Title slide

Practical Applications of the 2010 Standards for New Construction -- Part 1

James A. Bostrom, Deputy Chief, Disability Rights Section, U. S. Department of Justice

Images: new 3-story building under construction; Department of Justice seal

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DOJ’s 2010 ADA Standards, Appendices B and D, to 36 CFR part 1191(2009) -- 2004 ADA Guidelines...and the requirements contained in § 35.151 and subpart D of 28 CFR part 36

Image: cover of the 2010 ADA Standards for Accessible Design, Department of Justice, September 15, 2010

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Title II - State and Local Governments

Images: construction site with the frame of a building being constructed; a large existing brick building with white triangular pediments and columns with Ionic capitals and multiple entrances

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2010 Standards for Accessible Design Requirements in 28 CFR 35.151 and

2004 ADAAG

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Title III – Businesses and Non-Profits

Images: inside a very tall hotel atrium, looking from below at a pair of lighted glass elevator towers and tens of floors with curved balconies; the glass front of the Newseum building

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2010 Standards for Accessible Design Requirements in 28 CFR part 36 subpart D

and 2004 ADAAG

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2010 Standards

Images: cover of the 2010 ADA Standards for Accessible Design, Department of Justice, September 15, 2010; and Table of Contents from the Standards – 1 Introduction; 2 -- 2010 Standards for State and Local Government Facilities: Title II; 3 – 2010 Standards for Public Accommodations and Commercial Facilities: Title III; 4 – 2010 Standards for Titles II and III Facilities: 2004 ADAAG


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2010 Standards: Guidance

Image: cover of the Guidance on the 2010 ADA Standards for Accessible Design, Department of Justice, September 15, 2010

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2010 Standards at ADA.gov

Image: home page of ADA.gov with arrow pointing at the link to the 2010 ADA Standards for Accessible Design (New November 15, 2010)

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Title II and III Regulations; Revision of Nondiscrimination Policies and Adoption of 2010 Standards

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Compliance Date; On March 15, 2012, new construction and alterations requirements in effect title II -- 28 CFR 35.151(c); title III -- 28 CFR 36.406

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Effective Dates...Available From: www.ADA.gov; ADA Information Line

Image: cover page of the document ADA 2010 Revised Requirements: Effective Date – Compliance Date document

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Title II 2010 Standards

Images: on the left side of the screen, the cover of the 1991 Title III regulations including the ADA Standards and below it the cover of the Uniform Federal Accessibility Standards; in the center, a yellow arrow pointing right; on the right side, the cover of the 2010 ADA Standards for Accessible Design

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Title III 2010 Standards

Images: on the left side of the screen, the cover of the 1991 Title III regulations including the ADA Standards; in the center, a yellow arrow pointing right; on the right side, the cover of the 2010 ADA Standards for Accessible Design

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Harmonized with Model Building Codes

Images: cover of the 2006 International Building Code; cover of the 2003 American National Standard Accessible and Usable Buildings and Facilities

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Application in United States...~50% of Building Codes; 100% ADA Facilities --

DOJ Regulations

Images: under ~50% of Building Codes are the cover of the 2006 International Building Code and the cover of the 2003 American National Standard Accessible and Usable Buildings and Facilities; under 100% ADA Facilities—DOJ Regulations is the cover of the 2010 ADA Standards for Accessible Design

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28 CFR 35.151(a)(2) and 28 CFR 36.401(c) Structural Impracticability 2010 Standards

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2010 Standards Structural Impracticability

Image: excerpts from the Standards describing circumstances where an entity can claim structural impracticability

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2010 Standards

Image: cover of the 2010 ADA Standards for Accessible Design

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DOJ Regulation Text in 2010 Standards Read with...

Image: arrow pointing at excerpt from the Standards, Section 232.1 about detention facilities; Search for [See additional requirements...

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Title II 2010 Standards

Image: Table of Contents for 28 CFR part 35.151 New Construction and Alterations

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Title III 2010 Standards

Image: Table of Contents for 28 CFR part 36, subpart D -- New Construction and Alterations

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2010 Standards -- 2004 ADAAG

Image: Table of Contents for 2004 ADAAG


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2010 Standards

ADAAG Structure and Format; CHAPTER 1: APPLICATION AND ADMINISTRATION; CHAPTER 2: SCOPING REQUIREMENTS; CHAPTERS 3 - 10: TECHNICAL REQUIREMENTS

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2010 Standards; CHAPTER 1: APPLICATION AND ADMINISTRATION

Image: first page of ADA Chapter 1-- Application and Administration

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2010 Standards; • 1991 Standards – Advisory text was included in the Appendix; 2010 Standards – Advisory text is included within the text after the provision; Advisory Language NOT enforceable

Image: arrow pointing at Advisory box for Section 206.7.9 Team or Player Seating

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Figures provided for informational purposes only -- must read text... 104.3

2010 Standards

Image: arrow pointing at page from the Standards showing Figure 303.3 Beveled Change in Level and accompanying text

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102 Adults and Children

The technical requirements are based on adult dimensions and anthropometrics.

In addition, this document includes technical requirements based on children’s dimensions and anthropometrics for drinking fountains, water closets, toilet compartments, lavatories and sinks, dining surfaces, and work surfaces.

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103 Equivalent Facilitation

Image: partial page from the Standards – text of Section103 Equivalent Facilitation

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105 Reference Standards

105.2.1 ANSI/BHMA -- Power Operated and Power Assist and Low Energy Doors; ANSI/BHMA A156.10-1999 (see 404.3); ANSI/BHMA A156.10-1997 (see 404.3,

408.3.2.1, and 409.3.1); ANSI/BHMA A156.19-2002 (see 404.3, 408.3.2.1, and 409.3.1)


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Chapter 1: Application and Administration

106 Definitions; 106.2 Terms Defined in Referenced Standards; 106.3 Undefined Terms -- not defined in title II regulations or referenced standards; 106.5 Defined Terms

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Chapter 1: Application and Administration; Selected Changes in Defined terms

Technically Infeasible is in definitions and not in the alterations section

Many new definitions for recreation facilities

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2010 Standards; Italicized Text?; Italicized text are terms defined in 106.5

Image: partial page from the Standards – text of Section 202.3 Alterations including italicized words and phrases

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Title II and Title III 2010 ADA Standards; A Kit of Parts...; Chapter 1 (reference standards, defined terms, etc...); Chapter 2 -Scoping Requirements; Chapters 3 - 10 Technical Requirements; Requirements Not Duplicated...

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2010 Standards Chapter 2

Image: first page of ADA Chapter 2—Scoping Requirements

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2010 ADA Standards; Example -- Parking Spaces; Scoping is provided by 208

Parking Spaces (page 67); Technical specifications are in 502 Parking Spaces (page 149)

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Scoping and Technical Requirements; General Guidance: Look for Chapter 2 Requirements to Match Up with Requirements from Chapters 3 - 10

206.4 Entrances with 404...

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Chapter 2: Scoping Requirements; Section 201.1 Scope; All areas of newly designed and newly constructed buildings and facilities and altered portions of existing buildings and facilities shall comply with these requirements.


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Chapter 2: Scoping Requirements; Section 201.2; Application Based on Building or Facility Use. Where a site, building, facility, room, or space contains more than one use, each portion shall comply with the applicable requirements for that use.

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Chapter 2: Scoping Requirements; Section 203; General Exceptions; This section exempts certain sites, buildings, facilities and elements from accessibility requirements of the 2010 Standards.

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Chapter 2: Scoping Requirements; Section 203 General Exceptions; Carries over similar exceptions from the 1991 Standards... 203.2 Construction Sites; 203.3 Raised Areas; 203.4 Limited Access Spaces; 203.5 Machinery Spaces

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Chapter 2: Scoping Requirements; Section 204 Protruding Objects; 204.1 General

Protruding objects on circulation paths shall comply with 307. EXCEPTIONS: 1. Within areas of sport activity, protruding objects on circulation paths shall not be required to comply with 307. 2. Within play areas, protruding objects on circulation paths shall not be required to comply with 307 provided that ground level accessible routes provide vertical clearance in compliance with 1008.2.

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Chapter 2: Scoping Requirements; Section 205 Operable Parts Adds new exceptions...

Operable parts intended for use by service or maintenance personnel... Electrical or communication receptacles -- dedicated use... Outlets in an accessible kitchen

Cleats and other boat securement devices... Exercise machines and exercise equipment

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Chapter 2: Scoping Requirements; Section 206 Accessible Routes; Limits the “all” of 201.1...; Covers “where” and “where not”...; Pairs with Chapter 4, Accessible Routes

Image: partial page from the Standards – text of Section 206 Accessible Routes including sections 206.1 and 206.2

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Chapter 2: Scoping Requirements; Section 206 Accessible Routes; 206.2.7 Press Boxes;

Aggregate area of all press boxes is 500 square feet maximum

Image: people standing and sitting on stepped seating in front of a small athletic field press box

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Chapter 2: Scoping Requirements; Section 206 Accessible Routes; 206.2 Where Required ; Employee Work Areas -- Common use circulation paths within employee work areas with exceptions... less than 1000 square feet, work area equipment, and certain exterior areas...

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Chapter 2: Scoping Requirements; Section 206 Accessible Routes; 206.2 Where Required; Amusement Rides; Recreational Boating Facilities; Bowling Lanes; Court Sports; Exercise Machines and Equipment; Fishing Piers and Platforms; Golf and Miniature Golf Facilities; Play Areas

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Where’s the Accessible Route?

Image: a building at the top of a steep hill has several pathways, all with stairs, leading up to and around it

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Accessible Route Connects All Accessible Buildings?

Image: view of dormitories in the distance from the top of a flight of stairs that leads to a plaza and another flight of stairs

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Chapter 2: Scoping Requirements; Section 206 Accessible Routes; 206.3 Location;

Accessible routes shall coincide with or be located in the same area as general circulation paths. Where circulation paths are interior, required accessible routes shall also be interior.

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Direct Access Bridges; 206.4.2 Parking Structure Entrances; 206.4.3 Entrances from Tunnels or Elevated Walkways

Image: view of an elevated walkway from inside an airport terminal

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Chapter 2: Scoping Requirements; Section 206 Accessible Routes; 206.5 Doors, Doorways, and Gates; Entrances to a building or facility; Rooms and Spaces; Transient Lodging Facilities – passage


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Chapter 2: Scoping Requirements; Section 206

Accessible Routes; 206.7 Platform Lifts; Performance Areas and Speakers’ Platforms; Wheelchair Spaces -- dispersion etc.; Incidental Spaces -- not public and 5 person max.; Judicial Spaces; Existing Site Constraints

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Chapter 2: Scoping Requirements; Section 206 Accessible Routes; 206.7 Platform Lifts;

Guest Rooms and Residential Dwelling Units; Amusement Rides; Play Areas; Team or Player Seating; Recreational Boating Facilities and Fishing Piers and Platforms

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Chapter 2: Scoping Requirements; Section 207 Egress; 207.1 General. Means of egress shall comply with section 1003.2.13 of the International Building Code (2000 edition and 2001 Supplement) or section 1007 of the International Building Code (2003 edition)

(incorporated by reference, see “Referenced Standards” in Chapter 1). EXCEPTIONS: 1. Where means of egress are permitted by local building or life safety codes to share a common path of egress travel, accessible means of egress shall be permitted to share a common path of egress travel. 2. Areas of refuge shall not be required in detention and correctional facilities.

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Chapter 2: Scoping Requirements; Section 208 Parking Spaces; Minimum Number; Exception for spaces exclusively for buses, trucks, delivery vehicles etc...; 208.2.4 Van Spaces -- 1 of every 6 or fraction of 6...; Location; Residential Facilities

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Chapter 2: Scoping Requirements; Section 209 Passenger Loading Zones

and Bus Stops; Larger loading zones...; Bus loading zones...; Medical Care and Long-Term Care Facilities; Valet Parking; Mechanical Access Parking Garages

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210 Stairways

Image: partial page from the Standards – text of Section 210 Stairways, including section 210.1 General and Advisory 210.1 General

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Chapter 2: Scoping Requirements; Section 213 Toilet Facilities and Bathing Facilities; Alteration exception for single unisex toilet or bathing room; Qualified historic facilities; Portable toilet or bathing units; Multiple single user toilet rooms – clustered; Single-use or family toilet or bathing rooms

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Chapter 2: Scoping Requirements; Section 215 Fire Alarm Systems

Image: visible fire alarm and audible alarm speaker

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Chapter 2: Scoping Requirements; Section 221 Assembly Areas; Read with 35.151(g) or 36.406(f); Number of wheelchair spaces -- reduced scoping; Integration; Lines of Sight and Dispersion; Companion Seats; Designated Aisle Seats -- at least 5% of aisle seats; Lawn Seating

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Chapter 2: Scoping Requirements; Section 224 Transient Lodging; Read with places of lodging at 36.406(c); Read with housing at a place of education at 35.151(f) or 36.406(e); Alterations; Guest room doors and doorways; Guest rooms with mobility features; Beds -- >25 bed, minimum 5%; Guest rooms with communication features; Dispersion

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Chapter 2: Scoping Requirements; Section 225 Storage; At accessible spaces, at least one of each type; Lockers, at least 5%, but no fewer than one of each; Self-service shelving on an accessible route; Self-storage storage facilities

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2010 Standards; Chapter 3 Building Blocks; 48 inches max -- 15 inches min

Images: figures 308.2.1-- Unobstructed Forward Reach and 308.3.1-- Unobstructed Side Reach from the 2010 Standards

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Toe and Knee Clearance

Images: arrow pointing to left image, an elevation of toe clearance and dimensions; arrow pointing from top down to right image, an elevation of knee clearance and dimensions

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Clear Floor Space

Images: figure 305.3 showing clear floor or ground space; figure 305.5 showing position of clear floor or ground space – parallel or forward approach to a ground element from the 2010 Standards


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Children’s Reach

Image: Advisory 308.1 General, including chart of children’s reach forward and side reach ranges

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307 Protruding Objects

Image: figure 307.3, 2 views of post-mounted protruding objects – free-standing object mounted on posts and sign or other obstruction mounted between posts or pylons from the 2010 Standards

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