Spring 2007

ICC Accessibility Codes Help New York Fans with Disabilities
Enjoy Accessible Features of New Ballparks
By Dominic Marinelli, Director, Accessibility Services, United Spinal Association

Stadiums and arenas being planned and constructed today will provide accessibility features to better meet the needs of fans with disabilities. United Spinal Association has been working on several stadium projects in order to ensure compliance with the latest and greatest accessibility requirements provided in the revised ADA/ABA Accessibility Guidelines, the International Building Code and the International Code Council’s American National Standard for Accessible and Usable Buildings - A117.1.

Responding to accessibility modifications mandated by the Department of Justice (DOJ) in their existing stadium, the New York Yankees instructed HOK Sports Architects and United Spinal Association to work with New York City’s very active disabled community to solicit input on ways to make the new stadium as accommodating to Yankees’ fans with disabilities as possible. All suggestions are reviewed by the design team – even if their inclusion would exceed existing city and federal accessibility requirements.

“One suggestion that made a lot of sense was from a wheelchair user who requires oxygen during events. By simply adding an electrical receptacle within the wheelchair viewing location, he will be able to plug-in his medical equipment,” Yankees’ ADA Coordinator Carol Laurenzano said.

Beyond the increased number of wheelchair viewing locations required by New York City’s accessibility requirements Local Law 58, the stadium will have the requisite lines of sight over standing spectators for wheelchair users, whose viewing locations will also be integrated throughout the seating bowl. Although not required by city and federal accessible requirements, many fans with disabilities have requested unisex toilet rooms for privacy and to assist family members with disabilities. These accessible family toilet rooms are required by the International Building Code (IBC) for large Assembly and Mercantile occupancies. Even though the IBC has not yet been adopted in New York City, these accessible single-use toilet rooms will be featured on all levels of the stadium.

The stadium will also feature large electronic display boards on the first and third base facades that will be dedicated to captioning public address announcements for fans with hearing disabilities. The ADA’s Accessibility Guidelines do not provide specific requirements on the need to provide this type of equivalent communication. Many pro stadiums, ballparks and arenas accommodate people with hearing disabilities by distributing hand-held devices that provide text messages of public address announcements to avoid competing with the revenue that can be generated by using the display boards as advertising space. Providing these accessibility features is much less of a challenge than ensuring that they can be utilized by the people they were designed to benefit.

The Department of Justice (DOJ) allows venues to sell wheelchair viewing locations on a level when all the able-bodied locations on that level are sold. DOJ does not permit ticket-sellers to ask people requesting wheelchair viewing locations for proof of their disability. In venues that sell-out their stadiums on a regular basis, ticket scalpers gobble-up the wheelchair viewing locations and sell the seats to able-bodied fans. This is most frustrating to long-time Yankees fan Kevin Feighery, whose daughter uses a wheelchair.

“Nothing is more frustrating then going to a game and seeing only able-bodied individuals in areas dedicated for wheelchair users and their families,” Feighery said. “Overcoming DOJ’s self-identification restrictions, while ensuring that the relatively limited number of accessible locations are available to those who need them the most is the real challenge.”

While the needs of wheelchair users and people with hearing disabilities can be met in measurable ways, the game experience of individuals with visual disabilities goes well beyond signage with contrasting colors identifying spaces and way finding surfaces from parking and public transportation.

Vision impairments range from total blindness to degrees of low vision. Contrary to the beliefs of many, individuals who are blind and vision impaired can derive equal benefit and equally participate in the ballpark game experience with certain reasonable accommodations. For those who require such accommodations, lacking them pose insurmountable barriers. Individuals with low vision using adaptive technology require unobstructed sight lines and close proximity to the playing field, which also provides access to the sounds of the game. Instantaneous audio description is normally provided by local radio broadcasts and made available on the stadiums’ Assistive Listening Devices on an alternate channel. Certain low vision fans require access to video displays to review replays. Protection from foul balls and bats is essential, as many blind and vision impaired attend the games without sighted companions. Guide Dog users require an appropriate amount of space for their canine partners.

Rick Morin, Board Member of the Council of Citizens with Low Vision International, points out that "…. ADAAG specifications for the location and configuration of wheelchair accessible locations are appropriate for many individuals who are blind and partially sighted. Individuals who are blind and vision impaired represent roughly 10 percent of the total disabled community and a pragmatic approach to accommodating individuals with vision impairments is to make a limited number of wheelchair accessible locations available to the blindness community." Rick encourages dialogue between DOJ, stadium owners and cross-disability groups to arrive at a workable solution for all members of the disabled community.

The Assembly Area Task Force of the A117.1 committee has used the existing Yankee Stadium as a venue for meetings. The task force is comprised of staff members of the United States Access Board, the International Codes Council, representatives of disability organizations, theater-owners and designers of assembly areas. The goal of the committee is to ensure that updates proposed to the 2008 edition of A117.1 are consistent with the accessibility requirements of the updated Americans with Disabilities Act Accessibility Guidelines (ADAAG).

In order to make compliance with accessibility requirements easier, the Access Board has sought to harmonize its updated accessibility guidelines for new or altered facilities covered by the Americans with Disabilities Act (ADA) and the Architectural Barriers Act (ABA) with the IBC and A117.1. The more stringent aspects of both standards have also been referenced along with New York City’s accessibility requirements (Local Law 58) at the new home of the New York Mets – Citi Field.

Careful consideration to providing access has been emphasized at unique fan attractions, like platforms that provide viewing of the bullpen and baseball diamonds right within the new ball park.

Both the new Yankee Stadium and Citi Field are scheduled to be ready for Opening Day – 2009.

 
The U.S. Justice Department Publishes Guidance On ADA Compliance
Department of Justice (DOJ) is preparing guidance material for use by state and local governments in complying with the Americans with Disabilities Act (ADA). The “ADA Best Practices Tool Kit” provides guidance on identifying barriers to access in government programs, services, activities, and facilities and how to correct them. The first installment, released in December, provides an overview of the ADA and relevant regulations. A second section covers notice and grievance procedures and includes a compliance checklist and sample notices and policies. The information is posted on DOJ’s website at:

www.usdoj.gov/crt/ada/pcatoolkit/abouttoolkit.htm.
Additional installments will be posted throughout the year as they become available.
 
Accessibility Services Provides Instruction at AIA Orange County’s 2006 “CES Catch-Up Conference”
By Jennifer Perry, Compliance Specialist

On December 14, 2006, United Spinal Association presented a continuing education program for AIA member in Orange County, California entitled “Update: State and Federal Accessibility Requirements”. The goal of this program was to provide AIA members with an overview of the Revised ADA/ABA Accessibility Guidelines, released by the US Access Board on July 26, 2004. Accessibility Services has provided a similar program for a number of AIA sponsored conferences, including, AIA Illinois, AIA Georgia, AIA South Atlantic Region (Tennessee, North Carolina, South Carolina and Georgia), and AIA New York.

The program was held at The Atrium Hotel, Irvine, California and qualified for two (2) AIA/CES Learning Units applicable towards Health, Safety and Welfare (HSW) credit. AIA Orange County hosts this annual event in order to benefit the design community by allowing individuals to meet their end-of-the-year AIA membership and various state licensing education requirements. The Accessibility Services program’s Leaning Objectives included:

  • Participants will develop an understanding of the scoping differences between ADAAG and the revised Americans with Disabilities Act and Architectural Barriers Act Accessibility Guidelines;
  • Participants will understand the major changes between current ADAAG and the Revised ADA/ABA Accessibility Guidelines, and how to apply them to specific projects/areas, including:
  Press boxes
Employee work areas
Assembly areas
Toilet rooms

Accessibility Services was honored to be a part of this Chapter’s continuing education programming, and we enjoyed meeting the Orange County design professionals. While Accessibility Services has provided instruction on state and federal accessibility requirements nationwide, this was our first continuing education program that was provided in conjunction with an AIA California Chapter. We look forward to meeting and working with other California AIA Chapters and providing technical assistance, consulting and training on state and federal accessibility requirements to other California AIA members.

Should you wish to learn more about Accessibility Services and our programs, please contact Jennifer Perry at 610.757.0044 or via email at jperry@unitedspinal.org

 
Updates On Barrier-Free Design Publications

Many of you have copies of our Barrier Free Design publications. The following two publications are still current and can still be used: Barrier-Free Design: Selected Federal Laws and ADA Accessibility Guidelines and Barrier-Free Design: New York City.
If you need additional copies of these two publications, you may call (800) 444-0120 or e-mail: publications@unitedspinal.org and place an order for a charge of $10 per copy.

Three of our publications are out of date and will not be reprinted. They are Barrier-Free Design: New York State, Barrier-Free Design: New Jersey, and Barrier-Free Design: Pennsylvania.

 
Tough Technical Questions
By Linda Volpe, Compliance Specialist

Accessibility Services’ staff spends a great deal of time answering technical questions in response to calls, emails and posts on our online Accessibility Requirements Forum. Answering technical questions keeps all of us up-to-date with city, state and federal requirements and gives us an idea of which requirements are the most confusing to architects, design professionals and code officials. Once in a while, we receive a question that really gets us digging in the code books, looking for the correct answer. We wanted to share a few of these questions with you, in hopes that you’ll learn something new, just like we did.

Do any requirements exist governing the location of kick plates on doors?

The Americans with Disabilities Act Accessibility Guidelines (ADAAG) provides the following guidance in its appendix regarding the location of kick plates on doors:

A4.13.9 Door Hardware. Some disabled persons must push against a door with their chair or walker to open it. Applied kick plates on doors with closers can reduce required maintenance by withstanding abuse from wheelchairs and canes. To be effective, they should cover the door width, less approximately 2 in (51 mm), up to a height of 16 in (405 mm) from its bottom edge and be centered across the width of the door.

Is visual contrast ever required on stairways?

The revised ADA/ABA Accessibility Guidelines provides an advisory note in Section 504.4 on tread surface, which recommends providing visual contrast on tread nosings so that stair treads are more visible for people with low vision.

Advisory 504.4 Tread Surface. Consider providing visual contrast on tread nosings, or at the leading edges of treads without nosings, so that stair treads are more visible for people with low vision.

The ICC/ANSI A117.1-2003 requires visual contrast of dark-on-light or light-on-dark on the leading 2 inches of the tread.

504.5 Nosings. The radius of curvature at the leading edge of the tread shall be ½ inch (13 mm) maximum. Nosings that project beyond risers shall have the under side of the leading edge curved or beveled. Risers shall be permitted to slope under the tread at an angle of 30 degrees maximum from vertical. The permitted projection of the nosing shall be 1 ½ inches (38 mm) maximum over the tread or floor below. The leading 2 inches (51 mm) of the tread shall have visual contrast of dark–on–light or light–on–dark from the remainder of the tread.

If you have any unanswered technical questions, Accessibility Services invites you to visit our online Accessibility Requirements Forum: http://www.accessibility-services.com/category/forum/

 
Fair Housing Act Requirements for Exterior Accessible Routes
By John Rooney Compliance Specialist

The Fair Housing Amendments Act (FHAA) was signed into law on September 13, 1986 and expands the protections found in Title VIII of the Civil Rights Act of 1968, which prohibits discrimination on the basis of race, color, religion, sex or national origin in housing sales, rentals or financing. The FHAA extends the prohibition of discrimination to persons with a disability and families with children.

One aspect of the Fair Housing Amendments Act is the design requirements for newly constructed multifamily dwellings. Structures with four or more dwelling units that are built for first occupancy after March 13, 1991 are subject to the design requirements of the Fair Housing Act.

The Fair Housing Act Guidelines contain seven design requirements for multifamily housing that is covered by the act. The focus of this article is Requirement 1, which requires at least one building entrance on an accessible route, unless it is impractical to do so because of terrain or unusual characteristics of the site. The burden of establishing that site impracticality exists is on whoever designs and constructs multifamily covered by FHAA.

Accessible exterior routes are required by the Guidelines to be provided from public transportation stops, accessible parking spaces, accessible passenger loading zones, and public streets and sidewalks to accessible building entrances unless it can be shown that it is impracticable due to terrain or unusual characteristics. During the planning stage all of the different ways that people arrive at a site must be considered in order to ensure compliance with FHAA requirements.

The Guidelines also require exterior accessible routes to all facilities, elements and spaces that are part of common and public use areas. Examples include, but are not limited to, outside mailboxes, playgrounds, gazebos and refuse disposal facilities.

There are two tests that can be used to determine if site impracticality due to difficult terrain exists on a site. The two tests are the Individual Building Test and the Site Analysis test. There is also a test to determine if the FHAA requirements can be reduced in sites with unusual characteristics. The latter is used in sites located in areas such as a federally designated flood-plain or a coastal high-hazard area.

It is important to understand the scope of where and when exterior accessible routes are required and to properly use the aforementioned tests to determine if site impracticality can be considered. For a complete and thorough understanding of the FHAA requirements and the proper use of site impracticality tests it is a good idea to review the Fair Housing Act Design Manual. This publication can be obtained in a PDF format at the following link: http://www.huduser.org/Publications/pdf/fairhousing/fairintro.pdf

 
TECHNICAL STUFF

Question: If you provide a parallel approach to a lavatory within a Type B, Option A bathroom, does the cabinetry have to be removable?

Answer: If you provide a parallel approach to the lavatory then the removable base cabinet is not required. Please note that the 30" by 48" clear floor space is required to be centered on the lavatory.

If a front approach is provided then a base cabinet (if provided) has to be removable and knee and toe clearances are required.

Below is the applicable section in the ICC/ANSI A117.1-2003:

1004.11.3.1.1 Lavatory. A clear floor space complying with Section 305.3, positioned for a parallel approach, shall be provided. The clear floor space shall be centered on the lavatory.

EXCEPTIONS:

1. A lavatory complying with Section 606.

2. Cabinetry shall be permitted under the lavatory provided such cabinetry can be removed without removal or replacement of the lavatory, and the floor finish extends under such cabinetry.

 
 


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