New Accessibility Standards, Part 3: General Exceptions
by Jeromy G. Murphy, AIA, RAS
The following is a common question that I hear from architects: “Is (fill-in-the-blank) required to be accessible?”
A simple question with a simple default answer: “Yes.”
Unsurprisingly, architects are rarely satisfied with that answer and for good reason, because there are always exceptions. Let’s start at the beginning.
Section 201.1 of the 2010 ADA Standards states the scope and offers a useful advisory:
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.
Advisory 201.1 Scope. These requirements are to be applied to all areas of a facility unless exempted, or where scoping limits the number of multiple elements required to be accessible. For example, not all medical care patient rooms are required to be accessible; those that are not required to be accessible are not required to comply with these requirements. However, common use and public use spaces such as recovery rooms, examination rooms, and cafeterias are not exempt from these requirements and must be accessible.
213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603.
Exceptions:
1. In alterations where it is technically infeasible to comply with 603, altering existing toilet or bathing rooms shall not be required where a single unisex toilet room or bathing room complying with 213.2.1 is provided and located in the same area and on the same floor as existing inaccessible toilet or bathing rooms.
2. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, no fewer than one toilet room for each sex complying with 603 or one unisex toilet room complying with 213.2.1 shall be provided.
3. Where multiple single user portable toilet or bathing units are clustered at a single location, no more than 5 percent of the toilet units and bathing units at each cluster shall be required to comply with 603. Portable toilet units and bathing units complying with 603 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
4. Where multiple single user toilet rooms are clustered at a single location, no more than 50 percent of the single user toilet rooms for each use at each cluster shall be required to comply with 603.
There are no exceptions for warehouse restrooms. If you are looking for the exception for the private office toilet room, you won’t find it in scoping. Instead the 2010 Standards provides a specific exception for each of the fixtures within a private toilet (see section 606.2 Exception 1).
The 2010 Standards include some general exceptions that are similar to the exemptions to the current Texas Accessibility Standards found in Admin Rules 68.30 (68.30).
203 General Exceptions
203.2 Construction Sites.
203.3 Raised Areas. ....security, life safety, or fire safety...
203.4 Limited Access Spaces. ...catwalks, crawl spaces, or very narrow passageways...
203.5 Machinery Spaces. ....mechanical, electrical or communications equipment rooms....
203.6 Single Occupant Structures. ....accessed only by passageways below grade or elevated above standard curb height....
203.7 Detention and Correctional Facilities. Exempts areas that do not serve accessible holding cells.
203.8 Residential Facilities.
203.9 Employee Work Areas. Spaces and elements within employee work areas shall only be required to comply with 206.2.8, 207.1, and 215.3 and shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area. Employee work areas, or portions of employee work areas, other than raised courtroom stations, that are less than 300 square feet (28 m2) and elevated 7 inches (180 mm) 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.
203.10 Raised Refereeing, Judging, and Scoring Areas.
203.11 Water Slides.
203.12 Animal Containment Areas.
203.13 Raised Boxing or Wrestling Rings.
203.14 Raised Diving Boards and Diving Platforms.
When in doubt, design for access.
The intent is for everything to be accessible unless the Standards specifically say it need not be accessible. For example, in new construction, is a toilet room located within a warehouse required to be accessible if accessible toilets are provided within the office area?
213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603.
Exceptions:
1. In alterations where it is technically infeasible to comply with 603, altering existing toilet or bathing rooms shall not be required where a single unisex toilet room or bathing room complying with 213.2.1 is provided and located in the same area and on the same floor as existing inaccessible toilet or bathing rooms.
2. Where exceptions for alterations to qualified historic buildings or facilities are permitted by 202.5, no fewer than one toilet room for each sex complying with 603 or one unisex toilet room complying with 213.2.1 shall be provided.
3. Where multiple single user portable toilet or bathing units are clustered at a single location, no more than 5 percent of the toilet units and bathing units at each cluster shall be required to comply with 603. Portable toilet units and bathing units complying with 603 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
4. Where multiple single user toilet rooms are clustered at a single location, no more than 50 percent of the single user toilet rooms for each use at each cluster shall be required to comply with 603.
There are no exceptions for warehouse restrooms. If you are looking for the exception for the private office toilet room, you won’t find it in scoping. Instead the 2010 Standards provides a specific exception for each of the fixtures within a private toilet (see section 606.2 Exception 1).
The 2010 Standards include some general exceptions that are similar to the exemptions to the current Texas Accessibility Standards found in Admin Rules 68.30 (68.30).
203 General Exceptions
203.2 Construction Sites.
203.3 Raised Areas. ....security, life safety, or fire safety...
203.4 Limited Access Spaces. ...catwalks, crawl spaces, or very narrow passageways...
203.5 Machinery Spaces. ....mechanical, electrical or communications equipment rooms....
203.6 Single Occupant Structures. ....accessed only by passageways below grade or elevated above standard curb height....
203.7 Detention and Correctional Facilities. Exempts areas that do not serve accessible holding cells.
203.8 Residential Facilities.
203.9 Employee Work Areas. Spaces and elements within employee work areas shall only be required to comply with 206.2.8, 207.1, and 215.3 and shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area. Employee work areas, or portions of employee work areas, other than raised courtroom stations, that are less than 300 square feet (28 m2) and elevated 7 inches (180 mm) 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.
203.10 Raised Refereeing, Judging, and Scoring Areas.
203.11 Water Slides.
203.12 Animal Containment Areas.
203.13 Raised Boxing or Wrestling Rings.
203.14 Raised Diving Boards and Diving Platforms.
When in doubt, design for access.
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Jeromy G. Murphy, AIA, RAS
Jeromy G. Murphy, AIA, RAS
jmurphy@acico.com
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