Differences between A117.1-2009 and the 2010 ADA Standards

February 28, 2014

The most obvious difference between the 2010 ADA Standards and A117.1-2009 is Chapter 2. Chapter 2 of the  ADA Standards provides complete scoping for determining when and where accessibility is required. Chapter 2 of A117.1 does not include scoping but instead defers to the administrative authority that adopted the standard. Typically, the scoping comes from Chapter 11 of the IBC.

Aside from this bureaucratic difference, there are some major differences between the scoping and technical requirements of the ADA Standards and the IBC/ICC A117.1.

For example: Multiple Single-User Toilet and Bathing Rooms

Both standards start with the requirement that each toilet room and bathing room must be accessible.

ADA 213.2 Toilet Rooms and Bathing Rooms. Where toilet rooms are provided, each toilet room shall comply with 603. Where bathing rooms are provided, each bathing room shall comply with 603.

IBC 1109.2 Toilet and bathing facilities. Each toilet room and bathing room shall be accessible.

Then, exceptions are offered for existing conditions, private offices, transient lodging and medical facilities.

The exceptions for multiple single-use toilet rooms have one not-so-obvious difference:

ADA 213.2 Exception 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.

IBC 1109.2 Exception 3. Where multiple single-user toilet rooms or bathing rooms are clustered at a single location, at least 50% but not less than one room for each use at each cluster shall be accessible.

The exception in the ADA Standards leaves out bathing rooms and only allows the exception for toilet rooms. It is unclear why bathing rooms were not included in the exception.

The result is that if you have multiple single user bathrooms in facility such as a truck stop, 100% of the bathing rooms must be accessible. A clinic that has 4 unisex toilet rooms would only require 2 accessible toilet rooms.

This interpretation has been confirmed by the Texas Department of Licensing and Regulation and addressed in Technical Memorandum 2013-10.




Fake Braille. Seriously?

July 29, 2013

Meanwhile, in Canada…


Detectable Warnings on Curb Ramps

January 31, 2013

The 2010 ADA Standards do not require detectable warnings on curb ramps. They are only required at transportation platform boarding edges.

810.5.2 Detectable Warnings. Platform boarding edges not protected by platform screens or guards shall have detectable warnings complying with 705 along the full length of the public use area of the platform.

Requirements for detectable warnings are included in the proposed Guidelines for Public Right-of-Way. Although this document has not yet been adopted, it provides very good guidance for public ROW projects.

Here in Texas, a curb ramp located within a site is no longer required to contrast with adjoining surfaces or include detectable warnings or grooves.

Detectable warnings are required where accessible routes enter hazardous vehicular areas. This cannot be found in the 2012 TAS but is instead hidden away in the Texas Architectural Barriers Administrative Rules. A hazardous vehicular area includes all street crossings but does not include most driveways or pedestrian crossings within a site. Crossings at signalized driveways require detectable warnings.

Keep in mind that detectable warnings are required where are route enters a street even if there is no curb ramp.

The area covered by the detectable warnings should be limited to the 24″ minimum at the curb line. There is no benefit to providing more detectable warnings.

Researching Projects in Texas

January 31, 2013

A not-so-secret tool of Accessibility Specialists is the TDLR AB Project Data Search. This search engine includes all projects that have been registered for accessibility review and inspection in Texas. It’s a great tool, but use caution. The information isn’t always correct.

Search results will give the option to reprint the “Project Confirmation Page”




The confirmation page includes all of the information that was submitted by the architect or owner when the project was initially registered. Unfortunately, the confirmation page is a snapshot and cannot be changed; take care when you register a project with TDLR that all of the info is correct.

Older projects and projects that were registered by TDLR will not have confirmation pages.


This example search result shows that the construction at my office was inspected by Ms. Harris and was disapproved. Once all of the paperwork is completed, the Current/Last Action will change to an approval.


A few questions from a client regarding sinks in break rooms.

August 7, 2012

From: Brad Pitt, Architect (honorary)

Sent: Monday, August 06, 2012 5:37 PM

To: Jeromy Murphy [jmurphy@acico.com]

Subject: Accessibility Question-Knee Space under Sinks

We are trying to get proper interpretation on the attached bulletin.

In summary:

  • A Break Room with a sink but without “Cooking Facilities” is not required to have Knee Space
  • Any room with at least one fixed or built-in cooking facility including microwave ovens is considered a kitchen and therefore the sink needs knee space
  • A portable countertop Microwave Oven is not considered a Cooking Facility since it is not fixed or built-in
  • Sinks in Break Rooms with no other cooking facility except a portable countertop microwave oven does not require knee space

Are these statements correct?

Your best buddy,



From: Jeromy Murphy [jmurphy@acico.com]

Sent: Monday, August 06, 2012 5:37 PM

To: Brad Pitt, Architect (honorary)

Subject: re: Accessibility Question-Knee Space under Sinks


So good to hear from you. See my answers in red below. Note that these are NOT my interpretations, they are directly from TDLR.

      • A Break Room with a sink but without “Cooking Facilities” is not required to have Knee Space. False. 606.2(Exception 1) only applies to sinks located in “Kitchens” or “Wet Bars”. Because a break room is neither a kitchen nor a wet bar, the knee clearance is required (ridiculous, I know).
      • Any room with at least one fixed or built-in cooking facility including microwave ovens is considered a kitchen and therefore the sink needs knee space. True, but…If there is only a microwave, you can apply 606.2(Exception 1) and not provide the knee clearance. If it’s a non-fixed microwave, you can still call it a kitchen, but then you must meet the 50% storage and other kitchen requirements.
      • A portable countertop Microwave Oven is not considered a Cooking Facility since it is not fixed or built-in. Truish. These Standards only address fixed or built-in elements. If dedicated circuits or shelves are provided for a microwave, it could still be considered a kitchen.
      • Sinks in Break Rooms with no other cooking facility except a portable countertop microwave oven does not require knee space. False. As described, this is not a kitchen nor a wetbar, therefore 606.2(Exception 1) cannot be applied.

See you this Thanksgiving,


For reference:

606.2 Clear Floor Space. A clear floor space complying with 305, positioned for a forward approach, and knee and toe clearance complying with 306 shall be provided.

1. A parallel approach complying with 305 shall be permitted to a kitchen sink in a space where a cook top or conventional range is not provided and to wet bars.

Problems with the 2010 ADA Standards (and 2012 TAS)

July 18, 2012

There are two things that really bug me about the new Standards.

Firstly, this issue with 50% storage in kitchens. See my earlier post. This rule was not written by someone familiar with designing kitchens. Just take a look at the recent Access-Board webinar on kitchens where in one slide they show upper cabinets dimensioned 48″ to the bottom shelf, but somehow still fit a microwave under that upper cabinet. The elevation is unrealistic and so is the rule.

Secondly, under the old Standards we had an exception for maneuvering clearance at doors that were automatic or power-assisted (1991 ADA Standards 4.13.6). The new Standards allow the maneuvering clearance exception only at doors that are automatic. Here in Texas, and probably elsewhere, the interpretation is that an automatic door does not require any interaction so push-button operators are out. The problem with this is that often push-button operators were installed at existing restroom doors where tight spaces didn’t allow the provision of complying maneuvering clearance. Now, I guess that door will need to be automatic and will just swing open anytime someone passes by. I don’t think that is very practical.

Away from any State or local authority you can always argue compliance to the “maximum extent feasible” and stick with the push-button, but in Texas the words “maximum extent feasible” equate to “rejected variance application”.

Barrier-free Continuing Education

May 3, 2012

By request, here is the slideshow that I use for continuing education. Distribution is encouraged (see CC license info below).


Upcoming seminars:

 June 14: AIA Austin 2012 Annual Summer Conference & Product Expo, Commons Learning Center.

October 18: Texas Society of Architects Annual Conference, Austin Convention Center

Creative Commons License
2012 TAS Presentation by Jeromy G. Murphy is licensed under a Creative Commons Attribution-NonCommercial-NoDerivs 3.0 Unported License.