The Americans with Disabilities Act Accessibility Guidelines (ADAAG) will require retailers to rethink existing layouts as well as new designs. That was the central theme of the SPECS session, “ADAAG Is Changing, Are You?” which was led by Douglas J. Anderson, a partner with Chicago-based LCM Architects and a member of the U.S. Access Board, and Brent Styles, senior VP, Jones Lang LaSalle, Chicago. Together, the speakers illuminated the major regulatory changes retailers must address.
A handful of key ADAAG changes could have a significant impact on construction and renovation projects. On the employee side, work areas comprising more than 1,000 sq. ft. are required to maintain accessible circulation paths with a minimum of 36-in. wide routes. In addition to potentially requiring an increase in space allocation for employee work areas, this could also impact the options for how equipment is laid out in the space.
Throughout the retail environment, the side-reach range for equipment such as self-serve kiosks, vending machines and ATMs has been given a tighter window. The maximum height range has gone from 54 in. to 48 in., and the minimum low-reach range has been raised from 9 in. to 15 in.
Several changes are on tap for water closet and restroom facilities, including a slight tweak to the centerline requirement, which has been given a range of 16 in. to 18 in. compared to the current 18-in. requirement. This tiny modification could potentially allow room for construction tolerance. Additionally, the minimum clearance range for the apron beneath lavatories and sinks that was at 29 in. has been adjusted to 27 in.
However, a big adjustment is in store for the space between the edge of the lavatory and the centerline of the water closet. Previous standards called for a minimum of 18 in. between these points, but the new ADAAG requires 60 in., which will likely increase the square-foot allocations for single-occupancy toilet rooms.
Although this short course in ADAAG changes was beneficial, perhaps the bigger take-away message for SPECS attendees was the clarification that the retailer has ultimate responsibility for compliance.
The most common, and potentially most costly, mistakes a business makes, according to Anderson and Styles, are assuming that ADA regulations have been met, or that the architect holds the liability when ADAAG rules are not enforced. Similarly, assuming that a local building permit confirms compliance, or that buildings constructed prior to 1992 are exempt, or that barrier removal is a one-time obligation, are all potential pitfalls.
“It’s also wrong to assume that architecture is the only discipline that must comply with ADAAG,” noted Anderson. “Civil engineers, decor providers, site planners and equipment manufacturers all must be in compliance.”
Anderson and Styles also cited problems of noncompliance on the exterior of buildings that often are overlooked by retailers. Parking lots can prove particularly difficult, and Styles noted that issues with slope and aisle size can violate the ADAAG. Accessibility to curb ramps and accessibility through vestibules and entrances are areas to watch.
“A high percentage of the businesses we work with have exterior issues, and these are as likely to occur with new stores and new parking lots as with older properties,” cautioned Styles.
In closing, the SPECS attendees were given recommendations for strategies that might help them avoid ADA litigation. Topping the list, they were told to take a proactive rather than reactive approach to problem areas. Identifying and focusing on problem stores, particularly those located in “litigious states,” was suggested. Finally, they were encouraged to develop written plans and establish definitive time lines for addressing problem areas, as well as create procedures and control processes that would ensure new construction and renovations were conducted in compliance with ADAAG.