December 1, 1992 CRANE PLUMBING Office on the Americans with Disabilities Act Civil Rights Division FIAT U. S.

Department of Justice PRODUCTS P. O. Box 66738 Washington, D. C. 20035-9998 Attention: Ms. L. Irene Bowen, Deputy Chief Public Access Section, Civil Rights Division Reference: Americans with Disabilities Act (ADA) - Clarifications Dear Ms. Bowen: Due to pending jobs in progress and in light of your comments made at the ASPE Technical Session, listed below are areas that need immediate interpretation and clarification. 1. Section 4.19.2 ADA Acceptance of 6-15-92 Draft of A117.1 on Knee and Toe Clearances. My letter to Mr. John Wodatch on Sept. 29, 1992. (Your acknowledgement DJ 202-PL-341 dated 11-3-92.) 2. Section 4.16.3 Closet Seat Height - ADA is min. 17" - Max. 19" At ASPE Meeting you stated 19 1/4"-19 1/2" was alright. Please clarify. 3. Section 4.21.2 Shower Stalls - Size and Clearance A. 36" x 36" Size (1.) Where is measurement taken - inside or outside? (2.) If this is inside is the measurement taken on centerline, front, back, etc.? (3.) What is the tolerances on the 36 inch dimension? It is being interpreted as 36 inch without any tolerances per Section 3.1 as dimensions being absolute. B. 60" x 30" (1.) Where is measurement taken - inside or outside? (a.) If it is inside, the shower will not fit into the pace required for a bathtub. A standard bathtub is 60" x 30" on the outside. (b.) If it is outsider what is the minimum inside dimension? In Figure 57(b) the minimum opening as I interpret is 36" minimum. Is this correct?

(2.) What is the tolerances on the 60" x 30" dimensions? It is being interpreted as 6O" without any tolerances and 30" minimum. The 60" being absolute per Section 3.1. (3.) In Figure 57(b) the front to back dimension is shown as 36". Is this to mean that you have to have (2) two sizes: 60" x 30" min. and 60" x 36"? (Page 1 of 3) CR/PL,INC. P.O. Box 389 Nevada, Mo. 64772 417-667-6048 01-02356 Ms. Bowen 12-1-92 2 of 3

C. Section 4.21.3 Seats - If the seat extends the full depth of the stall this will force the shower curtain to hang outside the unit allowing water to fall on the floor outside of the unit causing a wet slippery unsafe condition to exist. D. Section 4.26.2 Grab Bars - Clearance between grab bar and wall is called out as 1 1/2 inches. What is the tolerance on this dimension. It is being interpreted as absolute per Section 3.1it must be 1 1/2 inches no more no less. E. Section 4.21.7 Curbs - 60" x 30" - Calls cut no curb - What keeps water from running out across floor? 4. Section 4.18.2 Urinals - What constitutes an elongated urinal? There is no definition that I can find. 5. Section 2.2 Equivalent Facilitation - Where do we go to receive an interpretation of this Section? 6. Section 3.2 Dimensional Tolerances - Can you define "all dimensions are subject to conventional building industry tolerances for field conditions"? 7. Section I PURPOSE - The purpose states that "This document sets guidelines for accessibility to places The ADA is being interpreted as absolute law with no variations. If it is not just like the illustrations or verbage it is wrong. Different interpretations whether it is inside or outside dimensions etc. 8. Section 3.1 Graphic Conventions - "Dimensions that are not marked minimum or maximum are absolute, unless otherwise indicated in the

text or captions." This is the section that people are referring when they say that there is no tolerances or variations. This section needs to be deleted or changed. 9. Section 4.20.3 Seat - "In the tub seats" shown in Fig. 33 are not available due to liability concerns. 10.There is no mention of a shower curtain on bathtubs and/or showers. Is it not to be used? Where is it to be located if it is to be used? 11.Is the Appendix part of the enacted law? Are the explanations in the Appendix mandatory? 12.Since the ADA Accessibility Board is a member of the ANSI A117.1 Standards Committee, will the ADA adopt the new language and changes made to the ANSI A117.1 Standard Final Draft dated 6-15-92? If they do, when will it go into affect? 01-02357 Ms. Bowen 12-1-92 3 of 3

It was a pleasure talking with Ms. Janet Blizard on the above concerns. As Ms. Blizard and I discussed, we, CR/PL, L. P. and the Plumbing Fixture Manufacturers, would be interested in attending a Meeting with the ADA Accessibility Board and the Department of Justice to discuss the above areas of concern. I feel that with some clarifications and explanations that the intent of the Americans with Disabilities Act (ADA) could be made more understandable and useful. If further information is needed or questions arise on the above, please let me know. Thank you. Sincerely, CR/PL, L.P. (Signature) _____________________________

W. E. Olson, Sr. Engineering Supervisor WEO/nc cc: R. L. Klaess - Evanston M. Klimboff - Cinn. M. Nagley - Dallas B. Peck - Dallas K. Phelan - Evanston P. L. Thompson - Somerset 01-02358