Pass to Compliance

July 1, 1998
Interpreting the ADA correctly and recommending ways to adhere to the law is essential to the compliance process.

A primary purpose of the Americans with Disabilities Act (ADA) as it relates to schools and universities is to give the more than 5 million students with disabilities the same access to transportation, school buildings and telecommunications that students without disabilities enjoy.

Schools can lose federal funding and accreditation if not in compliance. In addition, inaction constitutes a violation of a disabled person's civil rights, and school districts and administrators can face the possibility of lawsuits, which can damage an institution's reputation, among other things.

Adhering to Title III

If a school or educational facility is undergoing renovations to its existing space or a new construction project, compliance with Title III in public restrooms of the facility is mandatory.

As a school administrator, facilities or physical plant manager, interpreting the ADA correctly and recommending ways to adhere to the law is essential to the compliance process. To aid in this process, consider the following (As always, it is advisable to review the ADA and its regulations, as well as check individual state and local codes for any additional re quirements):

-Public or private. The ADA Title III divides buildings and facilities into two categories: public accommodations and commercial facilities. Schools are public accommodations.

-Compliance in existing educational facilities. The first step is to review the type of construction project. Requirements for public accommodations existed before the ADA was passed. In addition, existing public accommodations must meet ADA requirements for barrier removal, if possible. Some examples of the Title III-required barrier removal in washrooms include relocation of dispensers and the widening of stall partitions (if current dispensers and stalls cannot be used by the disabled).

-Compliance in new construction and alterations. School buildings under construction must meet ADA technical requirements. Alterations defined as a change that affects or could affect the usability of the building or any part thereof must meet ADA compliance as well. Alterations include such projects as remodeling, renovation, rehabilitation, reconstruction, historic-preservation changes or rearrangements in structural parts or elements, and changes or rearrangements in the plan configuration of walls and fill-height partitions. Therefore, such projects as moving walls must meet accessible design requirements. Even minor alterations such as the installation of new soap, bathroom-tissue or paper-towel-dispensing systems must conform to Title III. However, work such as reroofing, painting, asbestos removal or changes to certain building systems generally are not considered alterations by ADA definition.

Ensuring accessibility

Knowing what is supposed to go where, and how high and how wide fixtures must be, represents the nuts and bolts of ADA compliance.

Washroom dispensers must be operable with one hand and should not require tight grasping, pinching or twisting of the wrist. The force required to operate controls cannot exceed 5 pounds. In addition, dispensers must be located to meet "reach range" and clear-floor-space requirements. There are special requirements for bathroom stalls and other restroom items as well. Details include:

-Clear floor space. The space required to operate a stationary wheelchair is 30 inches by 48 inches. Dispensers should be positioned for either a forward or parallel approach. Therefore, if the floor space extends more than 24 inches into an alcove, the minimum alcove width should be about 36 inches. If a parallel-approached clear floor space extends more than 15 inches into an alcove, the minimum alcove length should be 60 inches.

-Reach range (vertical distance from the floor). If the clear floor space permits a parallel approach by a person in a wheelchair, the maximum high-side reach should be 54 inches, and the minimum low-side reach should be 9 inches. On the other hand, if the clear floor space permits only a forward approach by a person in a wheelchair, then the maximum high-forward reach should be 48 inches and the minimum low-forward reach 15 inches. Remember, if reaches are interfered with by obstructions, there are different reach requirements.

-Bathroom stalls. Each educational facility must provide one accessible stall. Two are required if there are more than six bathroom stalls in a restroom.

In a standard ADA-accessible stall, the toilet must be positioned so a clear unobstructed floor space is provided around the toilet to allow a student using a wheelchair or scooter to maneuver into his or her own best position to transfer onto the toilet. The required wide or open space provided next to the toilet may be on either the right or left, provided the other elements of the stall are in correct relationship to the toilet. It is recommended that, throughout a building or facility, there be a mix of standard accessible stalls, some with the open space beside the toilet oriented to the left and some to the right, to accommodate students who can transfer only to one side.

Stall doors should be self-closing with low-profile-model coathooks placed no higher than 48 inches. The stall door hardware should be loop handle with slide-type latch. The toilet seats should be mounted to the floor and be positioned so they are no higher than 17 to 19 inches from the floor. Tissue dispensers should be installed on the near-side wall, a minimum of 19 inches above the floor and maximum of 36 inches from the rear wall.

Grab bars are required and should be mounted 33 inches to 36 inches above the floor. One 40-inch side-wall grab bar and one rear-wall grab bar are required.

-Mirrors. Each educational facility must provide one accessible mirror in a restroom. It is recommended that mirrors be mounted at usable heights for both seated and standing individuals. The bottom edge should be no more than 40 inches above the floor to meet the requirements of ADA standards. A full-length mirror is a universal solution because it works equally well for elementary-age students and older students in wheelchairs.

-Sinks/faucets. Appropriately designed standard wall-mounted and countertop fixtures can be installed to meet accessibility design requirements and will work well for the majority of users. Critical issues are depth of the fixture (no more than 17 inches), mounting height (no higher than 34 inches), position of supply lines, and drain and type of faucet.

Special lower-level sinks are not required and often are less accessible to older students who use wheelchairs because reaching across an elongated sink to faucet controls can be difficult. In general, faucets should be easy to operate.

-Exposed pipes and surfaces. There should be protection from hot-water lines, exposed drain pipes and any sharp or abrasive objects underneath the sink. Four basic methods of covering lines and drains are acceptable: insulated wrap, pipe covers, protective panels or integrated fixture shroud.

Practical solutions

Purchasing restroom products to comply with ADA requirements does not have to be a major financial burden. However, if you install any of the products listed below, it is considered an alteration, and at least one dispenser from that category must be accessible: *Paper-towel dispensers. *Soap dispensers. *Bathroom-tissue dispensers. *Seat-cover dispensers. *Facial-tissue dispensers.

When purchasing new dispensers to comply with ADA technical requirements, make sure reach-range and clear-floor-space requirements are met. One option is to look for hands-free bathroom tissue, soap and paper-towel dispensing options.

Hygienic bath tissue, single interleaved sheets of tissue enclosed within a dispenser, provides for easy, one-at-a-time dispensing. Hands-free soap dispensers that use infrared-sensor signals allow the disabled to simply place their hands under the nozzle and soap will dispense automatically.

In addition, hands-free dispensers can help reduce the risk of cross-contamination. Since there are no buttons, cranks or levers to touch, germs are not spread due to surface contact with the dispenser.

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