# 147 III-7.3000 III-7.

5105 September 30, 1994

Mr. Gene Colin Mr. Kermit Robinson State of Washington State Building Code Council 906 Columbia Street, SW P.O. Box 48300 Olympia, Washington 98504-8300 Dear Mr. Colin and Mr. Robinson: This is in response to your letter regarding the application of title III of the Americans with Disabilities Act (ADA) to self-storage businesses that rent storage units to people who wish to store personal goods. The ADA authorizes the Department of Justice to provide technical assistance to individuals and entities that have rights or responsibilities under the Act. Pursuant to that authority, this letter provides informal guidance to assist you in understanding the ADA. However, this technical assistance does not constitute a legal interpretation of the statute, and it is not binding on the Department. Your letter asks whether, in newly constructed or altered self-storage businesses, each individual storage locker or room must be constructed to be accessible or whether only a certain percentage may be accessible. Self-storage areas may be covered by several different ADA provisions, depending on their placement and purpose. For example, if each self-storage facility is an independent building, then each separate facility will be covered by 4.1.3 of the ADA Standards for Accessible Design (Standards). Therefore, each such facility must comply with all applicable requirements of the ADA Standards, including the requirement to provide an accessible entrance that is located on an accessible route. On the other hand, if self-storage lockers are part of a larger building, that building must provide accessible entrance(s) to the building, accessible routes to the accessible

storage lockers, and other accessible elements addressed in ​4.1.3 of the ADA Standards. However, the storage lockers, themselves, would not all be required to be accessible. Rather, under 4.1.3(12), at least one of each type or size of storage facility must be accessible. The requirements for accessibility of such storage lockers will vary depending on the types of storage lockers provided. If storage lockers are intended for people to enter, the accessible locker will have to provide an accessible entrance, accessible interior controls, and accessible interior space, as well as accessible storage spaces. If, on the other hand, storage lockers are not intended for people to enter, they need not provide an accessible entrance or accessible interior space, but rather they must simply provide clear floor space at the locker, accessible door opening and closing mechanisms, and reachable storage space, as provided in 4.25 of the ADA Standards. I hope that this information is helpful to you. Sincerely,

John L. Wodatch Chief Public Access Section