XX DEC 29 1993

Mark S. Rabinowitz Paul Rabinowitz Glass Company, Inc. 1421 S. 2nd Street Philadelphia, Pennsylvania 19147 Dear Mr. Rabinowitz: This is in response to your letter dated June 8, 1993, and your telephone conversations with Ms. Johansen of our staff on June 8, and June 14, 1993, regarding exterior doors at banks. The ADA authorizes the Department of Justice to provide technical assistance to individuals and entities that are subject to the Act. This letter provides informal guidance to assist you in understanding the ADA accessibility standards. However, this technical assistance does not constitute a legal interpretation of the application of the statute and it is not binding on the Department. Your initial question when you called the information line dealt with exterior doors at existing banks that may be too heavy for some people with disabilities to open. You asked if it would be permissible to put a sign on the door with a bell for assistance. This is permissible. Existing facilities of this type have an obligation under title III of the ADA to remove architectural barriers to access where such removal is readily achievable. However, where the ADA Design Standards for new construction specify requirements for a particular element, the barrier removal obligation does not require existing facilities to exceed the Design Standards. The ADA Standards for Accessible Design applicable to new construction do not set a limit for the maximum door opening force for exterior hinged doors. See the ADA Standards for Accessible Design Section 4.13.11 and 4.13.12, Appendix A to the enclosed title III regulation. In your letter you state that you also want to provide a sign with a bell to ring for assistance on doors that are double leaf and do not meet the width requirements and on doors on which the hardware does not meet the Standards. As Ms. Johansen explained, title III obligates bank to remove architectural

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-2barriers to access where it is readily achievable to do so. Readily achievable means easy to accomplish without much difficulty or expense. The factors that determine whether a particular action is readily achievable are discusses at pp. 35568-35570 and 35597-35598 of the enclosed Federal Register document and Section III -4.4000 of the enclosed Title III Technical Assistance Manual. Taking into account these factors, if it is readily achievable for the bank to install the appropriate hardware and to alter the doors to meet the width requirements, it must do so. Alternatives to barrier removal such as the bell arrangement you describe are appropriate, and indeed required, only if barrier removal is not readily achievable. We hope this information is helpful to you. Sincerely,

Joan A. Magagna Deputy Chief Public Access Section Enclosures Title III Regulation Title III Technical Assistance Manual