2010 ADA Standards for Accessible Design: a chapter-by-chapter guide

What the 2010 ADA Standards are, and what ADAAG means

The 2010 Standards are not one text but three, read together (2010 ADA Standards, 2010 Standards for Titles II and III: 2004 ADAAG):

• 28 CFR 35.151, the Title II regulation on new construction and alterations, for state and local government facilities.
• 28 CFR part 36, subpart D, the Title III regulation on new construction and alterations, for public accommodations and commercial facilities.
• The 2004 ADAAG, published at 36 CFR part 1191, appendices B and D: Chapters 1 and 2 and Chapters 3 through 10, which hold the measurements. In the few places where the regulation and the 2004 ADAAG differ, the regulation prevails.

ADAAG stands for the Americans with Disabilities Act Accessibility Guidelines, published by the U.S. Access Board. The guidelines get their legal effect from the Department of Justice, which adopted ADA Chapter 1, ADA Chapter 2 and Chapters 3 through 10 of the 2004 ADA/ABA Guidelines as part of the 2010 Standards, which gives them legal effect under its Title II and Title III regulations (ADA Title III regulations, supplementary information to the 2010 rule). The earlier 1991 Standards were based on the 1991 ADAAG, which the Access Board published the same day (ADA Title III regulations, supplementary information to the 2010 rule). In other words, Chapters 1 to 10 of the 2010 Standards are the 2004 ADAAG, and they are enforceable under the ADA because the Department of Justice adopted them.

The Standards also serve as the reference point for existing buildings: for state and local governments that make structural changes to meet their program access duties, and for businesses that remove barriers where that is readily achievable (2010 ADA Standards, introduction). What a business open to the public has to do in a building it has not altered is explained in ADA compliance.

Which buildings the 2010 ADA Standards apply to

• Government facilities (Title II): every facility or part of a facility built or altered by, on behalf of, or for the use of a state or local government (2010 ADA Standards, 28 CFR 35.151(a)(1) and (b)(1)).
• Public accommodations (Title III): facilities run by a private entity in one of the categories the regulation lists, such as hotels, restaurants, theaters, stores, banks, doctors’ offices and museums (ADA Title III regulations, 28 CFR 36.104, “place of public accommodation”). The new construction and alterations rules apply to a facility used, or designed and built, as one (ADA Title III regulations, 28 CFR 36.102(b)(3)).
• Commercial facilities (Title III): facilities intended for nonresidential use by a private entity whose operations affect commerce, such as offices, factories and warehouses. Facilities covered or exempted by the Fair Housing Act, aircraft and railroad cars are not commercial facilities (ADA Title III regulations, 28 CFR 36.104, “commercial facilities”).
• A business in a home: the part used only as a residence is not covered, but the part used for the business is, including the front sidewalk, the door, the hallways and the restrooms used by employees or visitors (2010 ADA Standards, 28 CFR 36.401(b)).
• Not covered by Title III: religious entities and private clubs, except club facilities made available to the customers of a place of public accommodation (ADA Title III regulations, 28 CFR 36.102(e)).

Within those facilities, the Standards apply to fixed or built-in elements of buildings, structures, site improvements, and pedestrian routes or vehicular ways located on a site (2010 ADA Standards, 28 CFR 35.151(d) and 36.406(b)). Temporary buildings count as well as permanent ones (2010 ADA Standards, 201.3): reviewing stands, temporary classrooms, bleachers, stages and exhibit areas are among the advisory examples (2010 ADA Standards, advisory 201.3). All areas of a new building, and the altered parts of an existing one, comply, except where section 203 exempts them (2010 ADA Standards, 201.1 and 203.1): construction sites, areas raised for security or life safety such as lifeguard stands, spaces reached only by ladders or crawl spaces, and machinery rooms (2010 ADA Standards, 203.2 to 203.5). Employee work areas only have to let people with disabilities approach, enter and exit, plus a few listed requirements (2010 ADA Standards, 203.9).

A private building with fewer than three stories, or with less than 3,000 square feet per story, does not need an elevator, unless it houses a shopping center or mall, the professional office of a health care provider, a transit station or an airport passenger terminal (2010 ADA Standards, 28 CFR 36.401(d)(2) and 206.2.3, exception 1).

Existing buildings. The ADAAG chapters do not address existing facilities unless they are altered (2010 ADA Standards, 101.2). When an element or space is altered, it has to comply (2010 ADA Standards, 202.3), and no alteration may leave a building less accessible than the rules for new construction require (2010 ADA Standards, 202.3.1). An alteration to an area with a primary function, such as the dining area of a cafeteria or a bank lobby, also makes the path of travel to it accessible, including the restrooms, telephones and drinking fountains that serve it, unless that costs more than 20 % of the alteration (2010 ADA Standards, 28 CFR 36.403(a)(1), (b) and (f)(1)). When the full cost would be disproportionate, the priority order starts with an accessible entrance, then the route to the altered area, then at least one accessible restroom for each sex or a single unisex one (2010 ADA Standards, 28 CFR 36.403(g)(2)).

The regulation adds its own rules for some building types: hotels and other places of lodging (2010 ADA Standards, 28 CFR 36.406(c)), shelters and group homes (2010 ADA Standards, 28 CFR 36.406(d)), housing at a place of education (2010 ADA Standards, 28 CFR 36.406(e)), assembly areas such as stadiums, arenas and stadium-style movie theaters (2010 ADA Standards, 28 CFR 36.406(f)), medical care facilities (2010 ADA Standards, 28 CFR 36.406(g)), jails and prisons, where at least 3 % of cells, and no fewer than one, have mobility features (2010 ADA Standards, 28 CFR 35.151(k)(1)), and new or altered streets, which get curb ramps at intersections (2010 ADA Standards, 28 CFR 35.151(i)). The hotel rules are in ADA hotel room requirements and the street corners in ADA curb ramp requirements.

Chapters 1 and 2: how to read the Standards, and how many

Chapter 1 is short, but it decides how every number in the rest is read:

• Minimum, maximum or absolute. A dimension not stated as a minimum or a maximum is absolute (2010 ADA Standards, 104.1). All dimensions allow conventional industry tolerances, except a requirement stated as a range with a minimum and a maximum, such as a toilet seat of 17 to 19 inches (2010 ADA Standards, 104.1.1 and 604.4).
• Rounding. When a percentage gives a fraction of an element, the next whole number is provided (2010 ADA Standards, 104.2).
• Figures and advisory notes. Figures are informational (2010 ADA Standards, 104.3), and advisory notes explain or illustrate the requirements but are not enforceable (2010 ADA Standards, 28 CFR 35.151(d) and 36.406(b)).
• Other designs. A design, product or technology that gives substantially equivalent or greater accessibility is allowed (2010 ADA Standards, 103). If it is challenged, the owner has to show it, and except for transit facilities there is no process to certify it in advance (2010 ADA Standards, advisory 103).
• Children. The requirements use adult dimensions, with children’s dimensions added for drinking fountains, toilets and stalls, sinks, and dining and work surfaces (2010 ADA Standards, 102).
• Referenced standards. Some sections send you to another code that is part of the requirement, such as ASME A17.1 for elevators, NFPA 72 for fire alarms and the International Building Code for means of egress (2010 ADA Standards, 105, 407.1, 702.1 and 207.1).

Chapter 2 is where most questions start, because it says how many. A few examples: at least one accessible route connects accessible parking, loading zones, public streets and sidewalks and transit stops to the entrance they serve (2010 ADA Standards, 206.2.1); at least 60 % of public entrances comply with the door rules (2010 ADA Standards, 206.4.1); one of every six accessible parking spaces, or fraction of six, is a van space (2010 ADA Standards, 208.2.4); where toilet rooms are provided, each one complies with section 603, with a few exceptions such as a cluster of single-user rooms (2010 ADA Standards, 213.2); at least 5 % of the seating at dining surfaces is accessible (2010 ADA Standards, 226.1); and a swimming pool has at least two accessible means of entry, one of them a pool lift or a sloped entry, but a pool with less than 300 linear feet (91 m) of wall needs only one, which has to be a lift or a sloped entry, and wave pools, leisure rivers and other pools entered from a single area also need only one (2010 ADA Standards, 242.2 and exceptions 1 and 2).

Chapter 6: drinking fountains, restrooms and showers

Chapter 6 is the one most people look up, and it is detailed enough that we split it across eight guides. The headline figures:

Mirrors, paper towel dispensers, coat hooks and the other accessories of a restroom are in ADA mounting heights.

From the Standards to the map: what Braillito Maps asks

The Standards are written for the people who design and build. Braillito Maps is for the people who go: a community map of accessible places where each place answers ten questions: step-free entrance or ramp, wide doorway, accessible restroom, accessible parking, tactile paving, braille signage, braille menu, audible signals, guide dogs welcome and a quiet environment. Each answer is yes, no or no data until someone knows, and the score of a place is the number of yes answers out of ten, always shown with its number, never by color alone.

Six of the ten questions point to a chapter of the Standards, so the guides above help you decide what to answer when you add a place:

• Step-free entrance or ramp: Chapter 3 for changes in level and Chapter 4 for ramps (2010 ADA Standards, 303 and 405).
• Wide doorway: Chapter 4, doors (2010 ADA Standards, 404.2.3).
• Accessible restroom: Chapter 6, toilet rooms and toilets (2010 ADA Standards, 603 and 604).
• Accessible parking: Chapter 2 for how many and Chapter 5 for the spaces (2010 ADA Standards, 208 and 502).
• Tactile paving: Chapter 7, detectable warnings (2010 ADA Standards, 705).
• Braille signage: Chapter 7, signs (2010 ADA Standards, 703).

The other four are only partly in the Standards, or not at all. The Standards cover fixed or built-in elements (2010 ADA Standards, 28 CFR 36.406(b)), so a braille menu or a quiet environment is not among them. Audible signals appear inside buildings: at each elevator entrance a signal sounds once for up and twice for down, or a voice announces the direction (2010 ADA Standards, 407.2.2.1 and 407.2.2.3), a voice inside the car announces the floor where it is about to stop (2010 ADA Standards, 407.4.8.2), and fire alarms are both audible and visible (2010 ADA Standards, 702.1); the elevators are in ADA elevator requirements. The audible signals of pedestrian crossings are not in the 2010 Standards. And the rules on guide dogs come from elsewhere in the ADA, explained in guide dogs.

You do not need a tape measure to add a place: mark only what you saw and leave the rest without data. And if what a place says is wrong, it can be reported. Meet Braillito Maps.

More accessibility guides

• ADA compliance: a checklist for small businesses, with the 2010 Standards section behind each item.
• ADA bathroom requirements: toilet height and position, grab bar height, sink height, stall sizes and turning space.
• ADA ramp slope: the 1:12 rule, width, landings, handrails and edge protection.
• ADA door width: 32 inches of clear width, maneuvering space, thresholds, hardware and opening force.
• Accessible parking: ADA parking requirements: how many spaces, how wide, the access aisle and the sign.
• Braille signage: which signs need braille under the ADA, how high they go, on which side of the door, and the size of the dots.
• Accessibility laws by country: the ADA, the UK Equality Act, the Accessible Canada Act, Australia’s DDA and the EU rules, and what each covers.
• ADA Title II: what state and local governments have to make accessible: existing buildings, new construction, streets and curb ramps, parks, programs and the 2024 web rule.
• ADA hallway width: clear width of hallways and corridors, the 32-inch exception, width at turns, passing spaces, floor and slope, and objects that stick out from the walls.
• ADA platform lifts: where a wheelchair lift may replace a ramp or an elevator, platform size, doors and gates, controls and use without an attendant.
• All accessibility guides