ADA DESIGN
Last month a school board member called me with major money concerns. His district had contracted with an architect to produce an ADA report. The architect surveyed each building using the ADA Standards for Accessible Design, decided what needed to be done to bring each facility to the level of those standards and estimated the cost of the renovations. The report indicated that the district would need to spend $2.5 million. The school board member wondered exactly what his district’s obligation is under the ADA. This gets us to a common error.
Using New Construction Requirements for Old Buildings
Public school districts must comply with Title II of the ADA. The Department of Justice’s Title II regulations have different requirements for new construction, alterations and existing facilities. New construction must be designed and built to be accessible to and usable by people with disabilities. Alterations that affect usability have the same requirement. Existing facilities (defined as facilities that were built before January 26, 1992) have a different requirement that focuses on making sure students with disabilities (and others with disabilities who use the schools) have an equal opportunity to participate in school programs, services and activities.
The Title II ADA regulations require schools to make sure that each program, service and activity, when viewed in its entirety, is accessible to people with disabilities. The regulation does not require school districts to make all existing facilities, or every part of an existing facility, accessible.They can provide program access by several methods.
1. Reassignment of services to an accessible location. For example, rather than put in an elevator, classes or activities can be relocated to accessible ground-level floors within a building or reassigned to other buildings that are accessible. School districts may make programs accessible to parents with disabilities by reassigning their child to an accessible school.
2. Purchase, redesign or relocation of equipment. Often equipment can be raised or lowered to make it usable; sometimes redesign may be necessary. Redesign may include relocating a control panel, replacing grip/twist devices (doorknobs and drinking fountain faucets) with levers, altering door closure devices and providing audible or visual alarm signals for people with
visual or hearing impairments.
3. Assignment of aides. Aides may be needed to ensure that people with disabilities exit safely from program areas in an emergency. If equipment in a laboratory classroom is inaccessible to a student with a disability, an aide may assist the student.
4. Structural changes to eliminate barriers. Although structural changes are not required as a matter of course, they must be done if there is no other way to provide program accessibility. Structural changes might include installing a ramp, widening a doorway, installing a lift or lowering a toilet.
So what to do with that architect’s report? Well, it’s a great basis for program accessibility planning. In an assessment of program accessibility in existing facilities, it’s helpful to know the barriers and access issues in each facility.
When deciding whether, which and how many structural changes are needed to ensure program accessibility, school districts should provide access at schools dispersed throughout their district so that students with disabilities can attend school at locations comparable in convenience to those available to students without disabilities. School districts do not have to make all of their existing classroom buildings accessible to students with disabilities, provided that all programs offered in inaccessible classroom buildings are also available in other accessible schools in the district and that the accessible schools are comparable in convenience to those available to students without disabilities. School districts may not make only one facility or part of a facility accessible if the result is to segregate students with disabilities in a single setting.
It’s important to factor in another federal law: Section 504 of the Rehabilitation Act of 1973, as amended. Section 504 prohibits discrimination on the basis of disability in any program or activity that receives federal funds. Virtually all school districts receive federal financial assistance and have been required to comply with Section 504 for many years (the 504 regulations went into effect June 3, 1977). The Department of Education’s Section 504 has new construction and alteration requirements, as well as a program accessibility requirement for existing facilities. So, although facilities built before January 26, 1992 are“existing” facilities under Title II, if they were built on or after June 3, 1977, they should have been accessible under the Section 504 new construction standards.
Using Children’s Guidelines
Responding to the suggestions of architects and others concerned about facilities used primarily by children, the U.S. Access Board released accessibility guidelines in 1998 for building elements designed primarily for children’s use. The guidelines cover ages 12 and younger, and include specifications for drinking fountains, toilets, toilet stalls, grabbars, sinks, and fixed counters and tables. Although the children’s elements guidelines have not been adopted by the Department of Justice as part of their ADA regulation, the guidelines can be used to provide equivalent facilitation. Equivalent facilitation means that an alternative design (in this case alternative to the current adult dimension in the ADA Standards for Accessible Design) may be used if the design provides substantially equivalent or greater access to and usability of a facility.
Wheelchair-Accessible and Ambulatory Stalls
If a toilet room is being built or substantially altered and the room has six or more toilet stalls, one stall must be a 36-in.-wide "ambulatory" stall. People who walk with crutches, a cane, a walker or who have limited balance usually find it safer to use a stall that has parallel grab bars. A toilet room with six stalls should have one wheelchair accessible stall, one ambulatory and four regular stalls.
Areas Without Their Own Section in the Standards
The standards tell us how many wheelchair spaces are needed in an auditorium (there’s a chart) and how many parking spaces have to be accessible (there’s a chart), but they don’t include specifics for every possible design situation. If the standards don’t mention an element or indicate how many elements should be accessible (a laboratory workstation is an element), make a reasonable number (but at least one element) accessible. Use technical standards from the ADA Standards for Accessible Design for reach range, floor clear space, counter height, etc.
Assistive Listening Devices In Auditoriums, Etc.
The ADA Standards require that newly constructed and altered fixed-seating assembly areas, that accommodate 50 or more people or have audio-amplification systems, include a permanently installed assistive listening system. Other newly built or altered assembly areas must have a permanent system or an adequate number of electrical outlets or other wiring to support a portable system. There are basically three types of hardwired systems: induction loop, FM radio transmission and infrared. The standards also require a sign indicating the availability of the system.
Ramps That Are Exactly 1:12 Slope
The ADA Standards for Accessible Design actually says“the least possible slope shall be used for any ramp. The maximum slope in new construction shall be 1:12.” Watch someone push her wheelchair up a 1:12 ramp and you will understand how steep it is. Make the ramp as gradual as the site will allow. A walkway (1:20 or more gradual) is not required to have handrails or level platforms. It’s much more inviting and much less maintenance.
Emergency Evacuation Planning
While not strictly a design issue, emergency evacuation is a critical area that shouldn’t be overlooked. Only newly built, nonsprinkled buildings are required to have areas of rescue assistance, but you may want to consider including areas of rescue assistance in sprinkled buildings and older facilities. Evacuation plans might include a combination of areas of rescue assistance, evacuation devices and buddy systems.
Websites and Software Technology can be a terrific boon or a terrible barrier for people with disabilities. Information technology is accessible to people with disabilities if it provides more than one way for users to gain access to and manipulate information. Accessible features should: provide a text description for nontext elements, such as photos, graphics, audio, video and animation; avoid use of color alone to convey essential information; use high contrast foreground and background colors for those with visual impairments and; avoid animations that flash at frequencies between 2Hz and 55Hz that trigger seizures.
Universal Design
Although the following aren’t required, they are universal design issues that will make school facilities more usable. While ADA standards are minimum standards, universal design is a worldwide movement based on the concept that all facilities, products, technology and environments should be designed to consider the needs of the widest possible array of users.
Acoustics
It’s is important to improve acoustics for students with hearing disabilities, and students with normal hearing will also benefit from better acoustics.
Classroom Acoustics: A Resource for Creating Learning Environments, the Acoustical Society of America reports that speech intelligibility rating is 75 percent or less in many U.S. classrooms. Design considerations include placement of HVAC (heating, ventilation and air conditioning) systems, HVAC duct arrangements, exterior and interior wall construction, room entrance design, ceiling design, classroom layout and location of gymnasiums and other noisy areas.
Ergonomics
Poor posture in children whose muscular skeletal systems are still developing is a major problem. Repetitive strain injury is affecting students. Design considerations include chairs and tables that can be adjusted and teaching students how to make the best adjustments for themselves.