installed is not directly subject to these requirements


The modular furniture in an open office is not required to be installed so that there is a minimum 36″ width is provided.  They are essentially exempted from having to comply (unless they are permanently attached to the ground or wall)

207.1  Employee work areas are required to have an accessible means of egress per the requirements in the IBC

215.3 Employee Work Areas. Where employee work areas have audible alarm coverage, the wiring system shall be designed so that visible alarms complying with 702 can be integrated into the alarm system.

Employee Areas that are not work related

The requirements thus far have been for areas that are considered part of the “work” areas in a space.  But there are other areas that are also part of an employee area, but are not related to the work they perform.  Those areas that are NOT related to their job description will not be exempted and must comply.  Below are a few examples of areas that might be for employees only, but must be fully compliant with the Standards:

Break Rooms


The sink in this break room and the height of the counter are required to comply.  The microwave shown in this photo is not permanently attached and therefore the reach range is not required to comply.

LEED Showers for employees


Some showers that are accessed through a private office have less requirements.  But if it is a common use shower for all employees to use, then they must comply with section 608

Employee Restrooms


All restrooms including employee restrooms must comply with the requirements in Sections 603-606

Employee Locker Rooms


The lockers as well as the bench in this locker/dressing room must comply with the Standards

Employee dining counters

5% of the dining counter is required to be between 28″-34″ a.f.f. and provide a knee space like the photo above.
Employee parking
Parking that is designated for employees should have accessible spaces as well.
Vocational schools where they teach how to use certain “work area equipment” is not exempted.  Because it is considered a “public accommodation” , the equipment or access to it will have to be provided.  Sometimes that is not reasonable, and at that situation, the school will have to get a variance from TDLR or provide reasonable accommodations for the students with disabilities

Barrier Free Day in Dallas Texas

Experience what it is like to have a disability and be in a work space.  The AIA Dallas Codes and Standards Committee is having their annual Barrier Free Day this May 5th.  If you would like to participate, please sign up today.  If you would like to just get a 1 hr. Barrier Free CEU, join us at the happy hour where participants will share their experience of their day with a disability.
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Need CEUs

May 5th- Barrier Free Day Panel Discussion  5:30-7:30 at the Eberhard 2107 N. Henderson Dallas Tx 75206 1 hr. HSW Barrier Free CEU
May 23-27th  Building Industry Professionals: University of Texas at Arlington 416 Yates Street Arlington, TX 76010
May 24th: Legal and ADA issues of Practicing Architecture at Building Industry Professionals Conference, Arlington Texas
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:

They are available for sale now. (also available as an e-book)

If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Public Right of Way

Tuesday, September 1st, 2015

The ADA and TAS have requirements for building entrances.  The building code also has requirements for means of egress.  Both ADA and the building code connect entrances and means of egress to either a public way or a public street.  This newsletter will explain the difference between a public way and a public street and will give examples of how these can be applied to our accessible designs.

Definition of Public Way

The ADA defines a “Public way” as follows:
Public Way. Any street, alley or other parcel of land open to the outside air leading to a public street, which has been deeded, dedicated or otherwise permanently appropriated to the public for public use and which has a clear width and height of not less than 10 feet (3050 mm).
 If you notice the  definition, in addition to the public way being a street or alley, it also speaks about “other parcel of land open to the outside air leading to a public street” .  

But what does that mean?  My very smart client Josh Williams from D2 Architecture pointed out to me that  “other parcel of land” could be a parking lot that is located within the property line as long as it is open to the outside air and connected to a public street.  A parking garage would not meet that definition.


Public Way and Accessible Means of Egress

When designing an accessible means of egress, you are required to create a continuous and unobstructed path of travel to a safe area for a person with disabilities to reach in case of an emergency.
The definition of this path of travel is:
Accessible Means of Egress. A continuous and unobstructed way of egress travel from any point in a building or facility that provides an accessible route to an area of refuge, a horizontal exit, or a public way.
An accessible means of egress can terminate at a public way.  As we saw on the previous section, the public way can be a parking lot.
This parking lot is an acceptable “public way” for the purposes of providing a route for an accessible means of egress from the shopping center to the right.

Public Way and Accessible Route

Although, as we read in the previous section, an accessible means of egress is only required up to the “public way”, an accessible route has to connect the buildings or facility to a site arrival.  A site arrival would also include public sidewalks and public transportation stops even if they are outside the property line.
206.2.1 Site Arrival Points. At least one accessible route shall be provided within the site from accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; and public transportation stops to the accessible building or facility entrance they serve.
Even though this bus stop is not within the property line of the shopping mall that we see behind it, it must have an accessible route from the bus stop to the mall entrance.
1. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, no more than one accessible route from a site arrival point to an accessible entrance shall be required.
2. An accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing pedestrian access.
 This photo shows a building but no pedestrian access.  This would not require an accessible route all the way to the street.

Upcoming Continuing Education Opportunities

November 5 and 6: “Texas Accessibility Standards: A Success story of inclusion for over 20 years” TSA convention in Dallas, Texas (pricing for the convention go up on September 2nd)

If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes

If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide”  “Applying the ADA” published by Wiley. 



 They are available for sale now. (also available as an e-book)
If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Useful Links

Disney Impresses with Accessibility

Thursday, August 20th, 2015

My family and I just finished our first vacation to Disney World! We had such an incredible time riding all the rides, eating all the junk food and navigating our way around the various theme parks. My children did have to endure a few embarrassing “mom” moments, however — more than most kids usually have to put up with on a family vacation. In addition to enjoying our first Disney adventure, I made it my mission to document some of the new amusement park requirements in the 2010 ADA, which meant standing in line a few extra minutes to wait for any accessible seats, photographing complete strangers without their knowledge, and a few other tasks that completely shamed my children. Isn’t that what most parents do when they take their family to the happiest place on earth?

The Results Are In

The results of my undercover mission were quite impressive. It was truly amazing to me how accessible the entire Disney system was. There were so many people using wheelchairs and other mobility aids, not to mention people who had temporary mobility issues and even baby strollers. I was very impressed with Disney for how sensitive and accommodating their parks were for persons with disabilities.

Common Areas

As with any public accommodation, an amusement park has common areas that are open to the everyone and therefore must be in compliance. Disney succeeded in all areas, from the transportation system to restrooms to accessible ramps throughout every park. Take a look for yourself:

Designated loading areas at every bus stop and on every bus.


Accessible restrooms throughout every park.

Ramps along all routes.

Lifts and other means of entry in the swimming pool areas at each of the resorts.


Accessible dining surfaces and seating at the attractions in abundance.

Accessible Rides

The 2010 ADA devotes an entire section to creating accessible amusement park rides. With special spaces designated for people in wheelchairs, companion seats, accessible loading areas and ramps, Disney passed with flying colors.

Dreams Come True…For Everyone

I’m pleased to share that our first family trip to Disney World was a rousing success. Disney has created an accessible place where everyone can enjoy a magical experience, including my family, who, I’m proud to say, survived the entire vacation with their “crazy mom on a mission.”

Because the standard requirements for amusement parks are very detailed, I encourage you to study the 2010 ADA. You may also read more in my books:

“The ADA Companion Guide”

“Applying the ADA” published by Wiley.

They are available for sale now. (also available as an e-book)

Inspector’s Corner

Monday, August 3rd, 2015

July 26th, 2015 was the 25th anniversary of the ADA.  On July 23rd the AIA Dallas organized an awareness day exercise called “Wheelchair in A Day” where we asked 10 architects to sit in a wheelchair and record their experiences throughout the day.  The day was a huge success and the stories they retold were so important.  This newsletter will give you a few examples of the participants.


Thank you to Bob Bullis, AIA; Beth Brandt, AIA; Daivd Dillard, FAIA; Bob Borson, AIA; Peter Darby AIA, Laurel Stone, Amanda Adler, Jason Dugas, AIA for participating and for sharing your experience with the rest of us!

Traveling by Airplane on a wheelchair

AIA Dallas President Bob Bullis, AIA participated in the “Wheelchair for a Day” event.  He had a meeting in Houston which he decided to keep.  So he flew in his wheelchair and tweeted about his experience.  We asked him what was his biggest challenge.  He told us about his trials with TSA….and I will not get into the “search” pat down he received…Southwest Airlines was very accommodating, and allowed him to remain in the chair so he could experience what it was like.  He got to go to the front of the line and board first.


He liked the feel of the Terrazzo flooring the best….easier to push on.  But noticed that even the slightest slope was hard to navigate



Being in the office and going out to lunch

Two architects experienced their day in a wheelchair: Bob Borson, AIA and David Dillard, FAIA

Bob Borson, AIA experienced his day in the office doing his typical duties: making copies, taking drawings from his car to his desk, and even going out to lunch.  All a very eye opening experiences….read his blog post for a more detailed account


I bet Bob was glad that the doors of his office had the proper widths and maneuvering clearances 


When Bob wen out to lunch here is what he experienced 

Next challenge? Going out to lunch. Again, long arms to the rescue, but I am acutely aware of how freakishly long my arms are and as a result, I am acutely aware of how difficult going through a cafeteria line would be for people who don’t have the physical proportions of a simian. “ 


Taking the tray back to his table was a big challenge…glad he didn’t drop his food!


when he got to his table he noticed that there was no place for a wheelchair except at the end….he made everyone move and find a better table (It’s good to be the boss)


David Dillard, FAIA also stayed in his office and also experienced his daily routine in a wheelchair.  Meetings are easier when you are the designer of the office and make accommodations…Good job David!


David also had doors he had to maneuver…although his experience was different since he had an electric wheelchair


The City of Dallas didn’t plan properly the locations of stop signs and fire hydrants.  David found them right in the middle of his accessible route.  I bet those were fun to maneuver.


At lunch they found a restaurant with a wheelchair lift that accommodated him so he could dine with his colleagues


Experiences like these makes architects and designers more sensitive to the people they are designing for.

Taking public transportation

The last example was of our friend Peter Darby, AIA who decided to spend his day in a wheelchair navigating the public transportation system in the City of Dallas


Peter rode in buses, light rail, taxis and even Uber

“Quite a few impediments today. Blocked, Crooked pavements or sidewalks to nowhere! “


He experienced getting onto light rail via ramps


And buses


Getting assistance from rail operators


It takes so much longer to get from point A to point B when you are in a wheelchair taking public transportation, but most people with disabilities, especially visually impaired people use public transportation to get around.  It is so important that we have these accommodations to enable them to be independent and as sense of dignity and empowerment.

Upcoming Continuing Education Opportunities

August 7, 2015 Accessibility Professionals Association Regional training Plano, Texas

8:00 – 10:00 am- Difference between TAS and ADA Standards- 2 CE/LU/HSW

10:15 am -11:15 pm-  Retail Stores and Spaces- TDLR 1 CE #13464, AIA #155 1 LU/HSW- Detail Review of Retail Spaces Barrier Removal;Common errors; Path of Travel Requirements; Retail Accessible Parking and Accessible Routes,

August 13, 2015 Metrocon 15

An ADA Case Study of Existing & Remodeled Interiors
11:00 a.m. and 1:00PM

If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes

If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide”  “Applying the ADA” published by Wiley. 



 They are available for sale now. (also available as an e-book)

If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Useful Links




Accessible Airports

Wednesday, September 24th, 2014

Americans love to travel.  Travelling gives us the freedom to go to different destinations and experience different places.  People with disabilities also travel, and as such, the airports must be accessible.  For designers and airport operators, it is sometimes confusing what accessibility guidelines should be followed.

Under Part 382 of the Air Carrier Access Act (ACAA), air carriers are responsible for airport facilities or services that they “own, lease, operate, or otherwise control. The facilities, according the ACAA should follow the ADA Title III in those areas that are considered public accommodations and commercial areas.

Although the ADA’s statutory language exempts transportation “by aircraft:, airport terminals owned and operated by government entities are covered by Title II of the ADA which requires that the services are made available, and airport terminals open to the public are “public accommodation” covered by Title III of the ADA which requires building access. Both are subject to ADA access requirements of the Americans with Disabilities Act Accessibility Guidelines (ADAAG).

Additionally, airports that receive federal financial assistance are subject to Section 504 of the Rehabilitation Act. According to the U.S. Department of Transportation (DOT), “in order to be in compliance with Section 504, recipients must also be in compliance with all applicable regulations under the ADA.”

This newsletter will try to explain what those regulations.

Ticket Counters and Information Desks

Ticket counters and information desks outside the secured area fall under the ADA section 904 and possibly 902 since they are a public accommodation.  Section 904 discusses service and sales counters.  If the ticket counters are used for selling tickets or to provide some type of service, such as information, getting boarding passes, or checking in bags, those counters will require that a portion of the public side of the counter be no higher than 36″ a.f.f., and no shorter than 36″ in length.  A parallel or forward approach is allowed.


This ticket counter does not have a portion at 36″ a.f.f. , although the area where the baggage is turned in is open and lower.  It could be argued that the entire counter is part of the work area for the ticket agent, but in reality it is also where a customer approaches the ticket counter to receive their boarding pass or baggage claim stubs. This is not a compliant service counter.


This ticket counter has a shallow counter that is at 36″ a.f.f. which was allowed by the 1991 ADAAG and it is a safe harbor, but a person with disabilities will have difficulty communicating with the ticket agent since the ticket counter is higher than 36″ a.f.f.

More and more you find that self service check in are being offered.  A passenger will not approach a ticket counter but a self service kiosk.  These should be within reach range per section 308 of the ADA.  There are other requirements that these might need for people that are visually impaired.


Self-service kiosk systems clearly fall within the ACAA encompassing language, which incorporates the Americans with Disabilities Act (ADA) Title III standard for accessible design.  This means that these kiosks should meet the reach ranges specified by the ADA but in addition it should have similar privacy requirements as the ATMs do. The kiosks should have the ability to communicate with the visually impaired as well s the hearing impaired patrons.  This is not yet happening, but the industry is aware of the deficiency and will hopefully act on that in the near future.


In the same area as the ticket counter there might be counters for filling out baggage tags.  These would fall under the ADA Section 902.  5% of the counters must be accessible and have a forward approach.  They should be no higher than 34″ a.f.f and they should have a knee space complying with ADA section 306


Other areas of the airport might have information counters.  Those will fall under the service counters of ADA Section 904.  They should also have a portion at 36″ a.f.f. so that a passenger can communicate with the person behind the counter.  According to 904.4 the accessible portion of the counter top shall extend the same depth as the sales or service counter top.  Therefore a separate counter attached to the front of the service counter may not be used.


Car rental counters are also considered a service counter and are required to be accessible and follow ADA Standards section 904


Terminal Gates

Once a passenger passes through security and is at their gate, the counters at the gate are also required to follow ADA section 904.  The counter shown on the picture below followed the 1991 ADAAG which allowed a separate counter to be used which was not the same depth as the service counter itself.  Like we explained above, these separate counters are difficult for persons with disabilities because they cannot easily community with the agent behind the taller counter.  That is why the 2010 ADA Standards requires that a lower counter which is the same depth as the main counter be provided.


At the gate, sometimes the air carriers offer tables for people to use which they wait for their plane to board.  These would fall under ADA Section 902 as a non-employee work surface.  These should have a portion of the counter at 34″ a.f.f. maximum and have a knee space per section 306.


If there are power outlets located at the counter, those should be within reach range.


Jet Bridge and Airplanes

At the terminal gate, passengers go through a door and enter the Jet bridge. This is essentially a movable piece of equipment which allows passenger to board the plane. This is technically not part of the airport and will not fall under the ADA. The requirements for the jet bridge, the slope, handrails etc. will be found in the ACAA. Same with the requirements for inside the airplane. People with disabilities do not enter the plane on their own. There are procedures that air carriers follow with all their passengers with disabilities.


Upcoming CEU opportunities

Note: We will be closed on September 25 and 26

September 4- How to Make Interior Spaces Accessible TAID 1-3 p.m.

September 9- Procrastinator’s Day Barrier Free Seminar at AIA Dallas

November 6- Early Bird Three Hr Seminar: Applying TAS in Existing and Renovated Buildings” at the TSA Convention in Houston Texas

November 13- Half Moon Class 10:45 a.m.

November 13- CSI Dallas Meeting 7-8 p.m.

We are celebrating our 10th year of service to the building industry as a Registered Accessibility Specialist!  Mention this newsletter and receive 10% off your next review or inspection.

If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide”

“Applying the ADA” published by Wiley. 

They are available for sale now. (also available as an e-book)

If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Useful Links

Accessible Amusement Parks

Sunday, August 24th, 2014

My family and I just finished our first family vacation to Disney World!  It was amazing to me how accessible it was.  There were so many people using wheelchairs and other mobility aids, not to mention people that had temporary mobility issues and even baby strollers.  I decided to document some of the new requirements in the 2010 ADA for amusement parks. I was very impressed with Disney for how sensitive and accommodating their parks were for persons with disabilities.





In this newsletter we will discuss the basic requirements that the 2010 ADA Standards require when building a new amusement park or renovating an existing.  An existing amusement park rides are exempted from having to comply.  If you want further information, refer to “Applying the ADA” chapter 7 which is an entire chapter on accessible amusement parks.

Common use areas at the Park

As any public accommodation, an amusement park has common areas that are open to the public which will have to comply.  At Disney World, this was achieved beginning with their transportation and throughout the park.  They had accessible bus stops, restrooms, accessible ramps throughout the park as well as accommodation at restaurants and other public areas.



Designated bus stop loading areas are available at every bus stop 



Every bus is equipped with areas designated for wheelchairs


Accessible restrooms were located everywhere in the park


Ramps were located along all routes, making them all accessible





Pool lifts and other means of entry were located in swimming pool areas at their resorts 


Accessible dining surfaces were available throughout the park


Several of the attractions in Disney World are shows.  They also had accessible seating and companion seating available at almost every show.

Accessible Amusement Rides

The 2010 ADA has an entire section devoted on creating accessible amusement rides.  The scoping states:

234.2 Load and Unload Areas. Load and unload areas serving amusement rides shall comply with 1002.3.

234.3  Minimum Number. 

 – Amusement rides shall provide at least one wheelchair space complying with 1002.4


This ride had a space designated for people with wheelchairs.  A companion seat was also provided alongside it.

This ride has a ramp that deploys and allows a person in a wheelchair to enter the ride. 


This photo shows an accessible loading area onto a boat ride


This photo shows the person in a wheelchair in the designated seat for persons with disabilities.


This is a train ride with a space for the wheelchair 


Companion seats are provided for the designated wheelchair spaces 

– or at least one amusement ride seat designed for transfer complying with 1002.5, 

– or at least one transfer device complying with 1002.6.


  1. Amusement rides that are controlled or operated by the rider shall not be required to comply with 234.3.
  2. Amusement rides designed primarily for children, where children are assisted on and off the ride by an adult, shall not be required to comply with 234.3.
  3. Amusement rides that do not provide amusement ride seats shall not be required to comply with 234.3. 

 The technical Standards have requirements for the following elements of the amusement rides.  They are very detailed and we encourage you to read up on them if you are designing amusement rides.

1002.2 Accessible Routes.  An Accessible route will have to be provided to the loading and unloading area

1002.3 Load and Unload Areas.

Here is a video showing how the load unload areas work

1002.4 Wheelchair Spaces in Amusement Rides

Here is a video showing a spot for the amusement ride together with companion seating next to each other


1002.5 Amusement Ride Seats Designed for Transfer.

1002.6 Transfer Devices for Use with Amusement Rides.

Kudos to Disney World for their commitment to persons with disabilities!

Upcoming CEU opportunities

August 5th- “Applying the ADA and TAS: Avoiding common violations” at AIA Dallas

August 14- “Avoiding ADA Violations during Construction” Metrocon in Dallas Texas

Sponsored by Accessibility Professionals Assocation

August 19- “Applying the ADA in Existing Buildings” Webinar for Green CE

September 9- Procrastinator’s Day Barrier Free Seminar at AIA Dallas

November 6- Early Bird Three Hr Seminar: Applying TAS in Existing and Renovated Buildings” at the TSA Convention in Houston Texas

We are celebrating our 10th year of service to the building industry as a Registered Accessibility Specialist!  Mention this newsletter and receive 10% off your next review or inspection.

If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide”

“Applying the ADA” published by Wiley. 

They are available for sale now. (also available as an e-book)

If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Useful Links

Accessible Entrances

Tuesday, June 24th, 2014

The 2010 ADA Standards requires that entrances be made accessible.  Not every entrance has to be, but there are requirements for the different types of entrances provided.  The following entrances are required to comply:

  1. Public Entrances
  2. Parking Structure entrances
  3. Entrances from Tunnels  or Elevated Walkways
  4. Entrances at Transportation Facilities
  5. Tenant Spaces
  6. Residential Dwelling Units (Not Fair Housing or ANSI)
  7. Restricted Entrances
  8. Service Entrances
  9. Entrances for inmates or detainees

The newsletter will explain how the accessibility requirements.

Public Entrances

ADA Section 206.4.1 requires that 60 percent of all public entrances shall comply with the door requirements listed in section 404.  A public entrance is defined as:

“An entrance that is not a service entrance or a restricted entrance”

This means that if the entrance is available for the general public to use, then it will be  a public entrance.



This is a tenant space with a tenant entrance


Parking Structure Entrance 

Each direct access to the building from the parking structure


Entrances from Tunnels or Elevated Walkways 

At least one direct entrance to the building must be accessible.


Transportation facilities 

At least one public entrance serving each fixed route or group of fixed routes

Section 404 explains the requirements for the doors located at the entrances.  There should be proper widths, proper hardware and maneuvering clearances.  If the doors are not on grade and a ramp is required to access them, a landing at the top and bottom of the ramp should be provided and should coincide with the maneuvering clearances a the doors.  The image below shows an entrance, but not accessible (even though it shows the universal symbol of access)  😉


Restricted and Service Entrances

A restricted entrance is defined as:

“Restricted entrance is an entrance that is made available for common use on a controlled basis but not public use and that is not a service entrance.”


At least one of restricted entrance to the building or facility shall comply with Section 404.


At least one primary entrance a residential dwelling unit that has to comply with ADA  shall comply. Residential dwelling units that is required to comply with ADA are group homes, homeless shelters,  faculty and director’s residences in places of education and sleeping quarters for emergency personnel.


Where entrances used only by inmates or detainees and security personnel are provided at judicial facilities, detention facilities, or correctional facility, at least one such entrance shall comply.

A service entrance is defined as:

“Service Entrance is an entrance intended primarily for delivery of goods or services.”


If a service entrance is the only entrance to a building or to a tenancy in a facility, that entrance shall comply with Section 404.  Otherwise it is not required to.

Public Comments wanted by TDLR

The Texas Department of Licensing and Regulation (Department) is reviewing the Elimination of Architectural Barriers rules (Title 16, Texas Administrative Code, Chapter 68) for re-adoption, revision, or repeal.

The Department will determine whether the reasons for adopting or readopting these rules continue to exist by answering the following questions for each rule:

* Is it obsolete?
* Does it reflect current legal and policy considerations?
* Is it in alignment with the current procedures of the Department?

The Department encourages anyone interested in the Elimination of Architectural Barriers program to review the Notice of Intent and current Chapter 68 rules online at

Comments may be submitted by email to

Deadline for comments-June 30, 2014

More information

Our offices will be closed on June 4th and 5th.

We are celebrating our 10th year of service to the building industry as a Registered Accessibility Specialist!  Mention this newsletter and receive 10% off your next review or inspection.

If you want to learn more about these standards, be sure to check out my books:

“The ADA Companion Guide”

“Applying the ADA” published by Wiley. 

They are available for sale now. (also available as an e-book)

If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Useful Links

The 2010 ADA Standards: A Landlord’s perspective

Monday, August 20th, 2012

The Americans with Disabilities Act became the civil rights law for disabled Americans in 1990.  Ever since then, the disabled community has been able to get jobs, enjoy independence and become productive members of our society.  The ADA is organized in five “titles”.  In this post we will focus on the Title III which requires that places of public accommodation and commercial facilities be made accessible to persons with disabilities.  We will also touch on Title I which states that a business cannot discriminate against a person with disabilities when they are hiring or firing.  They can’t decide not to hire someone or fire someone based on their disability.  In essence the ADA makes sure that persons with disabilities get treated equally.  So how does a building owner and landlord comply?

Part of the ADA required that places of public accommodation and commercial facilities be made accessible to persons with disabilities.  By this mandate, building owners had to make their buildings, new or existing accessible.  This requirement was sometimes more difficult than was first thought.  For newly constructed buildings, they had to make sure that their architect and contractor understood the requirements otherwise their building would not be in compliance and there could be a risk of complaints or worse, a law suit.  Ultimately it is the building Owner’s responsibility to make sure things comply, therefore hiring architects, interior designer and contractors that understand the rules, is a huge help.

There are different rules for new construction and remodels.  The rules for new construction are a bit simpler.  Whatever you build must be in compliance. It only gets complicated if the new constructed areas are spaces that are not required to comply.  Some examples of areas that do not require accessibility are mechanical rooms, telephone equipment rooms and electrical rooms.  These are exempted based on the fact that they are considered “machinery” spaces.  Those are spaces that only have equipment inside and only periodically gets monitored by an employee.

Another area of confusion during design and building are employee areas.  Employee areas are not necessarily excempted from having to comply.  I hear a lot of building owners say “nobody will ever go back there” when they speak of employee areas.  They are correct in making the statement because customers may not necessarily be allowed to go to an exclusively employee or staff area.  But what it is not clear is that their employees and staff will be going “back there” and using the facility.  This is where Title III of the ADA gets intermingled with Title I.  Title III recognizes that not every employee will need the facility to be accessible at the time construction is complete and that the business may not have a disabled person working there.  Therefore they are not required to provide accessible “work areas” or areas where the work is happening at the time the project is finished.  As soon as a disabled person wants to work there, or if (G-d forbid) an employee becomes disabled while working there, accommodations will have to be provided.  Thus the work areas are exempted from the Title III of the ADA except for the ability to approach the area, enter the area and exit the area.  For example, if there is a stock room or a copy room in an office space, those are considered work areas and only require approach, enter and exit.  The elements within the space, such as counters and shelving or even sinks,  will not be required to comply.

But it is not ALL employee areas.  This exemption is only allowed to be taken for work areas.  Therefore employee restrooms or employee break rooms are not exempted and must be accessible.  The reason is that these spaces are not part of the job description, but rather where they take breaks from work.  Private offices that have restrooms inside them, are also exempted for certain elements.  The restroom should have the proper clearances, but grab bars, knee space at sinks and knee spaces at sinks will not be required at the onset.

The next type of construction is an alteration.  This type of construction is a bit more complicated to decide what is required and what is not.  The first thing one has to determine is what area of the building is being remodeled or altered.  Does the area contain a primary function of the space?  If it does not, such as a restroom or a storage room for example, then only the new elements must comply.  So if a new paper towel dispenser in a restroom is getting added, or even if an entire restroom is getting remodeled, only the restroom must comply and nothing else outside the restroom, including the entrance to the restroom.  But if the answer is that yes, the area being altered contains a primary function, then the new elements and spaces must comply but in addition to the new elements, existing path of travel from the main entrance of the building must also comply.  If the existing path of travel contains restrooms, drinking fountains and public telephones, those also must comply with the ADA Standards.  In Texas, the Texas Accessibility Standards added parking to the list. Therefore the parking that serves the altered area must also be in compliance.

There is a new exception to this rule of the path of travel.  If the building owner is leasing the space to a tenant and the tenant is the one who is paying for the finish out, then the path of travel elements within the building that leads to the tenant space does not have to be brought up to compliance if they don’t already comply.   If the landlord pays for any of the tenant finish out via an allowance or any other financial means, then the same rules apply for the alteration of a primary function and the path of travel elements will have to be brought up to compliance.  Also, if the facility and the elements along the path of travel comply, but they comply with the old Standards (1991 ADAAG or 1994 TAS), then those are considered a “safe harbor” and also do not have to be brought up to compliance.

If during the alteration, it is discovered that the upgrade to the elements found along the path of travel would cost more than 20% of the total construction cost, the Department of Justice considers it “disproportionate”.  Due to disproportionality, the DOJ allows a postponement to the upgrades.   If the upgrades will be postponed, the DOJ requires that certain things be done in a certain priority level.  Costs that may be counted as expenditures required to provide an accessible path of travel may include:

1) Costs associated with providing an accessible entrance and an accessible route to the altered area, for example, the cost of widening doorways or installing ramps;

2) Costs associated with making restrooms accessible, such as installing grab bars, enlarging toilet stalls, insulating pipes, or installing accessible faucet controls;

3) Costs associated with providing accessible telephones, such as relocating the telephone to an accessible height, installing amplification devices, or installing a text telephone (TTY); and

4) Costs associated with relocating an inaccessible drinking fountain.

The DOJ has established a priority list of items that are required to comply and what priority to give them.  A building owner may not decide to fix the door hardware of interior doors before they fix the main entrance.  In choosing which accessible elements to provide, priority should be given to those elements that will provide the greatest access, in the following order:

(1) An accessible entrance;

(2) An accessible route to the altered area;

(3) At least one accessible restroom for each sex or a single unisex restroom;

(4) Accessible telephones;

(5) Accessible drinking fountains; and

(6) When possible, additional accessible elements such as parking, storage, and alarms.

Sometimes the best efforts finds that access cannot be accomplished because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame or because other existing physical or site constraints prohibit modification.  In those cases, speaking to local authorities and the DOJ to get a variance or waiver might be the proper action to take.  But even if it is not possible to provide access for wheelchair users, the building owner is still required to make sure other disabilities are accommodated.  Accommodations in buildings should be provided for the visually impaired, hearing impaired and people with other mobility issues such as walkers, crutches and braces.

With all the complicated rules and regulations that we might encounter during the design process, it is important to keep in mind the big picture.  What was the reason for all this extra effort?  Before the ADA was enacted, a person with disabilities was relegated to stay home or in an institution.  They depended on others for transportation and for every day tasks.  The ADA was enacted to  encourage and promote the rehabilitation of persons with disabilities, to eliminate unnecessary architectural barriers for persons with disabilities, to not restrict the ability to engage in gainful occupation and to not restrict the ability to achieve maximum personal independence.  As building owners we must keep in mind our customers and how at the end of the day we are opening our doors to a large portion of the population that wasn’t thought of before.  And the struggle will continue as Americans age and as more of us become disabled.  But these guidelines are universal.  When we remove barriers for one group, we are essentially removing barriers for everyone.  And the more architectural barriers we remove, the more cultural and social barriers we remove as well.

This post was published in the CREST Publications’s Network Magazine September 2012 edition