Documenting Code Adherence - ADA Issues

As we've said, one of the places in the CD sets that become really important to make sure that you're getting across all the information that you need to, to the code officials and to the GCs, and to everybody else, is in ADA issues; anything related to sort of disability management. And the reason for that is because that is a very strong, specific, sort of disciplinary line, sort of a litigative line that goes through all your projects regarding those issues. And so it's just a place where it's really hard to get it right, unless you've been very clear about the information to all the different players, to the GCs, and that the code officials can see that.

So what kinds of information are we talking about? Well, we've previously talked about all the different sort of dimensions of things from a design standpoint; the idea that, I need to have a minimum of 36 inches to be able to get somebody in a wheelchair through, I can reduce that if its a short distance to 32 inches, just because somebody elbows would be still in for that short distance, but at some point they need to be able to move their arms to be able to make the wheelchair roll.

So things like that, those are all those design issues, but in fact we need to then show them on the floor plan; we need to be able to say, "alright, here's "a hallway, there's a little bit of a moment where "that hallway gets a little tighter." If this is a plan that is supposed to be accessible, we would have to say, very clearly, that that's a minimum, of say 36 inches, and that this would be a minimum of 32 inches.

If we didn't have that dimension on there, and yet we were calling that an accessible route, that would be something that the code officials would definitely balk at, they would definitely want to know what these dimensions were, in order to be able to say "yes, we agree, that is in fact an accessible route." So the types of issues like that would be mostly about ramps but it's also gonna be about access to doors, we've all talked about the sort of size of the box that sort of fits around where there's a door, so I need to have a certain amount of dimension next to the door.

So if I have a 36 inch door, I've got an 18 inch space next to that door. So the 18 inch space next to the door I might have to show, it would depend on the situation, but it might just be that from a design standpoint, I just make sure that that is always compliant.

So certain of these issues are going to be ones that we have to actually very clearly demonstrate and other ones are going to be that we just have to make sure that the design is inclusive of. So, like I said, something like a space next to the door, as long as it meets the rules, probably don't need to show that specifically, but something like the egress path, where the path narrows down, that would be sort of worrying to a code official, it would make it look like it may not meet the rules of an egress path, that would be something you would really have to show.

So what other kinds of issues would definitely want to be shown? Well, one would be the idea of reach ranges. So that would be something like showing in a public bathroom space, the fact that the paper towel dispenser can only be at a certain height because the reach range would not be reasonable to expect somebody in a wheelchair to reach up higher than a certain height, 48 inches, and that an electrical outlet would be, maybe about 15 inches off the floor, instead of the usual 12 inches off the floor.

And the reason for that, is because the reach range is sort of not expected that somebody could get down the low. So those kinds of issues, if I'm in a situation where the ADA is required, the ADA issues are required, then I would absolutely have to show those reach ranges, so that the code officials, but more specifically, so that the general contractors, would be able to understand that this is an important issue, and it's needed in order to be able to be compliant with the code.

So, much of what we show on the drawings regarding accessibility issues, are going to be about those movement issues, the width of the ramps, the width of the spaces for the egress path, that kind of thing, as well as the kind of reach range issues; a sink is at a certain height off a floor, the lowest shelf on a closet is at a certain height, again at that 48 inch height that highest reach range.

That each of these little elements, need to be shown, that's because of your sort of worry that the code officials want to make sure they're worried, you're worried, everybody's worried; they want to make sure that we're gonna be meeting all of these issues, because it has such a long history of A, discrimination, but B, litigation. And that can happen on a whole lot, whole wide range of topics, so they wanna make sure that those things are all shown very clearly. Now, most of the drawings are actually not required to get in that level of detail.

But on public bathrooms that are accessible, or public kitchens that are accessible, anything that's in that sort of big public space, where there's a lot of specificity, there's gonna have to be a lot of information there to make sure that the code officials understand that you are, in fact, meeting the letter of the law, as well as the spirit of the law, on those issues. Related to that, is the idea of the different responses that you would have to different types of disability.

So, in general, because it has such a big architectural impact, when we talk about disability, almost all of us think of wheelchairs. But, in fact, it's actually a lot wider than that. So even elements that are made for people with wheelchairs, are actually really useful for people with walkers, people on crutches, people with strollers, all sorts of people use the elements that are made for people with wheelchairs. But, there's actually a whole wide range of people who don't have anything to do with wheelchairs, that are also part of the sort of disability community.

So people with sight impairment, people with hearing impairment, there may be people wayfinding issues, there's a whole wide range of sets of people that need some help to be able to navigate through a building. And when you're required to be doing that kind of work, you would want to show that pretty clearly on your set of drawings. Doesn't have to be super complicated, but there has to be some place where you are very clearly stating, this is how we're meeting our accessibility issues; this is how we're gonna help people who are hearing impaired; this is how we're gonna help people who are visually impaired, so you could have a very clear moment where that is stated on the set of drawings, and then the code officials understand that you are doing it, and the GCs understand what the issue is; why that design aspect is what it is, so they can know that that is something that's invaluable, and that they need to make sure that they meet that set of rules, so we can keep the building in compliance with those sets of issues.

So, an obvious example would be something like a strobe light system for an alarm system, so somebody with a hearing disability can't hear the alarm, that the strobe lights are there in response to that. Another example might be something like brail signage that would have to be set at a very particular height, so you would show the height, you would show the system of brail signage in relationship to the regular signage, and make sure that somebody who is looking at this set of drawings would very clearly understand where those signs would go, what heights they'd be set at, and what the system of organization is for that to be able to be understood by the general contractor to be able to make this system work, so that somebody in a wheelchair can use the wheelchair aspects, somebody that's sight impaired can find the right signage, somebody that's hearing impaired can get out in a fire when the alarm goes off, but they couldn't hear the alarm so the strobe goes off, and so that's working.

Like, each of those different elements what is the response sort of overall to make sure that the building is safe and usable for everyone. Another level of thinking about this, comes into the idea of maintaining and signage for these different systems. So, the reason I mention this specifically, is something like a wheelchair lift. Wheelchair lifts are sort of famous, because they kinda sit there, unused, for a long time, and then somebody comes in and needs it, and nobody can find the little key that makes it operate, or it hasn't been used for awhile and now it's all rusty and doesn't work well, or something like that.

So building in the idea of maintenance, using systems that are durable enough to be able to withstand the actual kind of use that they're going to get, finding systems and making sure that they're maintainable in sort of logical ways, so having that wheelchair lift in a protected area as opposed to just out in the rain, something like that, these are the kind of design issues you want to address on the CD sets, though you probably don't necessarily need to clearly demonstrate to the code officials that you're doing that, but you do need to address those issues.

And then the signage issues, you absolutely need to address. You can't just say, "well, we have a big space "and we're going to call that the handicap space." You actually have to put a sign up that says this is the handicap space. And, of course, the reason for that is not so much because people who are handicap need to know where the space is, but to keep other people out of that space, so that it allows the handicapped folks to be able to actually get to it and use that space.

And anybody who is maintaining the parking lot to be able to tell if the wrong people are using the space or not. So there's a whole series of this kind of down-the-road issues, signage, maintenance issues, all of that, they really should show up on this set of drawings, because it's an important part of compliance, because a building exists in time, you can't just think about compliance on day one, you have to think of compliance through the years. So, one of the things that we're usually thinking about in these categories, when we're talking about the disability issues, a set of drawings, CD sets, one of the big questions is always going to be, does this particular building need to meet certain levels of accessibility.

Now, essentially all buildings should meet at least sort of basic ideas of accessibility, especially for public spaces, but different types of situations will drive that to be more accessibility, or more accessible, or whether the issues are such that it's not making you be more accessible.

So, one example, if I have public money in a project, if it's a public project and I have public money in the project, that's gonna mandate that there's more accessibility; that it is a more accessible building. If I'm building public housing, if I'm building affordable housing, and I have public money in that process, I not only have to meet the Fair Housing Act sort of generally, but that's going to also include a certain percentage of accessible units or adaptable units. So, the way the project is financed is an important question.

Is it a public amenity? Is it a public space? A store, a large store, office space, things like that, that there's an expectation that people with disabilities would likely be using, something along those lines, there's an expectation that the building is actually responding to that, that people with disabilities should be able to use these buildings. So, does your building meet those issues?

Does it need to meet those issues? You might have that written right on the drawing set, it might be right on that cover sheet, "this is a publicly funded building, "and it must meet the Fair Housing Act, "and it must meet all these other sets of issues "that would be locally defined from the ADA." And that would give a cue to the code officials of what to look for. It might be that you say right at there on the cover sheet, this is not a publicly funded building, this is not a building that needs to be more accessible, or needs to meet any of these accessibility issues, this is a private space, its a single family home, or something like that.

So you are clearly telegraphing what the issues are to the code officials and to the general contractors, to understand what they need to be worried about in terms of any of the accessibility issues. But for those situations where you do need to put it on, the set of issues are going to be pretty straightforward, it's going to be about moving people through, it's going to be about the different types of accessibility, like I said, hearing impairments, visual impairments, but clearly the wheelchair issue is going to be the big dominant one because it takes up so much space, and so it has such a large impact on a design system, that that's the one that things really focus around.

And that's really gonna end up being about the dimensions of those spaces, being able to open doors, get down hallways, get out in a fire, get into a stairwell, get through a door, be able to use a public bathroom, can they reach up to get all the things, can they reach down to get everything they need, what's the reach range of all that possibility, can they get in underneath the sink, their legs under a sink, and be able to wash a dish, can they have a place where they could cut vegetables, so they can pull in and cut the vegetables, all of those dimensions would have to be shown on that set of drawings, and very clearly shown so the code official would understand that you knew that you are complying with these issues and that they understood that you were complying with those issues, and therefore that the GCs would be able to build it in such a way that it's compliant with those issues.

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