Wheelchair Turning Space in Janitor’s Closets

UPDATE: Per a conversation with Technical Assistance at the US Access Board, it was clarified that employee only work areas are not required to have turning space. Turning space is only required in those areas where it is specifically mentioned in the ADA Standards. However, while in Texas, use the interpretation below.

I can’t believe that I have waited this long to write this post considering that this question is asked at least once a week.

The Texas Accessibility Standards, and similarly the ADAAG, requires that most areas be designed so that a person in a wheelchair could enter and leave the space.  For employee work areas, this is the only requirement:

4.1.1 Application. (3) Areas Used Only by Employees as Work Areas. Areas that are used only as work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas. These standards do not require that any areas used only as work areas be constructed to permit maneuvering within the work area or be constructed or equipped (i.e., with racks or shelves) to be accessible.

Even a Janitor’s Closet must meet the requirement for approach, entry and exit.  This may require a 60″ diameter turning space (or T-turn, see 4.2.3).   The big concern is that a person could become trapped within a small space if the door were to close behind the wheelchair and a 180 degree turn was not possible.  However, if the space is so small that a wheelchair (presumably occupying a rectangular space that is 30″ by 48″) cannot maneuver beyond the swing of the door, a turning space is not required.

TurningSpaceExplained

Examples of closets with and without turning space required.

Electrical, mechanical or IT closets are exempt from this requirement, but if a closet serves dual purpose Janitor/Mechanical, access is required.

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6 Responses to Wheelchair Turning Space in Janitor’s Closets

  1. Daryl says:

    Are visual alarms required in storage closets?

    • jeromymurphy says:

      The ADA Standards defer to NFPA 72.

      702.1 General. Fire alarm systems shall have permanently installed audible and visible alarms complying with NFPA 72 (1999 or 2002 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1), 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 dB 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).

      • Daryl says:

        Thanks for the comment. What I am asking about is in TAs 9102 4.28 Alarms
        4.28.1 General. Alarm systems required to be accessible by 4.1 shall comply with 4.28. At a minimum, visual signal appliances shall be provided in buildings and facilities in each of the following areas: restrooms and any other general usage areas (e.g., meeting rooms), hallways, lobbies, and any other area for common use.

        So would a locked (key required) closet require the alarm? Is that considered common use area?

  2. Daryl says:

    Jeromy?
    Any ideas?
    Thanks again for your insight.

  3. Ken Otten says:

    Jeromy,

    I have always espoused the position you have taken in this post and required such for projects I have reviewed and inspected, but after reading the following from the DOJ’s “Guide to ADAAG Provisions”, I have changed my position. In the Guide, it states this regarding Section 4.1.1(3):

    “Work areas must be accessible for “approach, entry, and exit,” which means location on an accessible route so that people using wheelchairs can enter and back out of the space. This includes accessible entry doors or gates.

    Recommendations: Space for turning within the work area and interior maneuvering clearances at doors, while not required, should be considered, especially where entrapment may be a concern (i.e., entry doors with closers); interior door clearances are recommended where space for full entry and turning is available within a work area.”

    The sideways logic for this requirement (or lack of a requirement, as it were) is that employees who need the maneuvering clearances and turning space within a room or space can request such as a reasonable accommodation.

    I don’t know of anything that changes this interpretation in the new Standards (either the 2010 ADA Standards or the 2012 TAS).

    Am I off here?

    Ken

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