Code Review Accessibility 1 Code Review Accessibility 1

Code Review: Accessibility 1

Code Review: Accessibility 1. Why Accessibility? 2. Regulatory Context 3. ADA 4. ADAAG 5. ADAAG Technical Chapters 6. 521 CMR 7. Variances Between Codes 2

Why Accessibility? 3

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes Why Accessibility? Accessibility is a growing concern. With an aging population and recent wars in the Middle East and Afghanistan more and more people are disabled in some form. • 19. 4% (49 million people in the US) have a disability • 24. 1 million people in the US have a severe disability • 34. 7 million people in the US are 65 or older • This number will double in the next 25 years • Disabilities increase with age 4

Regulatory Context 5

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes Regulatory Context Concepts for accessibility standards in the Massachusetts’ Building Code are taken from other codes: • • Architectural Barriers Act- 1968 Fair Housing Act- 1968, 1988 Section 504 - 1973 Air Carriers Access Act- 1988 Americans with Disabilities Act- 1990 Mass. Architectural Access Board- 1968 State & Local Anti-Discrimination Laws 6

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Regulatory Context What is the ABA? The Architectural Barriers Act (ABA) requires equal access to any facility that is designed, altered, or leased with federal funds. • The Uniform Federal Accessibility Standards (UFAS) is the current standard for complying with ABA. Variances Between Codes 7

ADA American with Disabilities Act 8

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADA The Americans with Disabilities Act (ADA) was signed into law on July 26, 1990 by President George H. W. Bush. The ADA is one of America's most comprehensive pieces of civil rights legislation that prohibits discrimination and guarantees that people with disabilities have the same opportunities as everyone else to participate in the mainstream of American life -- to enjoy employment opportunities, to purchase goods and services, and to participate in State and local government programs and services. 9

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR ADA The Americans with Disabilities Act (ADA) is Public Law 101336. ADA is based on the Civil Rights Act of 1964. The purpose of ADA is broad prohibition against discrimination based on disability. ADA is composed of: • TITLE I- Employment (Equal Employment Opportunity Commission) • TITLE II- Activities operated by state or local governments, including housing • TITLE III- Commercial Facilities & Places of Public Accommodation Variances Between Codes “No individual shall be discriminated against on the basis of disability” 10

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADA As of January 26, 1993 facilities must be designed and constructed that are readily accessible and usable by individuals with disabilities: • “…discrimination (for purposes of the ADA) includes a failure to design and construct facilities … that are readily accessible to and useable by individuals with disabilities. ” • Door knobs are an example of discrimination • Affirmative Action requires the proactive removal of barriers 11

Code Review: Accessibility Why Accessibility? Regulatory Context ADA New construction and alterations must comply with ADA standards. Law ADAAG Implementing Regulations ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG (guidelines) Adopted by US Do. J ADA Standards (enforceable) 12

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADA The ADA is formatted and organized in the following manner: • • • New numbering system consistent with model codes Clear delineation between scoping and technical provisions New figures and commentary Non-mandatory language -advisory information All figure-based information in written text Integrate special occupancy chapters (medical, libraries, transient lodging…) 13

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADA Chapter 1 of the ADA is Application and Administration. Chapter 1 includes: • • • 101 Purpose 102 Dimensions for Adults and Children 103 Equivalent Facilitation 104 Conventions 105 Referenced Standards 106 Definitions 14

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters ADA Chapter 2 of the ADA is Scoping Requirements. Chapter 2 specifies which spaces and elements are required to comply with ADA. It reinforces the underlying premise that all areas of newly constructed facilities are required to be accessible unless otherwise noted. Exceptions from the requirements are covered thoroughly. 521 CMR Variances Between Codes 15

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR ADA Chapter 2 includes new guidelines that enhance coverage of employee work areas that include accessible means of egress and connections for visual alarms. Another notable revision concerns press boxes, which have posed challenges due to their elevation and location. The new guidelines include an exception for certain press boxes based on their size, elevation, and location. Variances Between Codes 16

ADAAG American with Disabilities Act Accessibility Guidelines 17

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR ADAAG The American with Disabilities Act Accessibility Guidelines (ADAAG) is NOT a building code although it may look like one. The following is true of ADAAG: • It provides a minimum standard • It applies to all facility types except for some housing • It does not necessarily ensure compliance with the law Variances Between Codes 18

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters ADAAG Although the ADA Accessibility Guidelines (ADAAG) are titled as “Guidelines”, they are enforceable under the Americans with Disabilities Act. The ADAAG is incorporated into the Department of Justice’s regulations as the Current Design Standard. 521 CMR Variances Between Codes 19

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Since ADAAG was first issued in 1991, there have been several supplements and revisions that address: • State and local government facilities (1998) • Building elements designed for children’s use (1998) • Play areas (2000) • Recreation facilities (2002) These supplements have not been adopted by the DOJ and at this time they are not enforceable. However, they do provide guidance to ensure that all public programs and services are accessible to individuals with disabilities. 20

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters ADAAG The Americans with Disabilities Act Accessibility Guidelines (ADAAG) was reviewed and updated by a committee of 22 members who represented the design and construction industry, the building code community, state and local governments, and people with disabilities. 521 CMR Variances Between Codes The purpose of the committee was to ensure ADAAG remains consistent with technological developments and changes in model codes and national standards, as well as meeting the needs of people with disabilities. 21

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG The decade long review of ADAAG accomplished the following: • • • Updated the format Ensured its usability Reconciled it with the model codes Established consistency with ADA/ABA requirements Coordinated with the American National Standards Institute (ANSI) The Final Rules was issued in July, 2004. 22

Code Review: Accessibility ADAAG Current Design Standard (ADAAG 1992) Why Accessibility? Regulatory Context ADAAG (2002) ADAAG Technical Chapters ADA-ABA Guidelines (2004) 521 CMR Variances Between Codes More ADAAG to Come: State and local government facilities Building elements designed for children’s use Play areas Recreation facilities Public Rights-Of -Way Developed Outdoor Areas 23

ADAAG Technical Chapters 24

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 3 of the 2004 Americans with Disabilities Act Accessibility Guidelines (ADAAG) is titled “Building Blocks”. Chapter 3 covers the following topics: • Ground and floor surfaces (302) • Changes in level (303) • Wheelchair turning space (304) • Clear floor space (305) • Knee and toe clearances (306) • Protruding objects (307) • Reach ranges (308) 25

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR ADAAG Chapter 3 A significant change in Chapter 3 reduces the maximum side reach range from 54 to 48 inches. The change also specifics the height forward reaches: • Forward & Side Reaches: • 48” max. • 15” min. Variances Between Codes In this case ADA and ABA are more stringent than the 521 CMR regulations. 26

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 4 of the 2004 ADAAG is titled “Accessible Routes”. Chapter 4 covers the following topics: • • • Walking Surfaces (403) Doors (404) Ramps (405 Curb Ramps (406) Elevators (407 -409) Platform Lifts (410) 27

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 4 of the ADA Standards provides criteria for Door and Gate Opening Force. These standards state: • 404. 2. 9 Door and Gate Opening Force. Fire doors shall have a minimum opening force allowable by the appropriate administrative authority. The force for pushing or pulling open a door or gate other than fire doors shall be as follows: 1. Interior hinged doors and gates: 5 pounds (22. 2 N) maximum 2. Sliding or folding doors: 5 pounds (22. 2 N) maximum. 28

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters ADAAG Chapter 4 Regulations for the cross slope of an accessible route can be found in Chapter 4. This standard states: • Current 4. 3. 7 Slope. An accessible route with a running slope greater than 1: 20 is a ramp and shall comply with 4. 8. Nowhere shall the cross slope of an accessible route exceed 1: 50. 521 CMR Variances Between Codes 29

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 5 of the 2004 ADAAG is titled “General Site & Building Elements”. Chapter 5 covers the following topics: • • Parking (502) Passenger Loading Zones (503) Stairways (504) Handrails (505) 30

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR ADAAG Chapter 5 Passenger Loading Zones in Chapter 5 specifies that these zones must comply with the following: • No curbs • Mark/stripe access aisle • At least 1 mark/strip for every 100’ of loading zone space provided. Variances Between Codes 31

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 5 Chapter 6 of the 2004 ADAAG is titled “Plumbing Elements & Fixtures”. Chapter 6 covers the following topics: • Drinking Fountains (602) • Toilet and Bathrooms (603) • Water Closets & Compartments (604) • Urinals (605) • Lavatories & Sinks (606) • Bathtubs (607) • Showers (608) • Grab Bars (609) • Tub & Shower Seats (610) • Washing Machines and Clothes Dryers (611) • Saunas and Steam Rooms (612) 32

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR ADAAG Chapter 6 In Chapter 6 some provisions have been revised to help improve compliance as well as access. For example, an absolute dimension for the centerline placement of toilets (18”) has been replaced with a range (16” – 18”). To improve access and allow side transfers at toilets, lavatories are no longer permitted to overlap the required clear space aside toilets. Variances Between Codes 33

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 6 provides the specific clearance required around water closets and in toilet compartment: • 604. 3. 1 Size. Clearance around a water closet shall be 60 inches (1525 mm) minimum measured perpendicular from the side wall and 56 inches (1420 mm) minimum measured perpendicular from the rear wall • The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space. No other fixtures or obstructions shall be located within the required water closet clearance. 34

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR ADAAG Chapter 6 Furthermore, Chapter 6 outlines the requirements for drinking fountains which no longer allow a parallel approach: • Where only one drinking fountain is provided on a floor it shall be accessible. A single drinking fountain can be installed by the use of a "high-low" fountain. • Where more than one drinking fountain is provided on a floor, one in each location shall be accessible and shall be on an accessible route Variances Between Codes 35

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Chapter 6 Other changes in Chapter 6 concern shower compartments (specifications for water temperature, spray units, and curbs), and new criteria for washing machines and clothes dryers. ADAAG Technical Chapters 521 CMR Variances Between Codes 36

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 7 of the 2004 ADAAG is titled “Communication Elements & Features”. Chapter 7 covers the following topics: • • • Fire alarms (702) Signs (703) Telephones (704) Detectable warnings (705) Assistive listening systems (706), ATMs and fare machines (707) 37

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 7 provides the general requirements for fire alarms as follows: • Fire alarm systems shall have permanently installed audible and visible alarms complying with NFPA 72 (1999 or 2002 edition), except that the maximum allowable sound level of audible notification appliances complying with section 4 -3. 2. 1 of NFPA 72 (1999 edition) shall have a sound level no more than 110 d. B at the minimum hearing distance from the audible appliance. In addition, alarms in guest rooms required to provide communication features shall comply with sections 4 -3 and 4 -4 of NFPA 72 (1999 edition) or sections 7. 4 and 7. 5 of NFPA 72 (2002 edition). • EXCEPTION: Fire alarm systems in medical care facilities shall be permitted to be provided in accordance with industry practice. 38

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 7 Substantive changes to Chapter 7 include: • Addressing technical criteria for fire alarms through the National Fire Alarm Code (NFPA 72), which effectively overhauls specifications for visual alarms in a manner that will facilitate compliance while enhancing design and installation options • Revamped specifications for signs • New specifications for the capabilities and sound quality of assistive listening systems that derive from Boardsponsored research 39

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR ADAAG Chapter 7 Substantive changes to Chapter 7 include: Continued… • Improved access at ATMs and fare machines for persons with vision impairments through detailed criteria for audible output and tactile markings • Revised specifications for detectable warnings to allow a greater range of designs and products Variances Between Codes 40

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 8 of the 2004 ADAAG is titled “Special Rooms, Spaces & Elements”. Chapter 8 covers the following topics: • Assembly areas (802) • Dressing, fitting, and locker rooms (803) • Kitchens and kitchenettes (804) • Medical care facilities (805), transient lodging (806) • Holding and housing cells (807), • Courtrooms (808) • Residential dwelling units (809) • Transportation facilities (810) • Storage (811) 41

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 8 has been reorganized to clarify the application of requirements for certain types of spaces without respect to the overall occupancy. For example, specifications for kitchens and kitchenettes apply whether such spaces are located in a hotel guest room, a dwelling unit, or an employee break room. This differs from the original guidelines which addressed kitchens and kitchenettes only in relation to transient lodging facilities. 42

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters ADAAG Chapter 8 A specific standard within Chapter 8 establishes the requirement for wheelchair spaces to adjoin accessible routes: • 802. 1. 4 Approach. Wheelchair spaces shall adjoin accessible routes. Accessible routes shall not overlap wheelchair spaces. 521 CMR Variances Between Codes 43

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR ADAAG Chapter 8 Additionally, Chapter 8 provides the requirements for the companion seating for wheelchair spaces. These spaces must have shoulder to shoulder alignment : • 802. 3. 1 Alignment. In row seating, companion seats shall be located to provide shoulder alignment with adjacent wheelchair spaces. The shoulder alignment point of the wheelchair space shall be measured 36 inches (915 mm) from the front of the wheelchair space. The floor surface of the companion seat shall be at the same elevation as the floor surface of the wheelchair space. Variances Between Codes 44

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters ADAAG Chapter 8 According to Chapter 8, wheelchair spaces must comply with the following: • Provide a view over seated spectators • Provide a view over standing spectators • Provide a view between the heads of other spectators 521 CMR Variances Between Codes 45

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters ADAAG Chapter 9 of the 2004 ADAAG is titled “Built-In Elements”. Chapter 9 covers the following topics: • Dining and work surfaces (902) • Benches (903) • Sales and service counters, including check-out aisles (904) 521 CMR Variances Between Codes 46

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes ADAAG Chapter 10 of the 2004 ADAAG is titled “Recreation Facilities”. Chapter 10 covers the following topics: • Amusement rides (1002) • Recreational boating facilities (1003) • Exercise machines (1004) • Fishing piers and platforms (1005) • Golf facilities (1006), • miniature golf facilities (1007) • Play areas (1008) • Swimming pools, wading pools (1009) • Shooting facilities with firing positions (1010) 47

521 CMR Massachusetts Accessibility Regulations 48

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes 521 CMR The purpose and intent of the Massachusetts’ Architectural Access Board’s (AAB) regulations under 521 CMR are as follows: • To make public buildings and facilities accessible to, functional for, and safe for use by persons with disabilities. • To provide persons with disabilities full, free and safe use of all buildings and facilities so that all such persons may have the educational, living and recreational opportunities necessary to be as self-sufficient as possible and to assume full responsibilities as citizens. 49

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Under 521 CMR, raised islands must comply with the following regulations: • Any raised islands in crossings shall be cut through level with the street or have curb cuts at both sides and a level area at least 48 inches (48" = 1219 mm) long between the curb cuts in the part of the island intersected by the crossings. Variances Between Codes 50

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes 521 CMR also regulates walks, sidewalks and crosswalks: • A walk is a path designed and constructed for pedestrians. Walks include: • pedestrian/multi use paths • meandering walks along the roadway • walks sufficiently offset from the roadway, such that the roadway profile need not govern the sidewalk profile. • All walks where any portion of the finished profile is greater than 5% are considered ramps, and must be designed and constructed as such. 51

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR includes a new exception concerning press boxes. Press boxes must be: • 500 sq. ft. or less (aggregate area) and on bleachers, entered on one level OR • Free standing – elevated 12’-0” or more Variances Between Codes 521 CMR still requires all press boxes to be accessible. 52

Code Review: Accessibility Why Accessibility? 521 CMR regulates “Accessible Means of Egress”. Regulatory Context What is a means of egress? ADA • A means of egress is the path available for a person to ADAAG Technical Chapters 521 CMR leave a building, structure, or space. This route must be unobstructed, and doors along this route cannot be subject to locking from the side that people will be leaving. Variances Between Codes 53

Code Review: Accessibility Why Accessibility? 521 CMR regulates “Accessible Means of Egress”. Regulatory Context Isn’t the way in always the way out? ADA • In most buildings, the way in is also the way out. People ADAAG Technical Chapters 521 CMR Variances Between Codes generally will leave a building the same way they came in since that is the familiar route. However, the way out is not always possible. A fire could occur at any location in a building. The path used for entry into a space may be blocked. Or, in the case of a multi-story building, the route to the upper floors may include an elevator. Elevators are not permitted to be used as a general means of egress. Occupants are typically instructed to use the exit stairways. 54

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes 521 CMR “Accessible Means of Egress” under 521 CMR references the International Building Code (IBC). However, amendments to 521 CMR are more stringent than the IBC: • 20. 11. 1 - All spaces or elements required to be accessible by 521 CMR shall be provided with no less than one accessible means of egress. A. Where more than one means of egress is required under 780 CMR (the state building code) from any accessible space or element, each space or element shall be served by not less than two accessible means of egress. 55

Code Review: Accessibility Why Accessibility? Regulatory Context 521 CMR “Exterior Egress” under 521 CMR states: • 20. 11. 2 – The exit discharge shall provide a continuous path of travel from an exit to a public way by means of a walkway or a ramp. ADAAG A. Where public ways are further than 100 feet from an exit, exterior areas of rescue assistance ……. no closer than 100 feet from the building. ADAAG Technical Chapters 521 CMR Variances Between Codes B. In buildings where the grade at the level of exit discharge prohibits construction of either a walkway or a ramp, a portion of an exterior exit balcony located immediately adjacent to an emergency exit complying with 20. 12. 2 may be constructed as an area of rescue assistance. • 56

Code Review: Accessibility Why Accessibility? Regulatory Context ADA 521 CMR How is an Accessible Means of Egress Different from a General Means of Egress? • The main difference is where the means of egress is from a basement level or an upper level. Persons who can use stairways will use the exit stairways to evacuate. Persons who cannot use stairways must be able to get to the exit stairways or to an elevator equipped with standby power to obtain “assisted rescue” by emergency responders. It is standard operating procedure for emergency responders to check these locations first for anyone needing assistance. ADAAG Technical Chapters 521 CMR Variances Between Codes • 57

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR How is an Accessible Means of Egress Different from a General Means of Egress? Continued… • When the exit is a door leading directly to the outside, both the general means of egress and the accessible means of egress must be continually available without assistance and are typically the same route. 521 CMR Variances Between Codes 58

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes 521 CMR regulates “Areas of Rescue Assistance”. These areas are required when an accessible means of egress is not provided. Exceptions include: • Existing buildings undergoing alterations, remodeling, reconstruction • Buildings or facilities having a supervised automatic sprinkler systems • Tunnels • Open air parking garages and open air transit stations 59

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes 521 CMR An area of rescue assistance shall be one of the following: • A portion of a stairway landing within a smoke-proof enclosure. • A portion of an exterior exit balcony located immediately adjacent to an exit stairway when the balcony complies with applicable requirements of the State Building Code for exterior exit balconies. Openings to the interior of the building located within 20 feet (20' = 6 m) of the area of rescue assistance shall be protected with fire assemblies having a ¾ hour fire protection rating. • A portion of a one hour fire-resistive corridor located immediately adjacent to an exit enclosure. 60

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes 521 CMR regulates Limited Use Limited Application Elevators: LULA Elevators. LULA (lifts) are allowed in limited circumstances: • Performance area/speakers’ platforms • Wheelchair spaces • Judicial spaces • Incidental spaces • Amusement rides • Team/player seating • When elevator not required 61

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Section 30. 16. 2 of 521 CMR regulates the knee space required in public toilet rooms: • Height: Sinks shall be mounted with the rim no higher than 30 inches (30" = 762 mm) above the finish floor. A clearance of at least 25 inches (25"= 635 mm) above the finish floor to the bottom of the apron shall be provided. Knee and toe clearance shall be at least 30 inches (30"= 762 mm) wide and 19 (19" = 483 mm) deep. Variances Between Codes 62

Variances Between Codes 63

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes The Americans with Disabilities Act (ADA), the Architectural Barriers Act (ABA), and 521 CMR do not always have the same standards. For Employee Work Areas, each accessibility code requires access to egress, but also differ in opinion as follows: • ADA: > 1000 sq. ft. - must have accessible common use circulation paths (206. 2. 8) • ABA: Full access in employee work areas • 521 CMR: No jurisdiction over employee-only areas 64

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters Variances Between Codes Another discrepancy between the accessibility codes exists for Entrances: • ADA & ABA: 60% of public entrances must be accessible • 521 CMR: ALL public entrances must be accessible 521 CMR Variances Between Codes 65

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes Accessibility codes also vary when it comes to the maneuvering space in accessible routes. Here 521 CMR is more stringent than ADA & ABA: • ADA & ABA : Door in a recess > 8” requires flush maneuvering space • 521 CMR: Door in a recess > 6” requires flush maneuvering space 66

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes Variances in the accessibility codes can also be seen in the requirements for curb cuts. Here 521 CMR is more stringent than ADA & ABA. Here are the width requirements for landings at the top of curb ramps: • ADA & ABA: 36” min. • 521 CMR: 48” min. Variances Between Codes 67

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Variances Between Codes Another difference in the codes is for edge protection on ramps. Once again, 521 CMR is more strict than ADA and ABA: • ADA & ABA: Prevents the passage of a 4” diameter sphere ADAAG Technical Chapters 521 CMR Variances Between Codes • 521 CMR: Edge curbs, walls, railings, or projecting surfaces that prevent people from slipping off the ramp. Edge curbs shall be min. of 2” high. 68

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters Variances Between Codes The specifications for handrails vary between the codes. ADA & ABA provide more specifics than 521 CMR: • ADA & ABA: Gripping surface – provides more detail and more options • 521 CMR: Round or oval 521 CMR Variances Between Codes 69

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes The accessibility codes also vary in their standards for Single. Use Toilet Rooms: • ADA & ABA: 50% single-user toilet rooms must be accessible where toilet rooms are grouped • 521 CMR: ALL single-user toilet rooms must be accessible: • In each adult public toilet room, at least one water closet and one sink in each location shall be accessible to persons in wheelchairs, or a separate Accessible unisex toilet room shall be provided at each location. 70

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters Variances Between Codes Additionally, there is also a discrepancy in the requirements for the centerline placement of toilets: • ADA & ABA • 16” – 18” to CL for Accessible Water Closets • 17” – 19” to CL for Ambulatory Accessible Water Closets 521 CMR Variances Between Codes • 521 CMR: 18” for all 71

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters 521 CMR Variances Between Codes The accessibility codes also differ in the required mounting heights for signage. ADA & ABA provide for a range with 521 CMR does not: • ADA & ABA: Mounting height: 48” – 60” specific to position of Braille characters • 521 CMR: 60” mounting height to CL of sign Variances Between Codes 72

Code Review: Accessibility Why Accessibility? Regulatory Context ADAAG Technical Chapters Variances Between Codes Which code should be used? ? • If regulations vary between 521 CMR, ADAAG, and ADA then determine which rule is the most stringent. • Use the most stringent rule when working on a project where you have to comply with all three rules is a safe bet. 521 CMR Variances Between Codes 73

THE END Code Review: Accessibility 74