Solutions For Accessibility Challenges
William E. Endelman, AIA, principal of Seattle-based Endelman & Associates PLLC, has served as an accessibility consultant to school districts and other markets for more than 15 years. His firm's mission is to provide accessibility consulting, project management and code compliance services with objective interpretations and a risk management approach.
The basic requirements of the Americans with Disabilities Act that schools remove barriers to programs at existing buildings and construct new facilities to be fully ADA compliant should by now be understood by school districts. The ADA has been in force for 15 years. Here, Endelman offers administrators of small and large districts sage advice for recognizing and solving accessibility challenges, based upon his professional experience.
SPM: What is the biggest issue school districts face when addressing accessibility issues?
Endelman: The number-one issue for 99 percent of districts is that they don't have the money they would like to deal with districtwide issues, let alone accessibility. Because Title II of the ADA requires public entities to remove barriers to programs unless it causes an "undue burden," I suspect many districts have not done a lot with respect to ADA compliance because it is an undue burden.
SPM: So accessibility is about having enough money to upgrade facilities?
Endelman: Under Title II of the ADA for public entities, accessibility is about providing access to programs, which is different from providing access to facilities. In providing program accessibility, facilities are obviously a large part of it, but it goes beyond facilities. There are also other methodologies to solving program issues, like operational policies, scheduling students with disabilities into classrooms that are accessible and reassigning classrooms.
However, facilities solutions are much more enduring. Once you start with an operational solution, you have to train people, enforce the policy and deal with personnel turnover.
For example, I encountered a school that had a pair of double doors that were narrower than the required width. Administrators discussed a policy to hold the doors open for people to access the building. That policy requires someone to be responsible and available during all operational hours to open the door. So you can see where operational solutions can be difficult.
SPM: What does an accessibility program look like?
Endelman: Title II requires a Self Assessment, which is an ADA survey of program barriers. It also requires a Transition Plan, which is a strategy for providing access through time. For example, does the district try to make a little bit of every school accessible? Does it try to make one school in each geographic zone more accessible than others? How do administrators prioritize program barriers? That's where I think the transition plan is most important.
Accessibility is not a one-time effort. It is the ongoing updating, tracking and removal of barriers through time, especially because of the issue of the financial burden.
When it comes to programs, I think another item that school districts don't always consider is that the program is broad. It's not just about what classes students take. It includes extra-curricular activities, and sports and playing fields. It includes students, and it includes their families: How do parents with disabilities sit in bleachers to watch their children play football?
Many districts also allow community functions to occur in their school buildings. This program issue raises separate questions. For example, if you close three-quarters of a facility and leave the other quarter open for after-hour programs, does the facility still provide accessibility?
Some of these problems are somewhat complex to solve. I think what really needs emphasizing is that, to do it properly, school districts must do it in a thoughtful way — not a haphazard way.
SPM: What's required for a successful program?
Endelman: I think a successful program requires good documentation of the decisions that are made in response to day-to-day problems, as well as the required Self Assessment and Transition Plan.
Another consideration is to use consistency, because a lack of consistency can lead to litigation. What happens when a principal in one school makes a decision as to how he is going to deal with an issue and then, in another school in the district, another principal makes a very different decision? There has to be a districtwide oversight to understanding how these situations need to be handled.
Another issue school districts need to pay attention to as they begin renovation programs in various schools is compliance with ADA Accessibility Guidelines and local building codes. It's an opportunity to integrate the Self Assessment findings as part of the renovation. So, for example, if an architect is renovating one whole wing of a school, the district should provide the architect with the completed ADA Survey of that school and instruct him to pick up all items in the survey as part of the scope of the work. Doing lots of little projects to remove barriers is an opportunity to get some economies of scale.
SPM: How does a school district start providing accessibility?
Endelman: With the Self Assessment, Transition Plan and strategic planning. When we do an ADA Survey for a large school district, we provide a binder of detailed information that includes recommended solutions to remove barriers, itemized budget costs and recommendations for a general plan. That information needs to be digested by key stakeholders.
What we have done, and I think it is a successful process, is hold an all-day work session with the stakeholders and ask what are the key strategic methodologies we're going to use to resolve these challenges? That's what gets codified as part of the first Transition Plan, and it says, "Here is what we plan on doing right away to address problems, and here is our basic strategy as to how we're going to allocate funding to remove barriers. Here is how we're gong to respond to complaints."
During the work session, a number of questions are asked. Is there an ADA coordinator in the district? Is there a central point of focus? Is information on accessibility available on the district's Website? These questions get into other aspects of providing programming accessibility that go beyond accessible classrooms and restrooms.
When it comes to a Transition Plan, there are lots of approaches. I'm suggesting that a really good approach involves key people who should be part of the stakeholders team through time. The group should meet yearly and ask what was accomplished in the past year. The group should discuss changing some strategies based on what did or didn't work.
SPM: How can school districts cost effectively remove barriers?
Endelman: Through facility maintenance. Every school district has a facility maintenance budget to replace broken door hardware, broken water fountains, broken handrails and such from normal wear and tear. The opportunity is to train maintenance staff that, when they replace these items, they do it with an accessible version.
This really hit home one day when I observed maintenance staff replacing a broken handrail with one that was not compliant. That was a lost opportunity to provide accessibility at very little cost.
Again, document what is accomplished because, when you get into a litigious situation, what's going to be sought after is what you have done to provide accessibility. How much money have you spent in recent years to provide accessibility? In addition to whatever dedicated money for a barrier-removal program is spent, if you can capture barrier removal as part of maintenance or renovation programs, it's strong evidence that you're on track.
SPM: What examples do you have of successful strategic solutions?
Endelman: Older two-story schools often have specialty spaces like laboratories and libraries on the second floor. That raises questions like, "Is it more cost effective and does it provide greater accessibility to provide an elevator to the second floor, or is it more cost effective to relocate the specialty spaces to the first floor and address generic classroom space on the second floor through classroom scheduling? Also, if we install an elevator, it opens a new range of possibilities and, even though it costs more, look at the additional benefits to be gained."
Let's say you have a school that has 30 classrooms. The question is, does every one of those 30 classrooms need to be accessible in order to have an accessible program? Probably not. That's one kind of strategic analysis we take into account when coming up with solutions.
Also, with older, historic buildings, solutions can be found for preserving beauty. One example is beautifully detailed door pairs that are not as wide as current code. You don't want to remove the doors, but you do want to provide access. One solution is to install a power-assisted door opener so that, when you press a button, both doors open simultaneously. This allows you to use the doors and enjoy their fine detail and historic nature.
SPM: What tips for accessibility success can you offer?
Endelman: First, I can say with certainty that ignoring the issue, hoping it will go away, is a recipe for disaster. There really is litigation going on. There really are issues of providing education to students with equality. It's foolish to not deal with the issues.
Second, talk with leaders of other districts. Find out what works for them. Some districts have very successful programs. There's no need to reinvent the wheel.
Finally, use professional expertise so that your money is spent intelligently when making facility changes to comply with the ADA Accessibility Guidelines. The details of the requirements can be complex, so it's important that compliant solutions are used to truly provide the accessibility intended.