JUL 22 1994 Mr. Gene Colin Chair State Building Code Council State of Washington 906 Columbia Street SW P.O.

Box 48300 Olympia, Washington 98504-8300 Dear Mr. Colin: Thank you for your supplemental submissions of August 20, 1993, and March 23, 1994, in support of your request for certification that the Washington State Regulations for Barrier Free Design (WSR), as adopted on November 8, 1991, and amended on November 13, 1992, meet or exceed the new construction and alterations requirements of title III of the Americans with Disabilities Act (ADA). We greatly appreciate your thorough responses to our initial review of the WSR. We are still awaiting written confirmation from your staff of the legal effect of the State Building Code Council's (Council) "interpretations" of the WSR, and without such confirmation we are unable to issue a preliminary determination regarding certification. However, in order to avoid any unnecessary delay, we have proceeded to review the WSR and the additional information, explanations, interpretations, and amendments provided in your recent submissions. Our analysis of the material you have submitted is discussed in detail in the attached side-by-side comparison. That analysis addresses only the issues raised in our initial response to your certification request and those raised by the 1992 amendments to the WSR. For each issue, the side-by-side comparison contains the relevant ADA provision in the left column, the WSR provision, with any amendments, in the center column, and the Department's original (May 1993) comment in the right column. Following that, the comparison provides, in the center column, the Council's cc: Records; Chrono; Wodatch; Blizard; Hill; FOIA \udd\hille\wash\final.mem

01-03192 ​ -2"comment" (italicized) and, in the right column, our response (underlined and bracketed) to the Council's comment. Following that, the analysis provides, in the center column, any interpretation (italicized and underlined) issued by the Council to address the issue, and, in the right column, our response (underlined and bracketed) to the interpretation. Based on this analysis, we have determined that in only a very few areas does the WSR not meet or exceed the relevant requirements of title III of the ADA. Therefore, upon correction of these few remaining problems, we propose to recommend that the Assistant Attorney General issue a preliminary determination of equivalency pursuant to 42 U.S.C. S 12188(b)(1)(A)(ii) and 28 C.F.R. SS 36.601 et seq. The remaining areas of nonequivalency are discussed below and noted in the right column of the side-by-side analysis in underlined and bracketed text. Many of these issues may be addressed through further interpretations of the WSR. A few others may require amendments to the WSR. A number of items that do not necessarily pose obstacles to certification require further discussion: 1) A number of items that are addressed by the ADA Standards for Accessible Design (ADA Standards), 28 C.F.R. Part 36 Appendix A, are not addressed by the WSR, including limitedflow toilet paper dispensers (Standard 4.16.6), telephone books (Standard 4.31.7), and audible alarms (Standard 4.28.2). These omissions from the WSR are based, in part, on the difficulty of regulating such items at the pre-construction/pre-occupancy stage. Because the omissions are limited to such "non-code" items, they will not prevent certification. Rather, the certification determination will not apply to those omitted items at all. Therefore, if such equipment is installed in a building, the certification determination will not constitute evidence of ADA compliance with respect to such equipment. 28 C.F.R. S36.607(a)(1). This limitation of the certification determination should be noted in any publication of the WSR if certification is issued. 2) The certification determination will be limited to the version of the WSR, including the amendments and interpretations,

that has been submitted to the Department. The certification determination will not apply to amendments or interpretations that have not been submitted to and reviewed by the Department. This limitation should be noted in any publication of the WSR if certification is issued. In addition, any future uncertified amendments should be distinguished from the certified version of the WSR. Finally, because the certification determination will be based, in part, on official interpretations of the WSR, those 01-03193 -3interpretations should be made public and published together with the WSR. 3) The certification determination will not apply to waivers granted under the WSR by local building officials. 56 Fed. Reg. 35592 (July 26, 1991), 28 C.F.R. Part 36, Appendix B. Therefore, if a builder receives a waiver, modification, variance, or other exemption from the requirements of the WSR for any element of construction or alterations, the certification determination will not constitute evidence of ADA compliance with respect to that element. Examples of such waiver provisions include WAC S 51-20-3101(e) (allowing modifications where full compliance is impractical), WAC S 51-20-3113 and S 51-20-3114 (allowing modifications when full compliance would threaten or destroy the historic value of a historic building), and WAC S 5120-3112(a)(2) (allowing a 20% cost limit on provision of access in the path of travel to altered primary function areas). This limitation of the certification determination should be noted in any publication of the WSR if certification is issued. 4) The WSR relies on building classifications that differ from those used by the ADA. This will not prevent certification of the WSR because the effects of these differences on accessibility have been substantially eliminated by the Council's interpretations. It should be made clear to building code enforcement officials that the WSR's general classifications should be applied flexibly in the context of accessibility to ensure full ADA compliance. 5) The Appendix to the WSR contains the "U.S. Architectural and Barriers Compliance Board Americans with Disabilities Act Guidelines for Automated Teller Machines," WAC S 51-20-93120. These provisions contain the former ADA Standards

for ATMS. On January 18, 1994, however, the Department amended the ADA Standards regarding ATMs. The amended version is enclosed. The WSR Appendix, therefore, should be amended to reflect the current ADA Standards. 6) The WSR does not address transportation facilities. The ADA provides special accessibility requirements for such facilities (by amendment dated January 18, 1994, enclosed). This difference between the WSR and ADA will not prevent certification. However, the certification determination will not apply to any elements in transportation facilities that are subject to section 10 of the ADA Standards and, therefore, will not constitute evidence of ADA compliance with respect to such elements. This limitation on the certification determination should be noted in any publication of the WSR if certification is issued. If the Council were to adopt accessibility requirements for transportation facilities, those requirements could be submitted to the Department for certification at a later date. 01-03194 -4The following issues need to be corrected before a certification determination can be issued (page references are to the side-by-side comparison): 1) Maneuvering clearances at doors (Standard 4.13.6, p. 77). The WSR fails to address the different requirements for different approaches to doors (i.e., hinge-side and latch-side). Instead, the code addresses only front approaches, assuming that providing the maneuvering clearance required for front approach will be sufficient, even if a side approach is required. This assumption is not valid. The size, shape, and placement of maneuvering clearances must change when the approach changes. Nor is it always possible to provide a front approach. In addition, the WSR assumes that the size of the maneuvering space is the only important factor. To the contrary, the shape and placement of the maneuvering space are also essential. In order to meet the ADA Standard, the WSR will need to be amended to provide the different space configurations needed for different approaches. 2) Grab bars (Standard 4.16.4, p. 86). The WSR does not correctly address all aspects of the required placement of grab bars at water closets. The WSR fails to require side grab bars

to begin no more than 12 inches from the back wall and to extend at least 54 inches from the back wall (WSR would require only extension to 48 inches from the back wall). This extension is necessary for people who need to reach far forward to pull to a standing position. The WSR also fails to require back grab bars to extend at least 12 inches beyond the center of the water closet and at least 24 inches toward the open side of the water closet. This placement is necessary to allow a diagonal transfer to the toilet when needed. An amendment will be necessary to meet the ADA Standard. 3) Food service shelves (Standard 5.5, p. 108). The WSR generally requires at least one shelf to be accessible. However, for food service lines, the ADA requires 50% of shelves to be accessible. The Council has issued an interpretation purporting to require 50% to be accessible. However, because this interpretation contradicts the code provision, the "interpretation" approach fails to provide appropriate guidance of the requirement. An amendment to the WSR is needed here. 4) Tableware and condiment areas (Standard 5.6, p. 109). The WSR provision references another code provision. However, the reference is erroneous. The Council has issued an interpretation directing readers to the correct provision. However, simply issuing an interpretation does not provide effective notice of the change and does not effectively correct the error in the code. 01-03195​ -55) Elements in showers and bathtubs: a) Shower seats (Standard 4.21.3, p. 92). The WSR fails to require that shower seats be L-shaped. The L shape permits people to sit in the corner of the shower and use both walls for support. b) Shower controls (Standard 4.21.5, p. 93). The WSR addresses placement of shower controls only in an interpretation. That interpretation fails to specify that such controls must be located at specific points on the wall, but, instead, simply requires them to be offset. Offsetting controls is not sufficient to ensure that they are always reachable. If a shower were built to the minimum accessibility requirements, offsetting may be acceptable, but if a shower were built larger than the minimum, offset controls may not be reachable.

c) Bathtub controls (Standard 4.20.5, p. 90). The WSR requires bathtub controls to be placed no more than 24 inches from the clear side of the tub. The ADA requires them to be offset between the midpoint of the tub and the outer edge. Although in very wide tubs (over 48 inches), the Washington requirement may exceed the ADA requirement, in standard tubs the ADA provision is better, because the midpoint of the tub will likely be 15-16 inches from the edge. d) Clear floor space (Standard 4.21.2, p. 91). The WSR does not require the clear floor space at a transfer shower to extend 12 inches beyond the seat wall, as ADA Figure 35 does. This space is necessary to allow a wheelchair to be placed to permit transfer without obstructing the seat. 6) Parking at medical care facilities (Standard 4.1.2(5), p. 26). The ADA requires accessible parking in increased percentages at medical care facilities - 10% at outpatient facilities and 20% at (inpatient and outpatient) facilities that specialize in mobility impairments. The WSR requires 10% at all outpatient facilities and doctors' offices and 20% only at inpatient mobility-specialty facilities. Thus, outpatient mobility specialists are required to provide 20% accessible parking under the ADA, but only 10% under the WSR. The WSR requires provision of 10% accessible spaces at physicians' offices; the ADA does not. However, outpatient mobility specialists create the greatest need for accessible parking, while physicians' offices create a lesser such need. Although the WSR approach may result in a larger total number of accessible spaces in the State of Washington, the spaces will be not be placed where they are most needed. 7) Elevator exception (Standard 4.1.3(5), p. 28; see also pp. 21 and 24). The ADA provides that, generally, no elevator is 01-03196​ -6required in multi-story buildings (1) that are less than three stories or (2) that have less than 3000 square feet per story. The comparable WSR provision provides an exception to the general requirement to install an elevator for "floors above and below accessible levels that have areas of less than 3000 square feet per floor." S 51-20-3103(b)(2). This language is ambiguous because it is not clear that all floors must be less than 3000 square feet (not just the accessible floor). This language

raises the possibility that if one floor is accessible and has less than 3000 square feet, the Washington code would allow all other floors to have no elevator access, regardless of the size of the floors. Although the WSR exceeds the ADA in that it does not extend the elevator exception to most two-story buildings, this is not sufficient to make up for the nonequivalency of the exception for small floors. 8) Alterations. Because the WSR requires all routes in new construction to be accessible, a number of the ADA Standards' requirements that items be placed on an accessible route are superfluous in the context of new construction under WSR. However, such requirements are necessary under WSR for alterations, where not all routes may be accessible: a) Protruding objects (Standard 4.1.2(3), p. 25; Standard 4.4, p. 58). The WSR provision regarding protruding objects limits protrusions into an "accessible route of travel, corridor, pathway, or aisle." S 51-20-3106(e). This appears to apply only to routes that are accessible to people who use wheelchairs. However, the ADA protrusion limits serve primarily people with vision impairments. Therefore, protrusions cannot be allowed in any route. b) Self-service shelves (Standard 5.5, p. 108). The WSR was amended to remove the requirement that self-service shelves be on an accessible route. 9) Unisex toilet rooms (Standard 4.1.6(3)(e), p. 48). The WSR fails to require that, when a unisex toilet room is installed in alterations, it must be placed in the same area as the existing toilet facilities. 10) Companion seating (Standard 4.33.3, p. 104). The WSR fails to require companion seats to be adjacent to accessible seats. The Council states that the code's requirement that accessible seating be "an integral part of any fixed seating plan" is sufficient. However, it is not clear that "integral" means that every accessible seat must be next to a companion seat. That meaning needs to be made more clear. 1-03197​ -7-

11) Location of lavatories: a) Water closets (Standard 4.16.2, p. 85). The WSR allows a lavatory to be installed in the clear floor space at a water closet. The ADA does not permit such a lavatory if the water closet is in a stall. The Council responded to this issue by stating that a lavatory could not be put in a stall because such a lavatory would reduce the required width of the stall. The reasoning behind this statement is unclear and needs to be explained. b) Bathtubs (Standard 4.20.2, p. 88). The WSR fails to specify that, if a lavatory is placed in the clear floor space of a bathtub, it can never be placed at the end of the tub where the seat is located, but may only be placed at the control end of the tub. 12) Diagonal curb ramps (Standard 4.7.10, p. 63). The ADA provides special standards for diagonal curb ramps; the WSR does not. The Council argues that it is not necessary to address diagonal curb ramps because they are rarely used in private development. The WSR would require such ramps to be accessible if they were in an accessible route. However, the standards for accessibility would be the same as that for curb ramps generally. Therefore, the bottom of the ramp would not be required to have 48 inches of clear space. This clear space limitation is necessary at diagonal ramps to allow people to maneuver out of the intersection. In addition, 24 inches of straight curb on either side would not be required if the ramp had flared sides. This straight space is needed to lessen foot traffic on diagonal ramps. 13) Tactile signage (Standard 4.30.4, p. 101). The WSR technical requirements for raised characters have been amended. The amendment has removed the requirement that such characters be in simple typeface. Therefore, the amended code is not equivalent to the ADA. 14) Knee clearance at tables (Standard 4.32.3, p. 103). The WSR fails to require that knee clearance be at least 19 inches deep at tables and counters. 15) Transient lodging (Standard 9.2.2(6), p. 116). The WSR does not specifically require carports that serve accessible

hotel rooms to be accessible. It only addresses such facilities if they serve type A (residential) dwelling units. We understand from your letter of March 23, 1994, that the Council is currently in the process of updating the WSR and we hope that our analysis will be helpful in that effort. Our staff would also be happy to meet with Council representatives to answer any questions that you may have about our analysis. 01-03198 ​ -8Our offices have worked diligently together over a long period of time and we stand on the threshhold of achieving the nation's first ADA-certified State code. Almost all of our work is done. I hope that we can reach agreement on the few remaining issues. We look forward to recommending certification of the WSR as soon as the remaining issues can be resolved. If you have any questions concerning this letter, please call Eve Hill at (202) 307-0663. Sincerely, John L. Wodatch Chief Public Access Section Enclosures: Side-by-side comparison Regulations Regarding ATMs and Transportation Facilities cc: Mr. Lawrence W. Roffee Executive Director U.S. Architectural & Transportation Barriers Compliance Board 01-03199 ​ ADA Requirements 1. Purpose. This document sets guidelines for accessibility to places of public accommodation and commercial facilities by individuals with disabilities. These guidelines are to be applied

during the design, construction, and alteration of such buildings and facilities to the extent required by regulations issued by Federal agencies, including the Department of Justice, under the Americans with Disabilities Act of 1990. The technical specifications 4.2 through 4.35 of these guidelines are the same as those of the American National Standard Institute's document A117.1-1980, except as noted in this text by italics. However, sections 4.1.1 through 4.1.7 and sections 5 through 10 are different from ANSI A117.1 in their entirety and are printed in standard type. The illustrations and text of ANSI A117.1 are reproduced with permission from the American National Standards Institute. Copies of the standard may be purchased from the American National Standards Institute at 1430 Broadway, New York, New York 10018. Washington State Regulations 51-20-002 Purpose. The purpose of these rules is to implement the provisions of chapter 19.27 RCW, which provides that the state building code council shall maintain the State Building Code in a status which is consistent with the purpose as set forth in RCW 19.27.020. In maintaining the codes the council shall regularly review updated versions of the codes adopted under the act, and other pertinent information, and shall amend the codes as deemed appropriate by the Council. RCW 19-27-020 (5). To provide for standards and specifications for making buildings and facilities accessible to and usable by physically disabled persons. 51-20-003 Uniform Building Code. The 1991 edition of the Uniform Building Code as published by the International Conference of Building Officials and available from the International Conference of Building Officials, 5360 South Workman Mill Road, Whittier, California 90601 is hereby adopted by reference with the following additions, deletions, and exceptions. 41-20-005 Uniform Building Code Requirements for BarrierFree Accessibility. Chapter 31 and other Uniform Build Code requirements for barrier-free access are adopted pursuant to chapters 70.92 and 19.27 RCW. Commentary

E - Equivalent NE - Not equivalent to ADA provisions PNE - Possibly/potentially not equivalent to ADA provisions Strike through = material deleted since prior DOJ review [Underline] = material added since prior DOJ review Italic = Washington response to DOJ comments ADA/Washington State July 12, 1994 01-03200 1. Purpose, continued. Pursuant to RCW 19.27.040, Chapter 31 and requirements affecting barrier-free access in Sections 3304 (b), 3304 (h), 3306 (g) and 3306 (i) shall not be amended by local governments. In case of conflict with other provisions of this code, chapter 31 and requirements affecting barrier-free access in Sections 3304 (b), 3304 (h), 3306 (g), and 3306 (i) shall govern. 51-20-3101 Scope. (a) General. Buildings or portions of buildings shall be accessible to persons with disabilities as required by this chapter. Chapter 31 has been amended to comply with the Federal Fair Housing Act (FFHA) Guidelines as published by the U.S. Department of Housing and Urban Development (March 1991) and the Americans with Disabilities Act (ADA) Guidelines as published by the Architectural and Transportation Barriers Compliance Board and the Department of Justice (July 1991). Reference is made to appendix Chapter 31 for FFHA and ADA requirements not regulated by this chapter. (b) Design. The design and construction of accessible building elements shall be in accordance with this chapter. For a building, structure, or building element to be considered to be accessible, it shall be designed and constructed to the

minimum provisions of this chapter. 51-20-3102 Person with Disability is an individual who has an impairment, including a mobility, sensory, or cognitive impairment, which results in a functional limitation in access to and use of a building or facility. 2 ADA/Washington State July 12, 1994

01-03201 Comment: Issue 1. It is acknowledged that the purpose of the ADA is a civil rights law designed to prohibit discrimination against persons with disabilities as defined in the Act and its regulations. It is further recognized that the ADA regulations attempt to provide for compliance with the act through regulations affecting policies and procedures as well as construction. The Washington Barrier-free facilities regulations are only construction regulations. The State Building Code Council is granted authority to promulgate accessibility construction standards under Chapter 70-92 of the Revised Code of Washington (RCW). The WAC process is similar to the federal regulatory process. Through the WAC process legislation is clarified and rules for enforcement are established. The Council can expand coverage in the adoption of the WAC as long as it isn't conflicting with the RCW. The provision of concern in the analysis is a provision of the RCW as adopted in 1973. The WAC is broader in application. Review of the scope and purpose statements found in Sec. 3101 will not reveal similar language limiting application to the "physically handicapped." Also to be taken into consideration is the adopted definition of "person with disability" found in Sec. 3102 which reads: "person with disability is an individual who has an impairment, including a mobility, sensory, or cognitive impairment, which results in a functional limitation in access to and use of a building or facility." The Washington regulations were written to incorporate the standards for new construction and alteration contained in

the Title III regulations of ADA. As such, the intent of the Washington regulations is to "protect" persons with disabilities as well as they are "protected" by the ADAAG, regardless of there [sic] specific type of disability. While the "stated" purpose may not be identical, the net result is the same, construction and alteration of buildings to be accessible. [E. Section 3102 does seem to include all disabilities that are affected by building construction. Therefore, the substantive coverage is equivalent.] 3 ADA/Washington State July 12, 1994

01-03202 Assembly Area. A room or space accommodating a group of individuals for recreational, educational, political, social, or amusement purposes, or for the consumption of food and drink. Chapter 4 Definitions and Abbreviations Section 402. Assembly Building is a building or portion of a building used for the gathering together of 50 or more persons for such purposes as deliberation, education, instruction, worship, entertainment, amusement, drinking or dining or awaiting transportation. Comment: Issue 2. The Uniform Building Code treats small assembly spaces as part of the major occupancy of the building. Most of these are Business (B) or Education (E) occupancies. For example, a small restaurant, is a B-2 occupancy. A small conference room in an office building is a B-2 occupancy. A classroom at a university or private or technical college is a B-2. A classroom at a grade school or high school will either be a E-1 or E-2. Anticipating this difference, the requirement for assistive listening systems is specifically referenced in the requirements for B and E occupancies (Sec. 3103(a)3 and 4, respectively). In addition the regulation on fixed seats and tables which you might find in a small restaurant is a general requirement contained in Sec. 3105(d)5. Since the exception to allow a portion of seats in a restaurant to be located in an inaccessible mezzanine applies only to A occupancies in the Washington regulations, it could not be used in smaller assembly spaces.

In this regard the WSR code provides greater accessibility than ADA. Not clearly referenced for small assembly spaces are the requirements for wheelchair spaces. The code does require each space, including such small assembly spaces to be accessible. We believe that assembly spaces where the total occupant load is less than 50 which also have fixed seats are fairly rare. The most likely location would be in some classrooms. In order to clarify the application of the code to these circumstances, the Council has issued Interpretation No. 93-32. It should be noted that the Washington Code requires distribution of wheelchair locations in all assembly occupancies, even those with fewer than 300 fixed seats. On balance we believe that the total set of regulations of assembly areas is equivalent.

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Dwelling Unit. A single unit which provides a kitchen or food preparation area, in addition to rooms and spaces for living, bathing, sleeping, and the like. Dwelling units include a single family home or a townhouse used as a transient group home; an apartment building used as a shelter; guestrooms in a hotel that provide sleeping accommodations and food preparation areas; and other similar facilities used on a transient basis. For purposes of these guidelines, use of the term "Dwelling Unit" does not imply the unit is used as a residence. Interpretation 93-32. Question: Are wheelchair spaces required in assembly areas which are not assembly occupancies, specifically assembly spaces with fixed seats and an occupant load of less than 50? Answer: Yes. The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guidelines. Regardless of occupancy classification, for assembly areas of 4 to 25 seats, one

wheelchair location is required, for areas of 26 to 50 seats, two wheelchair locations are required. (See Table 31-A). Sec. 405 D. Dwelling Unit is any building or portion thereof which contains living facilities, including provisions for sleeping, eating, cooking and sanitation, as required by this code, for not more than one family, or a congregate residence for 10 or less persons. Dwelling Unit, Type A is an accessible dwelling unit that is designed and constructed [in accordance with this chapter] to provide greater accessibility than a Type B dwelling unit. (Type A dwelling units constructed in accordance with this Chapter also meet the design standards for Type B dwelling units.) Dwelling Unit, Type B is an accessible dwelling unit that is designed and constructed [in accordance with this chapter.] [(Type B Dwelling Unit Standards are based on] the U.S. Department of Housing and Urban Development [(HUD)] Federal Fair Housing Act Accessibility Guidelines.[)] Single-Story Dwelling Unit is a dwelling unit with all finished living spaces located on one floor. Multistory Dwelling Unit is a dwelling unit with finished living space located on one floor, and the floor or floors immediately above or below it. [E. when read together with Table 31-A and S 3105.]

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01-03204 Mezzanine or Mezzanine Floor. That portion of a story which is an intermediate floor level placed within the story and having occupiable space above and below its floor. Primary Entry[ance] is a principal entrance through which most people enter the building. A building may have more than one primary entry.

Primary Entry[ance] Level is the floor or level of the building on which the primary entry is located. Comment: Issue 4. The 1992/93 amendments changed the term entry to entrance in all locations to eliminate this possible difference between ADA and Washington. [See page 599b of the Published Code.] The intent is the same and training being provided around the State includes the ADA concept of entrances. Chapter 4 Definitions and Abbreviations Section 414 Mezzanine or Mezzanine Floor is an intermediate floor placed within a room. Comment: Issue 5. ADA and Washington definitions are very similar. The ADA differentiation between mezzanine and raised or lowered floor area does not occur in the ADA definition, but must be discovered by combining the various provisions in Section 5. Similarly, the limitations on mezzanine design are found in Section 1717 of the UBC and Washington Code (attached). The key regulation is that the "clear height above and below the mezzanine floor construction shall not be less than 7 feet." It is clear from UBC that more than a simple raised or lowered area must be provided to be considered a mezzanine. This is clearer than the ADA which does not succinctly distinguish when a raised area becomes an intermediate floor level. Chapter 4, Section 408 Grade (Adjacent Ground Elevation) is the lowest point of elevation of the finished surface of the ground, paving or sidewalk within the area between the building and the property line or, when the property line is more than 5 feet from the building, between the building and a line 5 feet from the building. [E.] [E.] 8 ADA/Washington State July 12, 1994

01-03205 Comment: Issue 3. The analysis has confused the application of the phrase of "for 10 or less persons" contained in the UBC definition as applying to the whole definition. In[sic] only applies to congregate residences of 10 or less persons as being included in the definition of a "dwelling unit." Congregate residences of larger than 10 persons are treated differently in the UBC. The ADA definitions of dwelling unit is at odds with the definition of dwelling unit used in almost all building and zoning codes by indicating a dwelling unit is used as transient lodging. This definitional difference has no effect on the accessibility requirements as applied in the Washington Code. In order to give assistance to local building officials in applying the Washington Code in these cases, the Council has issued Interpretation No. 93-39. 6 ADA/Washington State July 12, 1994

01-03206 Entrance. Any access point to a building or portion of a building or facility used for the purpose of entering. An entrance includes the approach walk, the vertical access leading to the entrance platform, the entrance platform itself, vestibules if provided, the entry door(s) or gate(s), and the hardware of the entry door(s) or gate(s). Interpretation 93-39: Question: For purposes of accessibility requirements of Chapter 31, how should buildings such as homeless shelters, halfway houses, transient group homes, and similar social service establishments where people may sleep or temporarily reside be classified? Similarly, how should apartments or condominium complexes be classified where some or all of the units are rented to short term quests. Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent with the ADA Accessibility Guidelines. For the purpose of determining accessibility requirements per Chapter 31, uses such as homeless shelters, halfway houses, transient group homes, and similar facilities should be

reviewed on a case by case basis. While these uses are "residential" in nature, if the residents are considered transient, classification as R-1 hotel, or R-3 lodging house is more appropriate. Some may need to be classified either in an I (Institutional) or B (Business) category. If services are provided at the site such as job or health counseling, classification should be in a category which requires accessibility. These uses should not be categorized as congregate residence when the residents are essentially transient. Apartments or condominiums which are rented on a short term basis to transient guests should be categorized as either a Group R-1, hotel, or Group R-3 lodging house with appropriate accessibility provided. [E.]

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01-03207 Ground Floor. Any occupiable floor less than one story above or below grade with direct access to grade. A building or facility always has at least one ground floor and may have more than one ground floor as where a split level entrance has been provided for where a building is built into a hillside. Story. That portion of a building included between the upper surface of a floor and upper surface of the floor or roof next above. If such portion of a building does not include occupiable space, it is not considered a story for purposes of these guidelines. There may be more than one floor level within a story as in the case of a mezzanine or mezzanines. 51-20-0407 Section 407 Floor Area is the area included within the surrounding exterior walls of a building or portion thereof, exclusive of vent shafts and courts. The floor area of a building, or portion thereof, not provided with surrounding exterior walls shall be the usable area under the horizontal projection of the roof or floor above.

Ground Floor is any occupiable floor less than one story above or below grade with direct access to grade. A building may have more than one ground floor. 51-20-0420 Section 420 Story is that portion of a building included between the upper surface of any floor and the upper surface of the floor next above, except that the topmost story shall be that portion of a building included between the upper surface of the topmost floor and the ceiling or roof above. If the finished floor level directly above a usable or unused under-floor space is more than 6 feet above grade as defined herein for more than 50 percent of the total perimeter or is more than 12 feet above grade as defined herein at any point, such usable or unused under-floor space shall be considered as a story. 51-20-0320 Section 420 Story. First is the lowest story in a building which qualifies as a story, as defined herein, except that a floor level in a building having only one floor level shall be classified as a first story, provided such floor level is not more than 4 feet below grade, as defined herein, for more than 50 percent of the total perimeter, or not more than 8 feet below grade, as defined herein, at any point. 9 01-03208 Comment: Issue 6. The term "story" in the UBC serves more specific purposes than the term does in ADA and therefore the definition is more specific. The UBC limits types of construction (wood vs concrete vs steel) based on the number of stories. The UBC also limits certain occupancies (uses) are limited to 1st stories. These examples show the importance of knowing exactly what a story is. There is no effect on accessibility as regulated in Washington since all stories and basements must be accessible (with the limited exception of not providing elevator access to some small stories). [E. The potential problem here is that a building might be ADA/Washington State July 12, 1994

built with one or more floors below ground (for parking) and only one floor above ground. Under this definition, the below-ground floors would not be considered a "story". Thus, this would be considered a one-story building and no elevator would be required. However, the Washington accessibility provisions do not exempt a basement from accessibility requirements, even if it is not a "story", so a builder would be required to provide an accessible entrance and an accessible route to all parts of the building.] 10 01-03209 Transient Lodging. A building, facility, or portion thereof, excluding inpatient medical care facilities, that contains one or more dwelling units or sleeping accommodations. Transient lodging may include, but is not limited to, resorts, group homes, hotels, motels, and dormitories. DOJ 36.104(1). An inn, hotel, motel, or other place of lodging, except for an establishment located within a building that contains not more than five rooms for rent or hire and that is actually occupied by the proprietor of the establishment as the residence of the proprietor. 51-20-0404 Section 404 Congregate Residence is any building or portion thereof which contains facilities for living, sleeping and sanitation, as required by this code, and may include facilities for eating and cooking, for occupancy by other than a family. A congregate residence may be a shelter, convent, monastery, dormitory, fraternity or sorority house but does not include jails, hospitals, nursing homes, hotels or lodging houses. Chapter 4, Section 413 Lodging House is any building or portion thereof containing not more than five guest rooms where rent is paid in money, goods, labor or otherwise. 51-20-0409 Section 409 Hotel is any building containing six or more guest rooms intended or designed to be used, or which are used, rented or hired out to be occupied, or which are occupied for sleeping purposes by guests. ADA/Washington State July 12, 1994

51-20-0409 Section 409 Motel is any building containing six or more guest rooms intended or designed to be used, or which are used, rented or hired out to be occupied, or which are occupied for sleeping purposes by guests. (See definition of Hotel) 51-20-1201 Group R. Occupancies Defined. Group R Occupancies shall be: Division 1. Hotels and apartment houses. Congregate residence (each accommodating more than 10 persons) Division 2. Not used. Division 3. Dwellings, family child day care homes and lodging houses. Congregate residences (each accommodating 10 persons or less). 11 01-03210 Comment: Issue 7. (See also Issue No. 19) ADA defines terms to clarify which activities are regulated for accessibility. UBC defines terms to distinguish how buildings must be constructed, safely occupied and exited. The UBC does not use the term transient directly but it is a factor in all the regulations which distinguish a hotel from and[sic] an apartment building. A careful review and understanding of Chapters 12 and 33 of the UBC clarifies this approach. Every activity someone wishes to conduct in a building must fall in one of the UBC occupancy categories. If it is not specifically listed, the building official must categorize it as being similar to one of those listed and regulate it accordingly. See Section 501 of the UBC (attached). Thus any facility providing residential services on a transient basis will be categorized either as a hotel or lodging house by the building official and accessibility will be required at that change [sic] of occupancy. In order to assist local building officials address this potential concern, the Council has issued Interpretation No. 93-39. 12 ADA/Washington State July 12, 1994 ADA/Washington State July 12, 1994

01-03211 Interpretation 93-39. Question: For purposes of accessibility requirements of Chapter 31, how should buildings such as homeless shelters, halfway houses, transient group homes, and similar social service establishments where people may sleep or temporarily reside be classified? Similarly, how should apartments or condominium complexes be classified where some or all of the units are rented to short term quests. Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent with the ADA Accessibility Guidelines. For the purpose of determining accessibility requirements per Chapter 31, uses such as homeless shelters, halfway houses, transient group homes, and similar facilities should be reviewed on a case by case basis. While these uses are "residential" in nature, if the residents are considered transient, classification as R-1 hotel, or R-3 lodging house is more appropriate. Some may need to be classified either in an I (Institutional) or B (Business) category. If services are provided at the site such as job or health counseling. classification should be in a category which requires accessibility. These uses should not be categorized as congregate residence when the residents are essentially transient. Apartments or condominiums which are rented on a short term basis to transient guests should be categorized as either a Group R-1, hotel, or Group R-3 lodging house with appropriate accessibility provided. [E.] 13 ADA/Washington State July 12, 1994

01-03212

ACCESSIBLE ELEMENTS AND SPACES: SCOPE AND TECHNICAL REQUIREMENTS. 4.1 Minimum Requirements 4.1.1* Application. (1) General. All areas of newly designed or newly constructed buildings and facilities required to be accessible by 4.1.2 and 4.1.3 and altered portions of existing buildings and facilities required to be accessible by 4.1.6 shall comply with these guidelines, 4.1 through 4.35, unless otherwise provided in this section or as modified in a special application section. 51-20-3101 Scope (a) General. Buildings or portions of buildings shall be accessible to persons with disabilities as required by this chapter. Chapter 31 has been amended to comply with the Federal Fair Housing Act (FFHA) Guidelines as published by the U.S. Department of Housing and Urban Development (March 1991) and the Americans with Disabilities Act (ADA) Guidelines as published by the U.S. Architectural and Transportation Barriers Compliance Board and Department of Justice (July, 1991). Reference is made to Appendix Chapter 31 for FFHA and ADA requirements not regulated by this chapter. 51-20-3101 (b) Design. The design and construction of accessible building elements shall be in accordance with this chapter. For a building, structure or building element to be considered to be accessible, it shall be designed and constructed to the minimum provisions of this chapter. 51-20-3103 Building Accessibility (a) Where required. 1. General. Accessibility to temporary or permanent buildings or portions thereof shall be provided for all occupancy classifications except as modified by this chapter. See also Appendix Chapter 31. 51-20-0104 Application to Existing Buildings and Structures. (a) General. Buildings and structures to which additions, alterations or repairs are made shall comply with all the requirements of this code for new facilities except as

specifically provided in this section. See Section 1210 for provisions requiring installation of smoke detectors in existing Group R, Division 3 Occupancies.

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ADA/Washington State July 12, 1994

4.1.1 (2) Application Based on Building Use. Special application sections 5 through 10 provide additional requirements for restaurants and cafeterias, medical care facilities, business and mercantile, libraries, accessible transient lodging, and transportation facilities. When a building or facility contains more than one use covered by a special application section, each portion shall comply with the requirements for that use. 51-20-3106 Accessible Design and Construction Standards. (a) General. Where accessibility is required by this chapter, it shall be designed and constructed in accordance with this section, unless otherwise specified in this chapter. 51-20-3103 Building Accessibility (a) Where required. 1. General. Accessibility to temporary or permanent buildings or portions thereof shall be provided for all occupancy classifications except as modified by this chapter. See also Appendix Chapter 31. UBC Section 503. (a) ... When a building houses more than one occupancy, each portion of the building shall conform to the requirements of the occupancy housed therein. 15 01-03214 4.1.1*(2) Continued. 51-20-3103 Building Accessibility. (a) Where required. 1. General. Accessibility to temporary or permanent buildings or ADA/Washington State July 12, 1994

portions thereof shall be provided for all occupancy classifications except as modified by this chapter. See also Appendix Chapter 31. (a) 2. Group A. Occupancies. A. General. All Group A Occupancies shall be accessible as provided in this chapter. (a) 3. Group B. Occupancies. All Group B Occupancies shall be accessible as provided in this chapter. Assembly spaces in Group B Occupancies shall comply with Section 3103 (a) 2. B. 4. Group E. Occupancies. All Group E. Occupancies shall be accessible as provided in this chapter. Assembly spaces in Group E Occupancies shall comply with Section 3103 (a) 2. B. 5. Group H Occupancies. All Group H Occupancies shall be accessible as provided in this chapter. 6. Group I Occupancies. All Group I Occupancies shall be accessible in all public use, common use and employee use areas, and shall have accessible patient rooms, cells and treatment or examination rooms as follows: 6.A. In Group I, Division 1.1 hospitals which specialize in treating conditions that affect mobility, all patient each nursing unit, including associated toilet rooms and bathrooms. 6.B. In Group I, Division 1.1 hospitals which do not specialize in treating conditions that affect mobility, all patient rooms in each nursing unit, including associated toilet rooms and bathrooms. 6.C. In Group I, Division 1.1 and Division 2 nursing homes and long-term care facilities, at least 1 in every 2 patient rooms, including associated toilet rooms and bathrooms. 6.D. In Group I, Division 3, mental health Occupancies, at least 1 in every 10 patient rooms, including associated toilet rooms and bathrooms. 16 ADA/Washington State July 12, 1994

01-03215

4.1.1 (2) Continued.

4.1.1 (2) Continued. 6.E. In Group I, Division 3 jail, prison and similar Occupancies, at least 1 in every 100 rooms or cells, including associated toilet rooms and bathrooms. [6.F. In Group I Occupancies, all treatment and examination rooms shall be accessible.] In Group I, Division 1.1 and 2 Occupancies, at least one accessible entrance that complies with Section 3103 (b) shall be under shelter. Every such entrance shall include a passenger loading zone which complies with Section 3108 (b) 3. 51-20-3103 (a) 7. Group M. Occupancies. Group M, Division 1 Occupancies shall be accessible. [as follows:] [A.] Private garages, [and] carports [which contain accessible parking serving Type A dwelling units.] [B]. In Group M., Division 1 agricultural buildings, access need only be provided to paved work areas and areas open to the general public. 51-20-3103 (a) 8. Group R. Occupancies. A. General. All Group R Occupancies shall be accessible as provided in this chapter. Public and common-use areas and facilities such as recreational facilities, laundry facilities, garbage and recycling collection areas, mailbox locations, lobbies, foyers and management offices, shall be accessible. [EXCEPTION: Common- or public-use facilities accessory to buildings not required to contain either Type A or Type B dwelling units in accordance with Section 3103(a)8B.] B. Number of Dwelling Units. In all Group R, Division 1 apartment buildings the total number of Type A dwelling units shall be as required by Table No. 31-B. All other dwelling units shall be designed and constructed to the requirements for Type B units as defined in this chapter. EXCEPTIONS: 1. Group R Occupancies containing **[no more than] three dwelling units [need not be accessible]* **

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ADA/Washington State July 12, 1994

4.1.1 (2) Continued. 4.1.1 (3)* Areas Used Only by Employees as Work Areas. Areas that are used only as work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas. These guidelines do not require that any areas used only as work areas be constructed to permit maneuvering within the work area or be constructed or equipped (i.e., with racks or shelves) to be accessible. 51-20-3152 TABLE NO. 31-B REQUIRED TYPE A DWELLING UNITS Total Number of Dwelling Required Number of Type A Units on Site Dwelling Units 0-10 None 11-20 1 21-40 2 41-60 3 61-80 4 81-100 5 For every 20 units or fractional 1 additional part thereof, over 100 See Occupancy Groups above 18 01-03217 Comment: Issue 8. Except in Group M occupancies, the Washington code does not distinguish areas in a building which are employee versus public areas. It requires all areas of a building to provide equal accessibility. In this regard the ADA/Washington State July 12, 1994

Washington Code provides greater accessibility than the ADA. For example if a plan shows a room with a series of built in work stations, ADA would simply ask if the room can be approached, entered and exited. Under the Washington code, accessible aisles would be required between work stations and 5% of the stations would be accessible. Over time use of specific rooms change without need for a building permit or review by a building official. It is better in the long term of accessibility to require full accessibility at the time of construction. Group M occupancies are small, miscellaneous buildings that are limited in size to less than 1000 square feet and don't fit in other categories. Typically they are accessory buildings at other buildings. A typical garage at a house in [sic] an M-1. So is the storage shed at the house. Another broad category is agricultural buildings, also limited to 1000 square feet or less. Most things that small are at family farms, but not always. Thus for these small buildings which might be places of employment or places of public accommodation, accessibility is required by the Washington code. [E.] 19 ADA/Washington State July 12, 1994

01-03218 4.1.1 (4) Temporary Structures. These guidelines cover temporary buildings or facilities as well as permanent facilities. Temporary buildings and facilities are not of permanent construction but are extensively used or are essential for public use for a period of time. Examples of temporary buildings or facilities covered by these guidelines include, but are not limited to: reviewing stands, temporary classrooms, bleacher areas, exhibit areas, temporary banking facilities, temporary health screening services, or temporary safe pedestrian passageways around a construction site. Structures, sites and equipment directly associated with the actual processes of construction, such as scaffolding, bridging, materials hoists, or construction trailers are not included.

51-20-3103 Building Accessibility (a) Where required. 1. General. Accessibility to temporary or permanent buildings or portions thereof shall be provided for all occupancy classifications except as modified by this chapter. See also Appendix Chapter 31. 51-20-3103 (a) 1. EXCEPTION 2. Temporary structures, sites and equipment directly associated with the construction process such as construction site trailers, scaffolding, bridging, or material hoists are not required to be accessible. [This exception does not include walkways or pedestrian protection required by Chapter 44.] 51-20-0104 (e) Moved Buildings and Temporary Buildings. Buildings or structures moved into or within the jurisdiction shall comply with the provisions of this code for new buildings or structures. Temporary structures such as reviewing stands and other miscellaneous structures, sheds, canopies or fences used for the protection of the public around and in conjunction with construction work may be erected by special permit from the building official for a limited period of time. Such buildings or structures need not comply with the type of construction or fire-resistive time periods required by this code. Temporary buildings or structures shall be completely removed upon the expiration of the time limit stated in the permit. Comment: Issue 9. Section 3103(a)1, Exception 3 has been amended to include the following sentence. "This exception does not include walkways or pedestrian protection required by Chapter 44." (See Page 599c of the Published Code.) By adding this limitation to the exception, these walkways must still be accessible. Section 104(e) is primarily a permit process section. It allows a special permit for such temporary structures and allows waiver of construction type and fire-resistive standards. It does not waive requirements of Chapter 31 regarding accessibility. [E.]

20

ADA/Washington State July 12, 1994

01-03219 4.1.1 (5) General Exceptions. (a) In new construction, a person or entity is not required to meet fully the requirements of these guidelines where that person or entity can demonstrate that it is structurally impracticable to do so. Full compliance will be considered structurally impracticable only in those rare circumstances when the unique characteristics of terrain prevent the incorporation of accessibility features. If full compliance with the requirements of these guidelines is structurally impracticable, a person or entity shall comply with the requirements to the extent it is not structurally impracticable. Any portion of the building or facility which can be made accessible shall comply to the extent that it is not structurally impracticable. 51-20-3103(a) 1. EXCEPTIONS: 51-20-3103(b) 2. EXCEPTION[S]: [1. A single accessible route shall be permitted to pass through a kitchen or storage room in an accessible dwelling unit. 2. Floors above and below accessible levels that have areas of less than 3,000 square feet per floor, need not be served by an accessible route of travel from an accessible level. This exception shall not apply to: A. The offices of health care providers: or, B. Transportation facilities and airports: or, C. Buildings owned or leased by government agencies: or D. Multi-tenant Group B, Division 2, retail and wholesale occupancies of five tenant spaces or more.] [3] For sites where natural terrain or other unusual property characteristics do not allow the provision of an accessible route of travel from the public way to the building, the point of vehicular debarkation may be substituted for the accessible entrance to the site. 51-20-3105(a) General . . . [For Group R, Division 1 apartment buildings.] Where specific floors of a building are required to be accessible, the requirements shall apply only to the facilities located on accessible floors. 21 ADA/Washington State July 12, 1994

01-03220 4.1.1(5) Continued. 4.1.1(5)(b) Accessibility is not required to (i) observation galleries used primarily for security purposes; or (ii) in non-occupiable spaces accessed only by ladders, catwalks, crawl spaces, very narrow passageways, or freight (non-passenger) elevators, and frequented only by service personnel for repair purposes; such spaces include, but are not limited to, elevator pits, elevator penthouses, piping or equipment catwalks. Comment: Issue 10. The elevator exception has been revised and is now generally equivalent and, for two story buildings, requires substantially greater accessibility than the ADA. See also Issue No. 16, below. 51-20-3101(e) Modifications. Where full compliance with this chapter is impractical due to unique characteristics of the terrain, the building official may grant modifications in accordance with Section 106, provided that any portion of the building or structure that can be made accessible shall be made accessible to the greatest extent practical. Comment: Issue 11. In preparing the Washington's regulations it was noted that this provision of the ADA was very limited in potential application, therefore an equivalent provision was not adopted. Under Section 105 and 3101(d), building officials can approve alternative designs which provide substantially equivalent or greater accessibility. In addition, a specific exception based on terrain which allows an alternative approach than providing an accessible route from the street is provided by Sec. 3103(b)2. Through these provisions, the Washington Code is more restrictive than the appearance of the ADA provisions and provides greater accessibility. 51-20-3103(a) 1. EXCEPTIONS: 1. Floors or portions of floors not customarily occupied, including, but not limited to, elevator pits, observation galleries used primarily for security purposes, elevator penthouses, nonoccupiable spaces accessed only by ladders, catwalks, crawl spaces, very

narrow passageways or freight elevators, piping and equipment catwalks and machinery, mechanical and electrical equipment rooms. [Amendment: P.N.E. The language raises the possibility that the phrase "that have areas of less than 3000 square feet per floor" refers to "accessible levels" without limiting "floors above and below" or vice versa. Thus, if the ground floor were less than 3000 square feet, WAC would not require an elevator, even though any number of floors above or below it were greater than 3000 square feet. It needs to be clear that no floor can exceed 3000 square feet. Although WAC does exceed the ADA in that WAC does not allow an elevator exemption for two-story buildings, that does not make up for the possible problem caused by the ambiguity regarding square footage per floor.] [WAC applies a lower standard than "structurally impracticable". However, because this is a waiver provision, it is not part of the certification determination. Rather, any waiver will be non-certified.]

22 01-03221

ADA/Washington State July 12, 1994

Comment: Issue 12. It was the intent of the WSR to have the same effect as the ADA. The language of the exception may be poorly crafted but was intended as a long list of ways in which areas not customarily occupied would be accessed. To clarify application of this exception the Council has issued Interpretation No. 93-29. Interpretation 93-29: Question: 1. Do spaces such as machinery, mechanical, electrical, and telephone equipment rooms need to be accessible? Since these spaces typically work areas only open to employees, is it sufficient to have these rooms designed that persons with disabilities can approach, enter, and exit from these areas? 2. Are rooms used for storage considered to "not customarily occupied" and able to be nonaccessible?

Answer: 1. The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guideline. Machinery, mechanical, electrical, and telephone equipment rooms must be accessible, as must rooms identified as or other service spaces such as custodial, janitors', and supply rooms must be accessible when the primary occupancy must be accessible. Such rooms must be designed so they can be approached, entered, and exited by a person with disabilities. The intent of the exception is to only apply to spaces of the building which are very rarely accessed even by building service personnel such as a mechanical or plumbing chase, crawl space, plenum, or space above a suspended ceiling. The listing of the equipment rooms in this exception is intended only to be examples of locations where the small, non-occupiable spaces might be accessed. 2. Storage rooms are not spaces which are "not customarily occupied," and must meet accessibility standards of Chapter 31. [P.E. The interpretation has so many typographical errors that it is very confusing.] 23 ADA/Washington State July 12, 1994

01-03222 4.1.2 Accessible Sites and Exterior Facilities: New Construction. An accessible site shall meet the following minimum requirements: (1) At least one accessible route complying with 4.3 shall be provided within the boundary of the site from public transportation stops, accessible parking spaces, passenger loading zones if provided, and public streets or sidewalks, to an accessible building entrance. 4.1.2 (2) At least one accessible route complying with 4.3 shall connect accessible buildings, accessible facilities, accessible elements, and accessible spaces that are on the same site. 51-20-3105 Facility Accessibility (a) General. Where buildings are required to be accessible, building facilities shall be accessible to persons with disabilities as provided in this section. **[For Group R, Division 1 apartment buildings.] Where

specific floors of a building are required to be accessible, the requirements shall apply only to the facilities located on accessible floors. 51-20-3103(b)2. Accessible Route of Travel. When a building or portion of a building, is required to be accessible, an accessible route of travel shall be provided to all portions of the building, to accessible building entrances and connecting the building and the public way. The accessible route of travel to areas of primary function may serve but shall not pass through kitchens, storage rooms, toilet rooms, bathrooms, closets or other similar spaces. EXCEPTION[S]: [1. A single accessible route shall be permitted to pass through a kitchen or storage room in an accessible dwelling unit. 2. Floors above and below accessible levels that have areas of less than 3,000 square feet per floor, need not be served by an accessible route of travel from an accessible level. This exception shall not apply to: A. The offices of health care providers; or, B. Transportation facilities and airports; or, C. Buildings owned or leased by government agencies; or, D. Multi-tenant Group B, Division 2, retail and wholesale occupanices of five tenant spaces or more.] **[moved up #3] For sites where natural terrain or other unusual property characteristics do not allow the provision of an accessible route of travel from the public way to the building, the point of vehicular debarkation may be substituted for the accessible entrance to the site. [Amendment: P.N.E. It appears that the phrase "that have areas of less than 3000 square feet per floor" refers to "accessible levels" without limiting "floors above and below"or vice versa. It needs to be clear that no floor can exceed 3000 square feet (see discussion above at Standard 4.1.1(5)).] 24 ADA/Washington State July 12, 1994

01-03223 Continued.

4.1.2 (3) All objects that protrude from surfaces or posts into circulation paths shall comply with 4.4. 4.1.2(5)(b) One in every eight accessible spaces, but not less than one, shall be served by an access aisle 96 in (2440 mm) wide minimum and shall be designated "van accessible" as required by 4.6.4. The vertical clearance at such spaces shall comply with 4.6.5. All such spaces may be grouped on one level of a parking structure. EXCEPTION: Provision of all required parking spaces in conformance with "Universal Parking Design" (see appendix A4.6.3) is permitted. 4.1.2(5)(c) If passenger loading zones are provided, then at least one passenger loading zone shall comply with 4.6.6. Accessible routes of travel serving any accessible space or element shall also serve as a means of egress for emergencies or connect to an area of evacuation assistance. When more than one building or facility is located on a site, accessible routes of travel shall [connect] accessible buildings and accessible site facilities. The accessible route of travel shall be the most practical direct route connecting accessible building entrances, accessible site facilities and the accessible site entrances. 51-20-3106(e) Protruding Objects. Protruding objects shall not reduce the clear width of an accessible route of travel or maneuvering space. Any wall- or post-mounted object with its leading edge between 27 inches and 79 inches above the floor may project not more than 4 inches into [an accessible route of travel.] corridor, passageway, or aisle]. Any wall-or post-mounted projection greater than 4 inches shall extend to the floor. 51-20-3107(a)[5] . . . [For other than Group R, Division 1 apartment buildings, where accessible parking is required,] one [of] every eight accessible parking spaces, [or fraction thereof], shall [be designed to be accessible to vans]. 51-20-3107(b)2. . . . Van accessible parking spaces shall

have an adjacent access aisle not less than 96 inches in width. [(c) Signs. . . . Van accessible parking spaces shall have an additional sign mounted below the International Symbol of Access identifying the spaces as "Van Accessible." EXCEPTION: Where all of the accessible parking spaces comply with the standards for van accessible parking spaces.] 51-20-3108 Passenger Loading Zones. (a) Location. Where provided, passenger loading zones shall be located on an accessible route of travel [Amendment: E.] [Amendment: N.E. The amendment creates an ambiguity because of the placement of "accessible" at the beginning of the list of covered pathways. We need to be clear that objects must not protrude into any corridor or passageway or aisle, regardless of whether it is otherwise accessible. Because, in new construction, WAC requires all routes to be accessible, this distinction is a problem only for alterations.] [Amendment: E.] [Amendment: E.] 25 ADA/Washington State July 12, 1994

01-03224 4.1.2(5)(d) At facilities providing medical care and other services for persons with mobility impairments, parking spaces complying with 4.6 shall be provided in accordance with 4.1.2(5)(a) except as follows: (i) Outpatient units and facilities: 10 percent of the total number of parking spaces provided serving each such outpatient unit or facility; (ii) Units and facilities that specialize in treatment or services for persons with mobility impairments: 20 percent of the total number of parking spaces provided serving each such unit or facility. 4.1.2 (6) If toilet facilities are provided on a site, then each such

public or common use toilet facility shall comply with 4.22. If bathing facilities are provided on a site, then each such public or common use bathing facility shall comply with 4.23. For single user portable toilet or bathing units clustered at a single location, at least 5% but no less than one toilet unit or bathing unit complying with 4.22 or 4.23 shall be installed at each cluster whenever typical inaccessible units are provided. Accessible units shall be identified by the International Symbol of Accessibility. EXCEPTION: Portable toilet units at construction sites used exclusively by construction personnel are not required to comply with 4.1.2(6). 51-20-3107 (a) Accessible Parking Required. . . . [2] Inpatient Medical Care Facilities] For Group I, Division 1.1, 1.2 and 2 medical care Occupancies specializing in the treatment of persons with mobility impairments, 20 percent of parking spaces provided accessory to such occupancies shall be accessible. [3. Outpatient Medical Care Facilities. For Group I, Division 1.1 and 1.2 and Group B, Division 2 Occupancies providing outpatient medical care facilities, 10 percent of the parking spaces provided accessory to such occupancies shall be accessible.] Comment: Issue 13. Section 3107 has been amended to include a 10 percent requirement for outpatient medical care facilities at either hospitals (Group 1.1), Outpatient surgery centers (Group 1.2) or doctors and dentists offices (Group B2). (See page 604s of the Published Code.) Ironically this WSR provision will require more accessible parking than the ADA based on the interpretation of this provision contained in the January 1993 supplement to the Title III technical assistance manual. 51-20-3106 (k) 1. General. Bathrooms, toilet rooms, bathing facilities and shower rooms shall be designed in accordance with this section. (3106) [Amendment: N.E. WAC requires 20% at inpatient mobilityspecialists and 10% at outpatient facilities. Under S 3107 outpatient mobility-specialty facilities would only need 10%. The ADA would require 20% for all (inpatient and outpatient) mobility-specialty facilities. Although WAC does exceed the ADA in that it requires the additional (10%) accessible

spaces at doctors' offices, the increased accessible parking is most needed in the places WAC does not provide it (outpatient mobility specialists) and least needed in the places WAC does provide it (doctors' and dentists' offices).] 26 ADA/Washington State July 12, 1994

01-03225 4.1.3 (4) Interior and exterior stairs connecting levels that are not connected by an elevator, ramp, or other accessible means of vertical access shall comply with 4.9. Comment: Issue 14. Section 3103(a) 1 only exempts temporary structures which are directly related to the construction process. The standards for accessible toilets are provided and are applicable to permanent and temporary facilities. If someone gets a local building permit for portable toilets, there is nothing in Chapter 31 which exempts them from complying with 3105(b) or 3106(k). The code specifically regulates temporary as well as permanent structures in Section 3103(a)1. Not all jurisdictions require building permits for these temporary installations, thus it is not uniformly covered by local application of the code. This in no way exempts them from ADA compliance. 51-20-3306 Stairways. (a) General. Every stairway having two or more risers serving any building or portion thereof shall conform to the requirements of this section. When aisles in assembly rooms have steps, they shall conform with the provisions in Section 3315. 51-20-3106 (i) Stairways. 1. General. Stairways required to be accessible shall comply with section 3306 and provisions of this section. 51-20-5105 (c)3. Stairways. Stairways shall comply with Section 3106(i). Comment: Issue 15. Section 3105(c) has been amended to provide scoping for elevators, platform lifts and stairways. (See pages 603a and 603b of the Published Code.) The net result is the Washington regulations provide greater

accessibility than the ADA in that all stairways in covered buildings must comply with 3106(i). This is significantly more than the ADA which only applies to stairways where floors are not accessible by elevator or ramp. [E.] [E.] 27 ADA/Washington State July 12, 1994

01-03226 4.1.3 (5)* One passenger elevator complying with 4.10 shall serve each level, including mezzanines, in all multi-story buildings and facilities unless exempted below. If more than one elevator is provided, each full passenger elevator shall comply with 4.10. EXCEPTION 1: Elevators are not required in facilities that are less than three stories or that have less than 3000 square feet per story unless the building is a shopping center, a shopping mall, or the professional office of a health care provider, or another type of facility as determined by the Attorney General. The elevator exemption set forth in this paragraph does not obviate or limit in any way the obligation to comply with the other accessibility requirements established in section 4.1.3. For example, floors above or below the accessible ground floor must meet the requirements of this section except for elevator service. If toilet or bathing facilities are provided on a level not served by an elevator, then toilet or bathing facilities must be provided on the accessible ground floor. In new construction if a building or facility is eligible for this exemption but a full passenger elevator is nonetheless planned, that elevator shall meet the requirements of 4.10 and shall serve each level in the building. A full passenger elevator that provides service from a garage to only one level of a building or facility is not required to serve other levels. EXCEPTION 2: Elevator pits, elevator penthouses, mechanical rooms, piping or equipment catwalks are exempted from this requirement. EXCEPTION 3: Accessible ramps complying with 4.8 may be used in lieu of an elevator.

51-20-3105 (c) Elevators[, Platform Lifts and Stairways]. 1. [Elevators. A.] Where Required. In multi-story buildings or portions thereof required to be accessible by Section 3103, at least one elevator shall serve each level, including mezzanines. Other than within an individual dwelling unit, when an elevator is provided but not required, it shall be accessible. EXCEPTIONS: 1. In Group R. Division 1 apartment occupancies, an elevator is not required where accessible dwelling units and guest rooms are accessible by ramp or by grade level route of travel. 2. In a building of fewer than three stories an elevator is not required where ramps, gradelevel entrances or accessible horizontal exits from an adjacent building, are provided to each floor. 3. In multistory parking garages, an elevator is not required where an accessible route of travel is provided from accessible parking spaces on levels with accessible horizontal connections to the primary building served. 4. In Group R, Division 1 hotels and lodging houses less than 3 stories in height, an elevator is not required provided that accessible guest rooms are provided on the ground floor. [B. Design. All elevators shall be accessible.] EXCEPTIONS: 1. Private elevators serving only one dwelling unit. 2. Where more than one elevator is provided in the building, elevators used exclusively for movement of freight. 28 01-03227 ADA/Washington State July 12, 1994

4.1.3 (5)* Continued. 4.1.3 (5)* Continued. 51-20-3103 EXCEPTION 2: floors above and below accessible levels that have areas of less than 3000 square feet per floor, need not be

[served by an accessible route of travel from an accessible level. This exception shall not apply to: A. The offices of health care providers; or, B. Transportation facilities and airports; or, C. Buildings owned or leased by government agencies; or D. Multi-tenant Group B, Division 2, retail and wholesale occupancies of five tenant spaces or more.] 51-20-3105 (c) [1. Elevators.B.] Design. All elevators shall be accessible. EXCEPTIONS: 1. Private elevators serving only one dwelling unit. 2. Where more than one elevator is provided in the building, elevators used exclusively for movement of freight. Elevators required to be accessible shall be designed and constructed to comply with Chapter 296-81 of the Washington Administrative Code. [Amendment. P.N.E. The language raises the possibility that the phrase "that have areas of less than 3000 square feet per floor" refers to "accessible levels" without limiting "floors above and below" or vice versa. Thus, if the ground floor were less than 3000 square feet, WAC would not require an elevator, even though any number of floors above or below it were greater than 3000 square feet. It needs to be clear that no floor can exceed 3000 square feet. Although WAC does exceed the ADA in that WAC does not allow an elevator exemption for two-story buildings, that does not make up for the possible problem caused by the ambiguity regarding square footage per floor.] 29 01-03228 EXCEPTION 4: Platform lifts (wheelchair lifts) complying with 4.11 of this guideline and applicable state or local codes may be used in lieu of an elevator only under the following conditions: ADA/Washington State July 12, 1994

(a) To provide an accessible route to a performing area in an assembly occupancy. (b) To comply with the wheelchair viewing position line-ofsight and dispersion requirements of 4.33.3. (c) To provide access to incidental occupiable spaces and rooms which are not open to the general public and which house no more than five persons, including but not limited to equipment control rooms and projection booths. (d) To provide access where existing site constraints or other constraints make use of a ramp or an elevator infeasible. Comment: Issue 16. Item 1: Section 3103(a) 1 and 3103(b)2 have been revised to clarify that the exception for elevators is truly only an accessible route exception. It no longer exempts whole spaces from all accessibility standards. See also amendments to 3105(a). The Washington code now clearly provides greater accessibility than the ADAAG. See pages 599c, 601a and 603 of the Published Code. Item 2: The Washington State elevator standards were revised through an amendment to WAC Chapter 296-81 which was effective on July 1, 1992 to be consistent with the ADAAG. Section 296-81-007(5) specifically adopts the ANSI A117.1-1990 elevator standard which includes standards for wheelchair and platform lifts. In addition sections .300 through .360 and .370 adopts additional standards for elevator design and installation which are consistent with the ADA requirements. See Issue No. 46 for a comparison of the ADA and Washington regulations. (A copy of WAC 296-81 is attached.) 51-20-3105 (c) [2] Platform Lifts. Platform lifts may be used in lieu of an elevator under one of the following conditions subject to approval by the building official: [A.] To provide an accessible route of travel to a performing area in a Group A. Occupancy; or, [B.] To provide unobstructed sight lines and distribution for wheelchair viewing positions in Group A Occupancies; or, [C.] To provide access to spaces with an occupant load of less than 5 [that are not open to the public]; or [D.] To provide access where existing site constraints or other constraints make use of a ramp or elevator

infeasible. All platform lifts used in lieu of an elevator shall be capable of independent operation and shall comply with Chapter 296-81 of the Washington Administrative Code. [E. Equivalency of technical standards is addressed separately below.] 30 ADA/Washington State July 12, 1994

01-03229

4.1.3 (8) In new construction, at a minimum, the requirements in (a) and (b) below shall be satisfied independently: (a) (i) At least 50% of all public entrances (excluding those in (b) below) must be accessible. At least one must be a ground floor entrance. Public entrances are any entrances that are not loading or service entrances. (ii) Accessible entrances must be provided in a number at least equivalent to the number of exits required by the applicable building/fire codes. (This paragraph does not require an increase in the total number of entrances planned for a facility.) (iii) An accessible entrance must be provided to each tenancy in a facility (for example, individual stores in a strip shopping center). One entrance may be considered as meeting more than one of the requirements in (a). Where feasible, accessible entrances shall be the entrances used by the majority of people visiting or working in the building. [296-81-007. National Elevator Code adopted. ...(5) The American National Standard Safety Code for Elevators, Dumbwaiters, Escalators, and Moving Walks, ANSI A17.1,

1990 Edition, is adopted as the standard for elevators, dumbwaiters, escalators, and moving walks installed on or after July 1, 1992, with the exceptions of ANSI A17.1, Part XIX, and ANSI A17.1, Part V, Section 513, which is replaced by chapter 296-94 WAC.] Comment: Issue 17. Section 3105(c) 2C has been revised to read "To provide access to spaces with an occupant load of less than 5, that are not open to the public." (See paged (sic) 603a and 603b of the Published Code.) The provisions are now equivalent. Comment: Issue 18. See comment on Issue No. 16, above. 51-20-3103 (b) 3. Primary Entry[ance] Access. At least 50% of all public entries, or a number equal to the number of exits required by Section 3303 (a), whichever is greater, shall be accessible. One of the accessible public entries shall be the primary entry to a building. At least one accessible entry must be a ground floor entrance. Public entries do not include loading or service entries. EXCEPTION: In Group R. Division 1 apartment buildings only the primary entry need be accessible, provided that the primary entry provides an accessible route of travel to all dwelling units required to be accessible. Where a building is designed not to have common or primary entries, the primary entry to each individual dwelling unit required to be accessible, and each individual tenant space, shall be accessible. [E. Technical requirements addressed separately below.]

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01-03230 Comment: Issue 19. (See also comment on Issue No. 7, above.) Except where an apartment building is used as a

hotel, the ADA does not regulate apartment buildings. Under the UBC a permit issued for an apartment building is for residential apartment use and does not include transient use as covered by the ADA. A transient use of an apartment building would require a new building permit and occupancy certificate. If this is the intended use at the first permit, the applicant needs to so state so that the building is reviewed according to the proper standards. If that information is withheld there is a violation of the building code. Where the permit process is properly followed, this exception does not result in less accessibility than the ADA. To assist local building officials in understanding this difference, the Council has issued Interpretation No. 93-39. 32 ADA/Washington State July 12, 1994

01-03231 Interpretation 93-39: Question: For purposes of accessibility requirements ofChapter 31, how should buildings such as homeless shelters, halfway houses, (transient group homes, and similar social service establishments where people may sleep or temporarily reside be classified? Similarly, how should apartments or condominium complexes be classified where some or all of the units are rented to short term guests. Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent with the ADA Accessibility Guidelines. For the purpose of determining accessibility requirements per Chapter 31, uses such as homeless shelters, halfway houses, transient group homes, and similar facilities should be reviewed on a case by case basis. While these uses are "residential" in nature, if the residents are considered transient, classification as R-1 hotel, or R-3 lodging house is more appropriate. Some may need to be classified either in an I (Institutional) or B (Business) category. If services are provided at the site such as job or health counseling, classification should be in a category which requires accessibility. These uses should not be categorized as congregate residence when the residents are essentially transient.

Apartments or condominiums which are rented on a short term basis to transient guests should be categorized as either a Group R-1, hotel, or Group R-3 lodging house with appropriate accessibility provided. [E.] 33 ADA/Washington State July 12, 1994

01-03232 4.1.3 (8)(b)(i) In addition, if direct access is provided for pedestrians from an enclosed parking garage to the building, at least one direct entrance from the garage to the building must be accessible. (ii) If access is provided for pedestrians from a pedestrian tunnel or elevated walkway, one entrance to the building from each tunnel or walkway must be accessible. One entrance may be considered as meeting more than one of the requirements in (b). Because entrances also serve as emergency exits whose proximity to all parts of buildings and facilities is essential, it is preferable that all entrances be accessible. 51-30-3103 (b)2. ...The accessible route of travel shall be the most practical direct route connecting accessible building entrances, accessible site facilities and the accessible site entrances. Comment: Issue 20. Per the definition contained in Section 3102, these are primary entrances to a building and would need to be accessible, including the provision of accessible routes. Further, the side by side comparison appears to only compare this ADA requirement with one small part of the Washington provisions. Other provisions are critical to this comparison. The rest of 3103(b)2 is important, see attached. It clearly states that where there is more than one facility on the site, accessible routes be provided connected each facility. No exemption of any kind is provided for tunnels or elevated walkways. Section 3107 requires parking to be on

an accessible route which is the shortest possible to accessible building entrance(s). In case there is any question as to the intent of the provision, the Council has issued Interpretation No. 93-30. Intrepretation 93-30 Question: Must tunnels, elevated walkways, (pedestrian walkways) and doorways providing direct access from parking garages to a building provide an accessible entrance. Answer: Yes. The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guideline. These types of entrances and connections between buildings are considered to be primary entrances and must be accessible. [E.] 34 01-03233 4.1.3 (11) Toilet Facilities: If toilet rooms are provided, then each public and common use toilet room shall comply with 4.22. Other toilet rooms provided for the use of occupants of specific spaces (i.e., a private toilet room for the occupant of a private office) shall be adaptable. If bathing rooms are provided, then each public and common use bathroom shall comply with 4.23. Accessible toilet rooms and bathing facilities shall be on an accessible route. 51-20-3105 (b) Bathing and Toilet Facilities. 1. Bathing Facilities. When bathing facilities are provided, at least 2 percent but not less than 1, bathtub or shower shall be accessible. In dwelling units where both a bathtub and shower are provided in the same room, only one need be accessible. 51-20-3105 (b) 2. Toilet Facilities. Toilet facilities located within accessible dwelling units, guest rooms and congregate residences shall comply with Sections 3106(k) and 3106 (aa). In each toilet facility in other occupancies, at least one ADA/Washington State July 12, 1994

wheelchair accessible toilet stall with an accessible water closest shall be provided. In addition, when there are 6 or more water closets within a toilet facility, at least one other accessible toilet stall complying with Section 3106(k) 4, also shall be installed. Where urinals are provided, at least one urinal shall be accessible. 51-20-3105 (b) 3. Lavatories, Mirrors and Towel Fixtures. At least one accessible lavatory shall be provided within any toilet facility. Where mirrors, towel fixtures and other toilet and bathroom accessories are provided, at least one of each shall be accessible. 51-20-3106(k) 1. General. Bathrooms, toilet rooms, bathing facilities and shower rooms shall be designed in accordance with this section. For dwelling units see also Section 3106(aa). 35 01-03234 Comment: Issue 21. Item 1: 2% of Bathing Facilities. The intent of Interpretation No. 93-31 is to require accessible bathing facilities as required by ADA. It states that if only one bathing facility is provided in a building, it must be unisex and have 2% of its bathing features accessible; if multiple facilities are provided, they also must be accessible at the rate of 2% of the bathing fixtures. Item 2: Toilet Facilities without Stalls. The application of this section has been that each toilet facility is accessible, regardless of the number of facilities in a building or the number of water closets in the room or the presence of an actual "stall." In each "toilet facility" at least one fixture of each type provided must be accessible. The intent is to provide accessibility whether or not there is a stall. Read literally the WSR actually require a stall in all instances. No official interpretation of this has been issued and the questions received to date have been to nuances of meeting these provisions such as overlapping clear spaces in a single ADA/Washington State July 12, 1994

user facility, not whether it even has to be accessible because there is not a stall. Interpretation 93-31: Question: What is the application of the requirements for 2 percent of bathing facilities to be accessible when there is only one bathing facility in a building, or when there are multiple bathing facilities? Must separate facilities for each sex be provided? Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guidelines. Where only one bathing facility is provided in a building, 2 percent of the shower or bathtub fixtures within that facility must be accessible and the facility must be accessible to all persons (unisex). Where there are multiple bathing facilities in a building, each bathing facility must provide 2 percent of the shower or bathtub fixtures as accessible. Chapter 31 does not restrict how those bathing facilities are designated (men, women or unisex). [E.] 36 ADA/Washington State July 12, 1994

01-03235 4.1.3 (12) Storage, Shelving and Display Units: (a) If fixed or built-in storage facilities such as cabinets, shelves, closets, and drawers are provided in accessible spaces, at least one of each type provided shall contain storage space complying with 4.25. Additional storage may be provided outside of the dimensions required by 4.25. (b) Shelves or display units allowing self-service by customers in mercantile occupancies shall be located on an accessible route complying with 4.3. Requirements for accessible reach range do not apply. 4.1.3 (14) If emergency warning systems are provided, then they shall include both audible alarms and visual alarms complying with

4.28. Sleeping accommodations required to comply with 9.3 shall have an alarm system complying with 4.28. Emergency warning systems in medical care facilities may be modified to suit standard health care alarm design practice. 4.1.3 (15) Detectable warnings shall be provided at locations as specified in 4.29. 51-20-3105 (d) 6. Storage [Facilities]. In other than Group R, Division 1 apartment buildings, where fixed or built-in storage facilities such as cabinets, shelves, closets and drawers are provided in accessible spaces, at least one of each type provided shall contain storage space complying with Section 3106(r). Comment: Issue 22. See comment to Issue No. 19, above. 51-20-3105 (d) 9. Alarms. where provided, [alarm systems] shall include both audible and visible alarms. [Visible] alarm devices shall be located in all [assembly areas;] common-use areas including toilet rooms and bathing facilities,[;] hallways and lobbies[; and hotel guest rooms as required by Section 3103(a)8C]. EXCEPTIONS: 1. Alarm systems in Group I, Division 1.1 and 1.2 Occupancies may be modified to suit standard health care design practice. 2. Visible alarms are not required in Group R, Division 1 apartment buildings. Comment: Issue 23. See comment to Issue No. 19, above. 51-20-3106 (d) 5. B. Detectable Warnings. Curb ramps shall have detectable warnings complying with Section 3106 (g). Detectable warnings shall extend the full width and depth of the curb ramp. 51-20-3106 (d) [8]. Vehicular Areas. Where an accessible route of travel crosses or adjoins a vehicular way, and where there are no curbs, railings or other elements [which separate the pedestrian and vehicular areas and which are] detectable by a person who has a severe vision impairment, the boundary between the

areas shall be defined by a continuous detectable warning not less than 36 inches wide, complying with Section 3106 (q). [E.] [E.] 37 ADA/Washington State July 12, 1994

01-03236 4.1.3 (17) Public Telephones: (a) If public pay telephones, public closed circuit telephones, or other public telephones are provided, then they shall comply with 4.31.2 through 4.31.8 to the extent required by the following table: Number of each type of telephone provided on each floor 1 or more single unit 1 bank2 2 or more banks2 Number of telephones required to comply with 4.31.2 through 4.31.81

1 per floor 1 per floor 1 per bank. Accessible unit may be installed as a single unit in proximity (either visible or with signage) to the bank. At least one public telephone per floor shall meet the requirements for a forward reach telephone3.

1 Additional public telephones may be installed at any height. Unless otherwise specified, accessible telephones may be either forward or side reach telephones. 2 A bank consists of two or more adjacent public telephones, often installed as a unit. 3 EXCEPTION: For exterior installations only, if dial tone first service is available, then a side reach telephone may be installed

instead of the required forward reach telephone (i.e., one telephone in proximity to each bank shall comply with 4.31). Comment: Issue 24. The references have been corrected to 3106(q) in the November 1992 amendments, see attached. 51-20-3105 (d) 2. Telephones. On any floor where public telephones are provided at least one telephone shall be accessible. On any floor where 2 or more banks of multiple telephones are provided, at least one telephone in each bank shall be accessible and at least one telephone per floor shall be designed to allow forward reach complying with Section 3106... Comment: Issue 25. To simplify the code provisions, the Washington regulations lumped all telephones available to the public as public telephones. Section 401(a) of the UBC requires the use of Webster's Third New International Dictionary of the English Language, Unabridged, copyright 1986, to provide ordinary meanings for words not defined in the code. Webster's dictionary defines public as "a place accessible or visible to all members of the community." [E.] [E.] 38 ADA/Washington State July 12, 1994

01-03237 4.1.3 (19) (b) This paragraph applies to assembly areas where audible communications are integral to the use of the space (e.g., concert and lecture halls, playhouses and movie theaters, meeting rooms, etc.). Such assembly areas, if (1) they accommodate at least 50 persons, or if they have audio-amplification systems, and (2) they have fixed seating, shall have a permanently installed assistive listening system complying with 4.33. For other assembly areas, a permanently installed assistive listening system, or an adequate number of electrical outlets or other supplementary wiring necessary to support a portable assistive listening system

shall be provided. The minimum number of receivers to be provided shall be equal to 4 percent of the total number of seats, but in no case less than two. Signage complying with applicable provisions of 4.30 shall be installed to notify patrons of the availability of a listening system. 4.1.3 (20) Where automated teller machines are provided, each machine shall comply with the requirements of 4.34 except where two or more machines are provided at a location, then only one must comply. EXCEPTION: Drive-up-only automated teller machines are not required to comply with 4.34.2 and 4.34.3. 51-20-3103 (a) 2. B. Assistive Listening Devices. Assistive listening systems complying with Section 3106 (u) 3 shall be installed in assembly areas where audible communications are integral to the use of the space including stadiums, theaters, auditoriums, lecture halls, and similar areas; where fixed seats are provided; as follows: 1. Areas with an occupant load of 50 or more. 2. Areas where an audio-amplification system is installed. Receivers for assistive-listening devices shall be provided at a rate of 4 percent of the total number of seats, but in no case fewer than two devices. In other assembly areas, where permanently installed assistive-listening systems are not provided, [electrical outlets shall be provided at a rate of not less than 4 percent of the total occupant load]. Signage complying with Section 3106 (p) shall be installed to notify patrons of the availability of the listening system. Comment: Issue 26. See comment on Issue No. 2, above. Also, for assembly spaces without fixed seats, the ADA language requiring "an adequate number of electrical outlets. ... to support a portable assistive listening system" is not readily enforceable. To provide more specific standards for building designers and regulators, the Washington code provides an exact number of electrical outlets. If the intent of the ADA is only an outlet for the system transmitter, then a number of outlets which is 4% of the occupant load is going to be more than "adequate" and will provide greater accessibility than the ADA. [Appendix 51-20-93120(a) Purpose. The purpose of this

division is to provide the United States Architectural and Transportation Barriers Compliance Board Americans with Disabilities Act Guidelines for automated teller machines.] [E.] 39 01-03238 Comment: Issue 27. The ADA standards for ATM's are now located in the Appendix to Chapter 31. See page 970j of the Published Code.) As a total document, standards equivalent to the ADA are present and available for use. 51-20-3105 (d) 4. [Recreation Facilities. Where common or public use [recreation facilities,] swimming pools, hot tubs, spas and similar facilities are provided, they shall be accessible. Swimming pools shall be accessible by transfer tier, hydraulic chair, ramp or other means. Hot tubs and spas [need] be accessible only to the edge of the facility. [EXCEPTION: Common- or public-use facilities accessory to buildings not required to contain either Type A or Type B dwelling units in accordance with Section 3103(a)8B.] [This still does not provide scoping requirements. However, 28 C.F.R. S 36.607 provides that "if certain equipment is not covered by the [submitted] code, the determination of equivalency cannot be used as evidence with respect to the question of whether equipment in a building built according to the code satisfies the Act's requirements with respect to such equipment."] [Amendment: E.] 40 ADA/Washington State July 12, 1994 ADA/Washington State July 12, 1994

01-03239 4.1.5 Accessible Buildings: Additions. Each addition to an existing building or facility shall be regarded as an alteration. Each space or element added to the existing building or facility shall comply with the applicable provisions of 4.1.1 to 4.1.3, Minimum Requirements (for New Construction) and the applicable technical specifications of 4.2 through 4.35 and sections 5 through 10. Each addition that affects or could affect the usability of an area containing a primary function shall comply with 4.1.6(2). 51-20-3111 Additions. New additions may be made to existing buildings without making the entire building comply, provided the new additions conform to the provisions of Part II of this chapter except as follows: 1. Entries. Where a new addition to a building or facility does not have an accessible entry, at least one entry in the existing building or facility shall be accessible. 2. Accessible Route. Where the only accessible entry to the addition is located in the existing building or facility, at least one accessible route of travel shall be provided through the existing building or facility to all rooms, elements and spaces in the new addition which are required to be accessible. 3. Toilet and Bathing Facilities. Where there are no toilet rooms and bathing facilities in an addition and these facilities are provided in the existing building, then at least one toilet and bathing facility in the existing facility shall comply with Section 3106 or with Section 3112 (c) 5. 4. Group I Occupancies. Where patient rooms are added to an existing Group I Occupancy, a percentage of the additional rooms equal to the requirement of Section 3103 (a) 6., but in no case more than the total number of rooms required by Section 3103 (a) 6. shall comply with Section 3106 (w). Where toilet or bath facilities are part of the accessible rooms, they shall comply with Section 3106 (k). 5. Group R, Division 1 Apartment Buildings. Additions of 3 or fewer dwelling units in Group R, Division 1 apartment buildings need not comply with Part 1 of this chapter. Where an addition affects the access to or use of an area of primary function, to the maximum extent feasible, the path of travel to the area of primary function shall be made accessible.

Comment: Issue 28. See comment on to Issue No. 19, above. [E.] 41 01-03240 4.1.6 Accessible Buildings: Alterations. (1) General. Alterations to existing buildings and facilities shall comply with the following: (1) (a) No alteration shall be undertaken which decreases or has the effect of decreasing accessibility or usability of a building or facility below the requirements for new construction at the time of alteration. (1)(b) If existing elements, spaces, or common areas are altered, then each such altered element, space, feature, or area shall comply with the applicable provisions of 4.1.1 to 4.1.3 Minimum Requirements (for New Construction). If the applicable provision for new construction requires that an element, space, or common area be on an accessible route, the altered element, space, or common area is not required to be on an accessible route except as provided in 4.1.6(2) (Alterations to an Area Containing a Primary Function). 51-20-3110 Alteration is any change, addition or modification in construction or occupancy. 51-20-3112 Alterations. (a) General. 1. Compliance Alterations to existing buildings or facilities shall comply with this section. No alteration shall reduce or have the effect of reducing accessibility or usability of a building, portion of a building or facility. If compliance with this section is technically infeasible, the alteration shall provide accessibility to the maximum extent feasible. 51-20-3112 (a) 1. EXCEPTION: Except when substantial as defined by Section ADA/Washington State July 12, 1994

3110, alterations to Group R, Division 1 apartment buildings need not comply with this section. 51-20-0104 Application to Existing Buildings and Structures. (a) General. Buildings and structures to which additions, alterations or repairs are made shall comply with all the requirements of this code for new facilities except as specifically provided in this section. See Section 1210 for provisions requiring installation of smoke detectors in existing Group R, Division 3 Occupancies. (b) Addition, Alterations or Repairs. Additions, alterations or repairs may be made to any building or structure without requiring the existing building or structure to comply with all the requirements of this code, provided the addition, alteration or repair conforms to that required for a new building or structure. Additions or alterations shall not be made to an existing building or structure which will cause the existing building or structure to be in violation of any of the provisions of this code nor shall such additions or alterations cause the existing building or structure to become unsafe. . . (c) Any change in the use or occupancy of any existing building or structure shall comply with the provisions of Sections 308 and 502 of this code. For existing buildings, see Appendix Chapter 1.

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4.1.6, Continued. (1) (c) If alterations of single elements, when considered together, amount to an alteration of a room or space in a building or facility, the entire space shall be made accessible. 4.1.6(k) EXCEPTION: (i) These guidelines do not require the installation of an elevator in an altered facility that is less than three stories or has less than

3,000 square feet per story unless the building is a shopping center, a shopping mall, the professional office of a health care provider, or another type of facility as determined by the Attorney General. 4.1.6(k) EXCEPTION: (ii) The exemption provided in paragraph (i) does not obviate or limit in any way the obligation to comply with the other accessibility requirements established in these guidelines. For example, alterations to floors above or below the ground floor must be accessible regardless of whether the altered facility has an elevator. If a facility subject to the elevator exemption set forth in paragraph (i) nonetheless has a full passenger elevator, that elevator shall meet, to the maximum extent feasible, the accessibility requirements of these guidelines. 51-20-3112 (a) 2. Existing Elements. If existing elements, spaces, essential features or common areas are altered, each such altered element, space feature or area shall comply with the applicable provisions of Part II of this Chapter. Where an alteration is to an area of primary function, to the maximum extent feasible, the path of travel to the altered area shall be made accessible. See also Appendix Chapter 31 Division II. EXCEPTION 1: Accessible route of travel need not be provided to altered elements, spaces or common areas which are not areas of primary functions. 51-20-3112 (a) 4. Other Requirements. A. Where alterations of single elements, when considered together, amount to an alteration of a room or space in a building or facility, the entire area or space shall be accessible. 51-20-3112 (b) Substantial Alterations. Where substantial alteration as defined in Section 3110 occurs to a building or facility, the entire building or facility shall comply with Part II of this code. [EXCEPTION: Areas of evacuation assistance need not be added to a substantially altered building.] Comment: Issue 29. See comment on Issue No. 19, above. 51-20-3112(a)4.B. No alteration of an existing element, space or area of a building shall impose a requirement for greater accessibility than that which would be required for new construction.

[E.] NE No equivalent provision. Section 51-30-3103 (a) 1 allows floors of more than 3000 square feet above and below accessible floors to be constructed without access features. 43 ADA/Washington State July 12, 1994

01-03242

4.1.6 (2) Alterations to an Area Containing a Primary Function: In addition to the requirements of 4.1.6(1), an alteration that affects or could affect the usability of or access to an area containing a primary function shall be made so as to ensure that, to the maximum extent feasible, the path of travel to the altered area and the restrooms, telephones, and drinking fountains serving the altered area, are readily accessible to and usable by individuals with disabilities, unless such alterations are disproportionate to the overall alterations in terms of cost and scope (as determined under criteria established by the Attorney General). (See Section 36.403) Comment: Issue 30. See comment on Issue No. 16, above. 51-20-3112 (a) 2. Existing Elements. If existing elements, spaces, essential features or common areas are altered, each such altered element, space feature or area shall comply with the applicable provisions of Part II of this chapter. Where an alteration is to an area of primary function, to the maximum extent feasible, the path of travel to the altered area shall be made accessible. See Also Appendix Chapter 31, Division II. EXCEPTIONS: 1. Accessible route of travel need not be provided to altered elements, spaces or common areas which are not areas of primary function. 2. Areas of evacuation assistance need not be added to an altered building. [3. Subject to the approval of the building code official, the

path of travel need not be made accessible if the cost of compliance with this part would exceed 20 percent of the total cost of construction, inclusive of the cost of eliminating barriers, within an 36-month period.] 51-20-3114 (a)

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01-03243 Comment: Issue 31. With respect to this requirement, the Washington regulations will result in substantially more accessibility than the ADA. The Washington provision, now located in Sections 51-20-3111 and 3112(a)2 read as follows: ... [see above] The Washington provisions will result in more, rather than less improvements to the path of travel because of three differences between ADA and WSR: 1. Use of the exception is subject to review of the building official. The building official has the option of turning down the exception request, even if it exceeds 20%. 2. The Washington regulations do not require barrier removal. When a place of public accommodation does remove barriers, that action is treated as an alteration under the Washington regulations. If that action is occurring in an area of primary function, Washington law requires improvement to the path of travel, the ADA does not. 3. The Washington regulations require that 20% of the "total cost of construction" of the addition or alteration be applied to improving the path of travel. ADA requirements stated in Section 36.403(a) apply only to alterations which affect usability of, or access to an area of primary function. As such building modifications which don't affect access are not alterations under the ADA. These actions would not trigger the path of travel requirements nor their costs included in the determination of disproportional costs. In the Washington regulations, all the costs of the remodeling are

included. [The 36-month provision will create a snowball effect, because you take 20% of the past 3 years, regardless of whether the path of travel requirement was satisfied in the previous alterations. The ADA looks back only if the path of travel requirement was not met on the prior alterations. However, this does not result in less accessibility. In addition, because the disproportionality provision in WAC is a waiver, it is not covered by the certification determination.]

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Example: A owner proposes remodels of a building which include alterations to areas of primary function, removal of barriers and other changes. The total cost of the construction is $200,000. Under Washington regulations, $40,000 must also be applied to improvements to the path of travel. Under the ADA, much less will be spent. $50,000 is being spent to remove barriers. Another $40,000 is being spent on elements which do not affect accessibility or usability. Leaving only $110,000 being applied to "alterations," as defined in ADA. Under ADA, only $22,000 need be applied to improving the path of travel, before a claim of disproportionality can be made. For further clarification of the application of the Washington regulations see Council Interpretation No. 93-14. Interpretation 93-14: Question: 1. A 500 square foot addition is being proposed to the basement of an existing Group B, Division 2 Occupancy. The existing basement area is 3,200 square feet. Currently the building has two stairway exits from the basement, but it is not served by an elevator. The addition is primary function area. When applying the path of travel requirements, where the applicant intends to pursue an appeal because of costs over 20%, is it required that up to 20% be spent, or can it be waived. 2. Are items 1, 2, and 3 of Section 51-20-3111 redundant

with the requirement for improvements to the path of travel? Answer: 1. Each project should be considered on a case by case basis. If alterations to the path of travel exceed 20%, the intent of the code is that improvements to the path of travel be made to at least the 20% level. If however the only item needed to improve the path of travel costs more than the 20%, e.g. an elevator, then the expenditure on the path of travel can be "waived" at this time, but the amount should be added to future alterations or additions made in the subsequent 36 months. The code only requires improvements to the path of travel serving the addition or altered area. 2. Yes, items 1, 2, and 3 are part of the path of travel when additions are made to the area of primary function.

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01-03245 4.1.6 (3) (c) Elevators: (i) If safety door edges are provided in existing automatic elevators, automatic door reopening devices may be omitted (see 4.10.6). (ii) Where existing shaft configuration or technical infeasibility prohibits strict compliance with 4.10.9, the minimum car plan dimensions may be reduced by the minimum amount necessary, but in no case shall the inside car area be smaller than 48 in by 48 in. (iii) Equivalent facilitation may be provided with an elevator car of different dimensions when usability can be demonstrated and when all other elements required to be accessible comply with the applicable provisions of 4.10. For example, an elevator of 47 in by 69 in (1195 mm by 1755 mm) with a door opening on the narrow dimension, could accommodate the standard wheelchair

clearances shown in Figure 4. Fig. 4 Minimum Clear Floor Space for Wheelchairs. Fig. 4(d) Clear Floor Space in Alcoves. For a front approach, where the depth of the alcove is equal to or less than, 24 inches (610 mm), the required clear floor space is 30 inches by 48 inches (760 mm by 1220 mm). For a side approach, where the depth of the alcove is equal to or less than 15 inches (380 mm), the required clear floor space is 30 inches by 48 inches (760 mm by 1220 mm). Fig. 4(e) Additional Maneuvering Clearances for Alcoves. For a front approach, if the depth of the alcove is greater than 24 inches (610 mm), then in addition to the 30 inch (760 mm) width, a maneuvering clearance of 6 inches (150 mm) in width is required. For a side approach, where the depth of the alcove is greater than 15 inches (380 mm), then in addition to the 48 inch (1220 mm) length, an additional maneuvering clearance of 12 inches in length (305 mm) is required. 51-20-3112 (c) 4. Elevators. Elevators shall comply with Chapter 296-81, Washington Administrative Code. Comment: Issue 32. See comment on Issue No. 16, above. [E.]

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01-03246

4.1.6 (3) (e) Toilet Rooms: (i) Where it is technically infeasible to comply with 4.22 or 4.23,

the installation of at least one unisex toilet/bathroom per floor, located in the same area as existing toilet facilities, will be permitted in lieu of modifying existing toilet facilities to be accessible. Each unisex toilet room shall contain one water closet complying with 4.16 and one lavatory complying with 4.19, and the door shall have a privacy latch. (ii) Where it is technically infeasible to install a required standard stall (Fig. 30(a)), or where other codes prohibit reduction of the fixture count (i.e., removal of a water closet in order to create a double-wide stall), either alternate stall (Fig.30(b)) may be provided in lieu of the standard stall. (iii) When existing toilet or bathing facilities are being altered and are not made accessible, signage complying with 4.30.1, 4.30.2, 4.30.3, 4.30.5, and 4.30.7 shall be provided indicating the location of the nearest accessible toilet or bathing facility within the facility. 4.1.7 Accessible Buildings: Historic Preservation. (1) Applicability: (a) General Rule. Alterations to a qualified historic building or facility shall comply with 4.1.6 Accessible Buildings: Alterations, the applicable technical specifications of 4.2 through 4.35 and the applicable special application sections 5 through 10 unless it is determined in accordance with the procedures in 4.1.7(2) that compliance with the requirements for accessible routes (exterior and interior), ramps, entrances, or toilets would threaten or destroy the historic significance of the building or facility in which case the alternative requirements in 4.1.7(3) may be used for the feature. 51-20-3112 (c) 7. Toilet Rooms. A. Shared Facilities. The addition of one unisex toilet facility accessible to all occupants on the floor may be provided in lieu of making existing toilet facilities accessible when it is technically infeasible to comply with either part of Chapter 31. B. Number. The number of toilet facilities and water closets required by the Uniform Plumbing Code may be reduced by one, in order to provide accessible features. [C. Signage. When existing toilet facilities are altered and not all are made accessible, directional signage complying

with Section 3106(p)3 and 4 shall be provided indicating the location of the nearest accessible toilet facility.] 51-20-3113 Historic Preservation (a) General. Generally, the accessibility provisions of this part shall be applied to historic buildings and facilities as defined in Section 104 (f) of this code. The building official, after consultation with the appropriate historic preservation officer, shall determine whether provisions required by this part for accessible routes of travel (interior or exterior), ramps, entrances, toilets, parking or signage would threaten or destroy the historic significance of the building or facility. If it is determined that any of the accessibility requirements listed above would threaten or destroy the historic significance of a building or facility, the modifications of Section 3112 (c) for that feature may be utilized. [N.E. Need to address placement of the unisex toilet in the same area as existing facilities.]

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01-03247 4.1.7 (1) (b) Definition. A qualified historic building or facility is abuilding or facility that is: (i) Listed in or eligible for listing in the National Register of Historic Places; or (ii) Designated as historic under an appropriate State or local

law. 4.1.7 (2) Procedures: (a) Alterations to Qualified Historic buildings and Facilities Subject to Section 106 of the National Historic Preservation Act: 4.1.7 (2) (a) (i) Section 106 Process. Section 106 of the National Historic Preservation Act (16 U.S.C. 470 f) requires that a Federal agency with jurisdiction over a Federal, federally assisted, or federally licensed undertaking consider the effects of the agency's undertaking on buildings and facilities listed in or eligible for listing in the National Register of Historic Places and give the Advisory Council on Historic Preservation a reasonable opportunity to comment on the undertaking prior to approval of the undertaking. 4.1.7 (2) (a) (ii) ADA Application. Where alterations are undertaken to a qualified historic building or facility that is subject to section 106 of the National Historic Preservation Act, the Federal agency with jurisdiction over the undertaking shall follow the section 106 process. If the State Historic Preservation Officer or Advisory Council on Historic Preservation agrees that compliance with the requirements for accessible routes (exterior and interior), ramps, entrances, or toilets would threaten or destroy the historic significance of the building or facility, the alternative requirements in 4.1.7(3) may be used for the feature. 51-20-0104 (f) Historic Buildings. Repairs, alterations and additions necessary for the preservation, restoration, rehabilitation or continued use of a building or structure may be made without conformance to all the requirements of this code when authorized by the building official, provided: 1. The building or structure has been designated by official action of the legally constituted authority of this jurisdiction as having special historical or architectural significance. 2. Any unsafe conditions as described in this code are corrected. 3. The restored building or structure will be no more hazardous based on life safety, fire safety and sanitation than the existing building.

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01-03248

4.1.7 (2) (b) Alterations to Qualified Historic Buildings and Facilities Not Subject to Section 106 of the National Historic Preservation Act. Where alterations are undertaken to a qualified historic building or facility that is not subject to section 106 of the National Historic Preservation Act, if the entity undertaking the alterations believes that compliance with the requirements for accessible routes (exterior and interior), ramps, entrances, or toilets would threaten or destroy the historic significance of the building or facility and that the alternative requirements in 4.1.7(3) should be used for the feature, the entity should consult with the State Historic Preservation Officer. If the State Historic Preservation Office agrees that compliance with the accessibility requirements for accessible routes (exterior and interior), ramps, entrances or toilets would threaten or destroy the historical significance of the building or facility, the alternative requirements in 4.1.7(3) may be used. 4.1.7 (2) (c) Consultation With Interested Persons. Interested persons should be invited to participate in the consultation process, including State or local accessibility officials, individuals with disabilities, and organizations representing individuals with disabilities. 4.1.7 (2) (d) Certified Local Government Historic Preservation Programs. Where the State Historic Preservation Officer has delegated the consultation responsibility for purposes of this section to a local government historic preservation program that has been certified in accordance with section 101(c) of the National Historic Preservation Act of 1966 (16 U.S.C. 470a (c))

and implementing regulations (36 CFR 61.5), the responsibility may be carried out by the appropriate local government body or official. 51-20-3113 (a) ... The building official, after consultation with the appropriate historic preservation officer, shall determine whether provisions required by this part for accessible routes of travel (interior or exterior), ramps, entrances, toilets, parking or signage would threaten or destroy the historic significance of the building or facility. If it is determined that any of the accessibility requirements listed above would threaten or destroy the historic significance of a building or facility, the modifications of Section 3112 (c) for that feature may be utilized.

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01-03249

4.1.7 (3) Historic Preservation: Minimum Requirements: (a) At least one accessible route complying with 4.3 from a site access point to an accessible entrance shall be provided. EXCEPTION: A ramp with a slope no greater than 1:6 for a run not to exceed 2 ft (610 mm) may be used as part of an accessible route to an entrance. 51-20-3113 (b) Special Provisions. Where removing architectural barriers or providing accessibility would threaten or destroy the historic significance of a building or facility, the following special provisions may be used; 51-20-3113 (b) 1.

At least one accessible route from a site access point to an accessible route shall be provided. 51-20-3112 (c) Modifications. 1. General. The following modifications set forth in this section may be used for compliance where the required standard is technically infeasible or when providing access to historic buildings 51-20-3112 (c) 2. Ramps. Curb ramps and ramps constructed on existing sites, or in existing buildings or facilities, may have slopes and rises as specified for existing facilities in Chapter 31, where space limitations prohibit the use of 1 vertical in 12 horizontal slope or less provided that: A. A slope of not greater than 1 vertical in 10 horizontal is allowed for a maximum rise of 6 inches. B. A slope not greater than 1 vertical in 8 horizontal is allowed for a maximum rise of 3 inches. C. Slopes greater than 1 vertical in 8 horizontal are prohibited.

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01-03250

51-20-3114 Appeal (a) Request for Appeal. An appeal from the standards for accessibility for existing buildings may be filed with the building official in accordance with Section 204, when Existing structural elements or physical constraints of the site prevent full compliance or would threaten or destroy the historical significance of a historic building. 51-20-3114 (b) Review. 1. Consideration of Alternative Methods. Review of appeal requests shall include consideration of alternative methods which may provide partial access.

51-20-3114 (b) 2. Waiver or Modification of Requirements. The appeals board may waive or modify the requirements of this section when it is determined that compliance with accessibility requirements would threaten or destroy the historic significance of a building or facility.

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01-03251 Comment: Issue 33. The Washington request is for a determination of equivalency of the design and construction standards between the Washington Building Code and the ADA provisions. In the commentary to the final rule publication (page 35591, Federal Register, Volume 56, No 144); the Department of Justice implies that it will not be reviewing procedures as part of the certification process. The Washington procedure is only at slight variance from those contained in the ADA. The Washington law requires that the building official consult with the appropriate preservation officer. Therefore, if the building is on the National Register of Historic Places, the national process will have to be consulted. If it is a State or local landmark, that state or local process will be followed. Under the building code, the ultimate authority for review and issuance of permits lies with the building official. That duty technically can't be delegated to another agency or person outside of the direct authority of the building official. This is

the main reason behind the difference in the Washington procedure. The net effect may actually be more accessibility, in that a building official may be less likely to waive accessibility standards and requirements because of perceived impacts on historic significance than the specific historic preservation officer. Comment: Issue 34. See comment on Issue No. 33, above.

[Because the historic preservation provisions of WAC constitute a waiver, they are not covered by the certification determination.]

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01-03252 3/23/94 letter from Washington State Building Code Council. Issue 33 - Historic Buildings. The Washington State Building Code requires local building officials to consult with the appropriate preservation officer prior to approving use of alternative standards for accessibility for an historic building. Questions were raised whether the state process was similar to the national process. According to Mary Thompson, Assistant Director of the Washington State Office of Archeology and Historic Preservation, state and local historic offices are required to parallel the national process. See attached letter. Thompson letter. This letter is written to describe the process for entering properties onto the Washington State Register of Historic Places. The State Register is intended to give recognition and encourage protection to places having

historic significance in the State of Washington. The State Register process closely parallels the National Register process. Nominations are accepted by this office and are reviewed against the State Register Criteria (copy enclosed). That review takes place first at a staff level and then before the Washington State Advisory Council on Historic Preservation. If, in the judgment of the Advisory Council, a property meets the outlined criteria, they may recommend it to the State Historic Preservation Officer that it be placed on the State Register. The final decision on whether the property is listed belongs to the State Historic Preservation Officer. Properties that are reviewed and recommended for the National Register of Historic Places are automatically included on the State Register. Separate votes of the Advisory Council are taken for each listing.... 54 01-03253 ADA/Washington State July 12, 1994

4.2.3* Wheelchair Turning Space. The space required for a wheelchair to make a 180-degree turn is a clear space of 60 in (1525 mm) diameter (see Fig. 3(a)) or a T-shaped space (see Fig. 3(b)). Fig. 3 Wheelchair Turning Space. Fig. 3(b) T-Shaped Space for 180 degree Turns. The Tshape space is 36 inches (915 mm) wide at the top and stem within a 60 inch by 60 inch (1525 mm by 1525 mm) square. 51-20-3106 (b) 2. Wheelchair Turning Spaces. Wheelchair turning spaces shall be designed and constructed to satisfy one of the following requirements: A. A turning space not less than 60 inches in diameter; or, B. A turning space at T-shaped intersections or within a room, where the minimum width is not less than 36 inches. Each

segment of the T shall be clear of obstructions not less than 24 inches in each direction. [Wheelchair turning space may include knee and toe clearance in accordance with Section 3106(b)4C.] [Amendment: E.] 55 01-03254 ADA/Washington State July 12, 1994

4.3.2 Location. (1) At least one accessible route within the boundary of the site shall be provided from public transportation stops, accessible parking, and accessible passenger loading zones, and public streets or sidewalks to the accessible building entrance they serve. The accessible route shall, to the maximum extent feasible, coincide with the route for the general public. (2) At least one accessible route shall connect accessible buildings, facilities, elements, and spaces that are on the same site. (3) At least one accessible route shall connect accessible building or facility entrances with all accessible spaces and elements and with all accessible dwelling units within the building or facility. (4) An accessible route shall connect at least one accessible entrance of each accessible dwelling unit with those exterior and interior spaces and facilities that serve the accessible dwelling unit. 51-20-3103 (b) 2. Accessible Route of Travel. When a building, or portion of a building, is required to be accessible, an accessible route of travel shall be provided to all portions of the building, to accessible building entrances and connecting the building and the public way. The accessible route of travel to areas of primary function may serve but shall not pass through kitchens, storage rooms, toilet rooms,

bathrooms, closets or other similar spaces. [EXCEPTIONS: 1. A single accessible route shall be permitted to pass through a kitchen or storage room in an accessible dwelling unit. 2. Floors above and below accessible levels that have areas of less than 3,000 square feet per floor, need not be served by an accessible route of travel from an accessible level. This exception shall not apply to: A. The offices of health care providers; or, B. Transportation facilities and airports; or, C. Buildings owned or leased by government agencies; or, D. Multi-tenant Group B, Division 2, retail and wholesale occupancies of five tenant spaces or more. Accessible routes of travel serving any accessible space or element shall also serve as a means of egress for emergencies or connect to an area of evacuation assistance.] When more than one building or facility is located on a site, accessible routes of travel shall be provided connecting accessible buildings and accessible site facilities. The accessible route of travel shall be the most practical direct route connecting accessible building entrances, accessible site facilities and the accessible site entrances. EXCEPTION [3] [Move up]: For sites where natural terrain or other unusual property characteristics do not allow the provision of an accessible route of travel from the public way to the building, the point of vehicular debarkation may be substituted for the accessible entrance to the site. [(For Group R, Division 1 occupancies, see Section 3105(c)1.)] [Amendment: E.]

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01-03255

4.3.8 Changes in Levels. Changes in levels along an accessible route shall comply with 4.5.2. If an accessible route has changes in level greater than 1/2 in (13 mm), then a curb ramp, ramp, elevator, or platform lift (as permitted in 4.1.3 and 4.1.6) shall be provided that complies with 4.7, 4.8, 4.10, or 4.11, respectively.

An accessible route does not include stairs, steps, or escalators. See definition of "egress, means of" in 3.5. 4.3.11.3* Stairway Width. Each stairway adjacent to an area of rescue assistance shall have a minimum clear width of 48 inches between handrails. 4.3.11.4* Two-way Communication. A method of two-way communication, with both visible and audible signals, shall be provided between each area of rescue assistance and the primary entry. The fire department or appropriate local authority may approve a location other than the primary entry. 51-20-3106 (d) 4. Changes in Level. Changes in level along an accessible route of travel shall comply with Section 3106 (f). Stairs shall not be part of an accessible route of travel. Any raised area within an accessible route of travel shall be cut through to maintain a level route or shall have curb ramps at both sides and a level area not less than 48 inches long connecting the ramps. 51-20-3106 (f) Changes in Level. Accessible routes of travel and accessible spaces within buildings shall have continuous common floor or ramp surfaces. Abrupt change in height greater than 1/4 inch shall be beveled to 1 vertical in 2 horizontal. Changes in level greater than 1/2 inch shall be accomplished by means of a ramp meeting the requirements of Section 3106 (h) [a curb ramp meeting the requirements of Section 3106(d)7, or an elevator or platform lift meeting the requirements of Section 3105(c)]. For Type B dwelling units, see also Section 3106 (aa). 51-20-3104 (b) 3. Stairway Width. Each stairway adjacent to an area for evacuation assistance shall have a minimum clear width of 48 inches [between handrails]. Comment: Issue 35. Section 3104(b)3 has been amended to read in part ". . .shall have a minimum clear width of 48 inches between handrails." See page 602 of the Published Code. 51-20-3104 (b) 4. Two-way Communication. A telephone with controlled access to a public telephone system or another method of two-way communication shall be provided between each area for evacuation assistance and the primary entry. [The telephone or other two-way communication system shall be located with the reach ranges specified in Section 3106(b)4.] The fire department

may approve location other than the primary entrance. [The communication system shall not require voice communication.] Comment: Issue 36. Section 3104(b)4 has been amended to include the following sentence: "The communication system shall not require voice communication." See page 602 of the Published Code. [Amendment: E.] [E.] [E.] 57 ADA/Washington State July 12, 1994

01-03257

4.4 Protruding Objects. 4.4.1* General. Objects projecting from walls (for example, telephones) with their leading edges between 27 in and 80 in (685 mm and 2030 mm) above the finished floor shall protrude no more than 4 in (100 mm) into walks, halls, corridors, passageways, or aisles (see Fig. 8(a)). Objects mounted with their leading edges at or below 27 in (685 mm) above the finished floor may protrude any amount (see Fig. 8(a) and (b)). Free-standing objects mounted on posts or pylons may overhang 12 in (305 mm) maximum from 27 in to 80 in (685 mm to 2030 mm) above the ground or finished floor (see Fig. 8(c) and (d)). Protruding objects shall not reduce the clear width of an accessible route or maneuvering space (see Fig. 8(e)). Fig. 8 Protruding Objects. Fig. 8(c-1) Overhead Hazards. As an example, the diagram illustrates a stair whose underside descends across a pathway. Where the headroom is less than 80 inches, protection is offered by a railing (2030 mm) which can be no higher than 27 inches

(685 mm) to ensure detectability. Fig. 8(d) Objects Mounted on Posts or Pylons. The diagram illustrates an area where an overhang can be greater than 12 inches (305 mm) because the object cannot be approached in the direction of the overhang. Fig. 8(e) Example of Protection around Wall-Mounted Objects and Measurements of Clear Widths. The minimum clear width for continuous passage is 36 inches. Thirty two (32) inches is the minimum clear width for a maximum distance of 24 inches (610 mm). The maximum distance an object can protrude beyond a wing wall is 4 inches (100 mm). 51-20-3106(e) Protruding Objects. Protruding objects shall not reduce the clear width of an accessible route of travel or maneuvering space. Any wall- or post-mounted object with its leading edge between 27 inches and 79 inches above the floor may project not more than 4 inches into a [an accessible route of travel, corridor, passageway, or aisle]. Any wall-or post-mounted projection greater than 4 inches shall extend to the floor. [Amendment: N.E. It needs to be clear that "accessible" refers only to "route of travel" and not to "corridor, passageway, or aisle." Objects may not protrude into pathways even if those pathways are not otherwise "accessible". However, because WAC seems to require all routes in new construction to be accessible, this is only a potential problem in alterations.]

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01-03258

4.5.2 Changes in Level. Changes in level up to 1/4 in (6 mm) may be vertical and without edge treatment (see Fig. 7(c)). Changes in level between 1/4 in and 1/2 in (6 mm and 13 mm) shall be beveled with a slope no greater than 1:2 (see Fig. 7(d)). Changes

in level greater than 1/2 in (13 mm) shall be accomplished by means of a ramp that complies with 4.7 or 4.8. 4.5.3* Carpet. If carpet or carpet tile is used on a ground or floor surface, then it shall be securely attached; have a firm cushion, pad, or backing, or no cushion or pad; and have a level loop, textured loop, level cut pile, or level cut/uncut pile texture. The maximum pile thickness shall be 1/2 in (13 mm) (see Fig. 8(f)). Exposed edges of carpet shall be fastened to floor surfaces and have trim along the entire length of the exposed edge. Carpet edge trim shall comply with 4.5.2. 51-20-3106 (f) Changes in Level. Accessible routes of travel and accessible spaces within buildings shall have continuous common floor or ramp surfaces. Abrupt change in height greater than 1/4 inch shall be beveled to 1 vertical in 2 horizontal. Changes in level greater than 1/2 inch shall be accomplished by means of a ramp meeting the requirements of Section 3106 (h) [, a curb ramp meeting the requirements of Section 3106(d)7, or an elevator or platform lift meeting the requirements of Section 3105(c)]. For Type B dwelling units, see also Section 3106 (aa). 51-20-3106 (g) 2. Carpeting. Carpeting and floor mats in accessible areas shall be securely fastened to the underlying surface, and shall provide a firm, stable, continuous and relatively smooth surface. Comment: Issue 37. The Washington State Building Code Council did not feel that it was appropriate to include carpet pile height (thickness) in a building code, nor would it be appropriate to expect building inspectors to inspect for carpet pile height. Instead the WSR provides performance rather than prescriptive standards which have a better chance of resulting in accessible surfaces. In addition it allows greater design flexibility than the simplistic pile thickness standard. The Washington accessibility regulations have contained the requirement that carpeting provide a firm, stable, continuous and relatively smooth surface since 1976. Experience with this performance provision is that is adequate for the purpose. While carpet pile height may be important, the density of carpet piles is more critical and whether a surface is provided on which a person in a wheelchair can move and maneuver. The Washington regulation actually provides a more stringent, more accessible standard than the ADA.

[Amendment: E.] [E.]

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01-03259

4.6.2 Location. Accessible parking spaces serving a particular building shall be located on the shortest accessible route of travel from adjacent parking to an accessible entrance. In parking facilities that do not serve a particular building, accessible parking shall be located on the shortest accessible route of travel to an accessible pedestrian entrance of the parking facility. In buildings with multiple accessible entrances with adjacent parking, accessible parking spaces shall be dispersed and located closest to the accessible entrances. 4.6.3* Parking Spaces. Accessible parking spaces shall be at least 96 in (2440 mm) wide. Parking access aisles shall be part of an accessible route to the building or facility entrance and shall comply with 4.3. Two accessible parking spaces may share a common access aisle (see Fig. 9). Parked vehicle overhangs shall not reduce the clear width of an accessible route. Parking spaces and access aisles shall be level with surface slopes not exceeding 1:50 (2%) in all directions. Fig. 9 Dimensions of Parking Spaces. The access aisle shall be a minimum of 60 inches (1525 mm) wide for cars or a minimum of 96 inches (2440 mm) wide for vans. The accessible route connected to the access aisle at the front of the parking spaces shall be a minimum of 36 inches (915 mm).

51-20-3107 (a) . . .[6] Accessible parking spaces shall be located on the shortest possible accessible route of travel to an accessible building entrance. In facilities with multiple accessible building entrances with adjacent parking, accessible parking spaces shall be dispersed and located near the accessible entrances. Wherever practical, the accessible route of travel shall not cross lanes of vehicular traffic. Where crossing traffic lanes is necessary, the route of travel shall be designated and marked as a crosswalk. [EXCEPTION: In multilevel parking structures, all accessible van parking spaces may be located on the same level. Where a parking facility is not accessory to a particular building, accessible parking spaces shall be located on the shortest accessible route to an accessible pedestrian entrance to the parking facility.] 51-20-3107 (b) 2. Size. Parking spaces shall be not less than 96 inches in width and shall have an adjacent access aisle not less than 60 inches in width. [Van accessible parking spaces shall have an adjacent access aisle not less than 96 inches in width.] Where two adjacent spaces are provided, the access aisle may be shared between the two spaces. Boundaries of access aisles shall be marked so that aisles will not be used as parking space. 51-20-3107 (b) 4. Slope. Accessible parking spaces and access aisles shall be located on a surface with a slope not to exceed 1 vertical in 48 horizontal. 51-20-3107 (b) 5. Surface. Parking spaces and access aisles shall be firm, stable, smooth and slip-resistant.

[Amendment: E] [Amendment: E]

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01-03260

4.6.4* Signage. Accessible parking spaces shall be designated as reserved by a sign showing the symbol of accessibility (see 4.30.7). Spaces complying with 4.1.2(5)(b) shall have an additional sign "Van-Accessible" mounted below the symbol of accessibility. Such signs shall be located so they cannot be obscured by a vehicle parked in the space. 4.6.5* Vertical Clearance. Provide minimum vertical clearance of 114 in (2895 mm) at accessible passenger loading zones and along at least one vehicle access route to such areas from site entrance(s) and exit(s). At parking spaces complying with 4.1.2(5)(b), provide minimum vertical clearance of 98 in (2490 mm) at the parking space and along at least one vehicle access route to such spaces from site entrance(s) and exit(s). 51-20-3107 (c) Signs. Every parking space required by this section shall be identified by a sign, centered between 3 and 5 feet above the parking surface, at the head of the parking space. The sign shall include the International Symbol of Access and the phrase "State Disabled Parking Permit Required." [Van accessible parking spaces shall have an additional sign mounted below the International Symbol of Access identifying the spaces as "Van Accessible." EXCEPTION: Where all of the accessible parking spaces comply with the standards for van accessible parking spaces. (See also Section 3106(aa)2.)] Comment: Issue 38. Section 3107(c) has been amended to require the additional van accessible signage. See page 604t of the Published Code. 51-20-3107 (b) 3. Vertical Clearance. Where accessible parking spaces are provided for vans, the vertical clearance shall be not less than 114 inches [at the parking space and along at least one vehicle access route to such spaces from site entrances and exits]. Comment: Issue 39. Section 3107(b)3 has been amended to read in part ". . . the vertical clearance shall be not less than 114 inches at the parking space and along at least one vehicle access route to such spaces from site entrances and exits." (See page 604s of the Published Code.) It should be noted that the

Washington van height provides greater accessibility than the ADA. The intent of the WSR van parking height requirement was to apply to loading zones as well because these are essentially temporary parking spaces for all types of vehicles. To clarify the intent of the Code, the Council has issued interpretation No. 9333. [E.] [Amendment: E.] [E.]

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4.6.6 Passenger Loading Zones. Passenger loading zones shall provide an access aisle at least 60 in (1525 mm) wide and 20 ft (240 in)(6100 mm) long adjacent and parallel to the vehicle pull-up space (see Fig. 10). If there are curbs between the access aisle and the vehicle pull-up space, then a curb ramp complying with 4.7 shall be provided. Vehicle standing spaces and access aisles shall be level with surface slopes not exceeding 1:50 (2%) in all directions. 4.7.5 Sides of Curb Ramps. If a curb ramp is located where pedestrians must walk across the ramp, or where it is not protected by handrails or guardrail, it shall have flared sides; the maximum slope of the flare shall be 1:10 (see Fig. 12(a)). Curb ramps with returned curbs may be used where pedestrians would not normally walk across the ramp (see Fig. 12(b)). Fig. 12 Sides of Curb Ramps.

Fig. 12(a) Flared Sides. If the landing depth at the top of a curb ramp is less than 48 inches, then the slope of the flared side shall not exceed 1:12. Interpretation No. 93-33 Question: Are there any height (clearance) requirements for passenger load zones? Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guidelines. Accessible passenger load zones are essentially temporary parking spaces. The loading zones and the vehicular route to and from the load zones must have a clear height of 114 inches, as is required for van parking spaces. 51-20-3108 Passenger Drop-off and Loading Zones. (a) Location. Where provided, passenger loading zones shall be located on an accessible route of travel.

51-20-3108 (b) [2] Size. Passenger loading zones shall provide an access aisle not less than 5 feet in width by 20 feet in length with the long dimension abutting and parallel to: (1) the vehicle space on one side and (2) an accessible route of travel on the other. 51-20-3108 (b) 3. Slope. Such zones shall be located on a surface with a slope not exceeding 1 vertical in 48 horizontal. 51-20-3106 (d) [7] C. Side Slopes of Curb Ramps. Curb ramps located where pedestrians must walk across the ramp, or where not protected by handrails or guardrails, shall have sloped sides. The maximum side slope shall be 1 vertical in 10 horizontal. Curb ramps with returned curbs may be used where pedestrians would not normally walk across the ramp. [EXCEPTION: Where the width of the walking surface at the top of the ramp and parallel to the run of the ramp is less than 48 inches, the maximum side slope shall be 1 vertical in 12 horizontal.] [E.] [Amendment: E.]

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4.7.7 Detectable Warnings. A curb ramp shall have a detectable warning complying with 4.29.2. The detectable warning shall extend the full width and depth of the curb ramp. 4.7.10 Diagonal Curb Ramps. If diagonal (or corner type) curb ramps have returned curbs or other well-defined edges, such edges shall be parallel to the direction of pedestrian flow. The bottom of diagonal curb ramps shall have 48 in (1220 mm) minimum clear space as shown in Fig. 15(c) and (d). If diagonal curb ramps are provided at marked crossings, the 48 in (1220 mm) clear space shall be within the markings (see Fig. 15(c) and (d)). If diagonal curb ramps have flared sides, they shall also have at least a 24 in (610 mm) long segment of straight curb located on each side of the curb ramp and within the marked crossing (see Fig. 15(c)). Comment: Issue 40. Section 3106(d)7C has been amended to add the following additional provision: ... [see above]. See page 604b of the Published Code. 51-20-3106 (d) 5. B. Detectable Warnings. Curb ramps shall have detectable warnings complying with Section 3106 (q). Detectable warnings shall extend the full width and depth of the curb ramp. 51-20-3106 (d) [8]. Vehicular Areas. Where an accessible route of travel crosses or adjoins a vehicular way, and where there are no curbs, railings or other elements [which separate the pedestrian and vehicular areas, and which are] detectable by a person who has severe vision impairment the boundary between the areas shall be defined by a continuous detectable warning not less than 36 inches wide, complying with Section 3106 (g). Comment: Issue 41. See comment on Issue No. 24, above.

Comment: Issue 42. Diagonal curb ramp standards are not included in the WSR. Therefore, diagonal curb ramps are not directly permitted by the Washington Code. This design is rarely seen in designs for private development, but is more typically found at street intersection designs. The Washington Building Code does not apply to public rights of way, but only to development off of public rights of way. If someone wishes to use it, it could be approved by the local building official as an alternate design (equivalent facilitation). [E.] [E.] NE No equivalent provisions. [N.E. WSR does not prohibit use of diagonal curb ramps and leaves regulation of such ramps completely up to the discretion of the inspector. The special provisions for diagonal curb ramps are necessary to allow people enough space to maneuver out of the way of traffic and to lessen pedestrian traffic on the ramp so that individuals in wheelchairs can use it.] 63 ADA/Washington State July 12, 1994

01-03263 4.8.2* Slope and Rise. The least possible slope shall be used for any ramp. The maximum slope of a ramp in new construction shall be 1:12. The maximum rise for any run shall be 30 in (760 mm) (see Fig. 16). Curb ramps and ramps to be constructed on existing sites or in existing buildings or facilities may have slopes and rises as shown as allowed in 4.1.6(3)(a) if space limitations prohibit the use of a 1:12 slope or less (see 4.1.6). Fig. 16 Components of a Single Ramp Run and Sample Ramp

Dimensions. If the slope of a ramp is between 1:12 and 1:16, the maximum rise shall be 30 inches (760 mm) and the maximum horizontal run shall be 30 feet (9 m). If the slope of the ramp is between 1:16 and 1:20, the maximum rise shall be 30 inches (760 mm) and the maximum horizontal run shall be 40 feet (12 m). 51-20-3106 (h) 2. Slope and Rise. The maximum slope of a ramp shall be 1 vertical in 12 horizontal. The maximum rise for any run shall be 30 inches. 51-20-3315 (e) Ramp Slope. The slope of ramped aisles shall not be more than 1 vertical in 8 horizontal. Ramped aisles shall have a slip-resistant surface. EXCEPTION: When provided with fixed seating, theaters may have a slope not steeper than 1 vertical to 5 horizontal. Comment: Issue 43. The ramped aisles allowed by Section 3315(e) of the UBC are not allowed as part of an accessible route. Specifically Section 3315(a) states: "Aisles located within an accessible route of travel shall also comply with Chapter 31." Chapter 31 limits slope on accessible routes to a maximum rise of 1 in 12. [E.] 64 ADA/Washington State July 12, 1994

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4.8.5* Handrails. If a ramp run has a rise greater than 6 in (150

mm) or a horizontal projection greater than 72 in (1830 mm), then it shall have handrails on both sides. Handrails are not required on curb ramps or adjacent to seating in assembly areas. Handrails shall comply with 4.26 and shall have the following features: (1) Handrails shall be provided along both sides of ramp segments. The inside handrail on switchback or dogleg ramps shall always be continuous. 51-20-3106 (h) 5. Handrails. Ramps having slopes steeper than 1 vertical in 20 horizontal shall have handrails as required for stairways, except that intermediate handrails as required in Section 3306 (i) are not required. Handrails shall be continuous provided that they shall not be required at any point of access along the ramp, nor at any curb ramp. Handrails shall extend at least 12 inches beyond the top and bottom of any ramp segment. EXCEPTION: Ramps having a rise less than or equal to 6 inches or a run less than or equal to 72 inches need not have handrails. 51-20-3306 (i) Handrails. Stairways shall have handrails on each side, and every stairway required to be more than 88 inches in width shall be provided with not less than one intermediate handrail for each 88 inches of required width. Intermediate handrails shall be spaced approximately equally across the entire width of the stairway. EXCEPTION: 1. Stairways less than 44 inches in width or stairways serving one individual dwelling unit in Group R, Division 1 or 3 Occupancies, or a Group R, Division 3 congregate residence may have one handrail. 2. Private stairways 20 inches or less in height may have handrails on one side only. 3. Stairways having less than four risers and serving one individual dwelling unit in Group R, Division 1 or 3, or a Group R. Division 3 congregate residence or serving Group M. Occupancies need not have handrails.

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(2) If handrails are not continuous, they shall extend at least 12 in (305 mm) beyond the top and bottom of the ramp segment and shall be parallel with the floor or ground surface (see Fig. 17). (3) The clear space between the handrail and the wall shall be 1 1/2 in (38 mm). (4) Gripping surfaces shall be continuous. (5) Top of handrail gripping surfaces shall be mounted between 34 in and 38 in (865 mm and 965 mm) above ramp surfaces. (6) Ends of handrails shall be either rounded or returned smoothly to floor, wall, or post. (7) Handrails shall not rotate within their fittings. The top of handrails and handrail extensions shall be placed not less than 34 inches or more than 38 inches above the nosing of treads and landings. Handrails shall be continuous the full length of the stairs and, except for private stairways, at least one handrail shall extend in the direction of the stair run not less than 12 inches beyond the top riser or less than 23 inches beyond the bottom riser. Ends shall be returned or shall terminate in newel posts or safety terminals. The handgrip portion of handrails shall be not less than 1 1/2 inches or more than 2 inches in cross-sectional dimension or the shape shall provide an equivalent gripping surface. The handgrip portion of handrails shall have a smooth surface with no sharp corners. Handrails projecting from a wall shall have a space of not less than 1 1/2 inches between the wall and the handrail. Any recess containing a handrail shall allow a clearance of not less than 18 inches above the top of the rail, and shall be not more than 3 inches in horizontal depth.

Handrails shall not rotate within their fittings. Comment: Issue 44. The reference to Section 3306(i) for handrail requirements could be construed to allow single handrails in some circumstances. Since the exceptions only specifically state stairways, it was the intent of the Council that these exceptions not apply to ramps. The Council has issued Interpretation No. 9335 to clarify this limitation. [E.] 66 ADA/Washington State July 12, 1994

01-03266 Interpretation No. 93-35. Question: Do the exceptions in Section 3306(i) allowing only one handrail apply to ramps and stairways required to be accessible by Chapter 31? Answer: The intent of the code, as provided in Sec. 3101(a) is to provide standards equivalent to the ADA Accessibility Guidelines. Ramps. The exceptions do not apply to ramps designed for compliance with Chapter 31. Such ramps must provide handrails on both sides. Stairways. For stairways which provide access to areas of buildings where the accessible route exceptions have been used and no elevator or ramp is provided (per Sec. 3103(b)), handrails must be provided on both sides of the stairway regardless of the occupant load served.

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4.8.7 Edge Protection. Ramps and landings with drop-offs shall have curbs, walls, railings, or projecting surfaces that prevent people from slipping off the ramp. Curbs shall be a minimum of 2 in (50 mm) high (see Fig. 17). [51-20-3106(h)7. Edge Protection. Any portion of the edge of a ramp with a slope greater than 1 vertical in 20 horizontal, or landing which is more than 1/2 inch above the adjacent grade or floor, shall be provided with edge protection in accordance with the following: A. Walls and Curbs. When used, walls or curbs shall be not less than 2 inches in height above the surface of the accessible route of travel. B. Railings. When used, railings shall comply with Section 3106(h)5 and also shall have one of the following features: (i) An intermediate rail mounted 17 to 19 inches above the ramp or landing surface, or (ii) A guardrail complying with Section 1712.] [Amendment: E.]

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4.9.4 Handrails. Stairways shall have handrails at both sides of all stairs. Handrails shall comply with 4.26 and shall have the following features:

(1) Handrails shall be continuous along both sides of stairs. The inside handrail on switchback or dogleg stairs shall always be continuous (see Fig. 19(a) and (b)). (2) If handrails are not continuous, they shall extend at least 12 in (305 mm) beyond the top riser and at least 12 in (305 mm) plus the width of one tread beyond the bottom riser. At the top, the extension shall be parallel with the floor or ground surface. At the bottom, the handrail shall continue to slope for a distance of the width of one tread from the bottom riser; the remainder of the extension shall be horizontal (see Fig. 19(c) and (d)). Handrail extensions shall comply with 4.4. (3) The clear space between handrails and wall shall be 1-1/2 in (38 mm). (4) Gripping surfaces shall be uninterrupted by newel posts, other construction elements, or obstructions. (5) Top of handrail gripping surface shall be mounted between 34 in and 38 in (865 mm and 965 mm) above stair nosing. (6) Ends of handrails shall be either rounded or returned smoothly to floor, wall or post. (7) Handrails shall not rotate within their fittings. 51-20-3306 (i) Handrails. Stairways shall have handrails on each side, and every stairway required to be more than 88 inches in width shall be provided with not less than one intermediate handrail for each 88 inches of required width. Intermediate handrails shall be spaced approximately equally across the entire width of the stairway. EXCEPTION: 1. Stairways less than 44 inches in width or stairways serving one individual dwelling unit in Group R, Division 1 or 3 Occupancies, or a Group R, Division 3 congregate residence may have one handrail. 2. Private stairways 20 inches or less in height may have handrails on one side only. 3. Stairways having less than four risers and serving one individual dwelling unit in Group R, Division 1 or 3, or a Group R, Division 3 congregate residence or serving Group M. Occupancies need not have handrails.

3306 (i) Handrails. ... The top of handrails and handrail extensions shall be placed not less than 34 inches or more than 38 inches above the nosing of treads and landings. Handrails shall be continuous the full length of the stairs and, except for private stairways, at least one handrail shall extend in the direction of the stair run not less than 12 inches beyond the top riser or less than 23 inches beyond the bottom riser. Ends shall be returned or shall terminate in newel posts or safety terminals. The handgrip portion of handrails shall be not less than 1 1/2 inches or more than 2 inches in cross-sectional dimension or the shape shall provide an equivalent gripping surface. The handgrip portion of handrails shall have a smooth surface with no sharp corners. Handrails projecting from a wall shall have a space of not less than 1 1/2 inches between the wall and the handrail. Any recess containing a handrail shall allow a clearance of not less than 18 inches above the top of the rail, and shall be not more than 3 inches in horizontal depth. Handrails shall not rotate within their fittings.

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4.10 Elevators. 4.10.1 General. Accessible elevators shall be on an accessible route and shall comply with 4.10 and with the ASME A17.1-1990, Safety Code for Elevators and Escalators. Freight elevators shall not be considered as meeting the requirements of this section unless the only elevators provided are used as combination passenger and freight elevators for the public and employees. Comment: Issue 45. Section 3306(a) requires all stairways to be 44 inches wide or more unless the occupant load served is less

than 50. These are all fairly small buildings, and typically stairways less than 44 inches only occur in residential (non transient) apartment buildings. Use in commercial, educational or assembly buildings is very rare. To clarify that handrails on accessible stairs must have two handrails, the Council has issued Interpretation No. 93-35. Interpretation No. 93-35. Question: Do the exceptions in Section 3306(i) allowing only one handrail apply to ramps and stairways required to be accessible by Chapter 31? Answer: The intent of the code, as provided in Sec. 3101 (a) is to provide standards equivalent to the ADA Accessibility Guidelines. Ramps. The exceptions do not apply to ramps designed for compliance with Chapter 31. Such ramps must provide handrails on both sides. Stairways. For stairways which provide access to areas of buildings where the accessible route exceptions have been used and no elevator or ramp is provided (per Sec. 3103(b)), handrails must be provided on both sides of the stairway regardless of the occupant load served. 51-20-3105 (c) Elevators. 2-[B] Design. All elevators shall be accessible. EXCEPTION: 1. Private elevators serving only one dwelling unit. 2. Where more than one elevator is provided in the building, elevators used exclusively for movement of freight. Elevators required to be accessible shall be designed and constructed to comply with Chapter 296-81 of the Washington Administrative Code. [296-81-007 (5) The American National Standard Safety Code for Elevators, Dumbwaiters, Escalators, and Moving Walks, ANSI A17.1, 1990 Edition is adopted as the standard for elevators, dumbwaiters, escalators and moving walks installed on or after July 1, 1992, with the exceptions of ANSI A17.1, part XIX, and ANSI A17.1, part V, Section 513, which is replaced by chapter 296-94 WAC.] [E.]

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4.10.2 Automatic Operation. Elevator operation shall be automatic. Each car shall be equipped with a self-leveling feature that will automatically bring the car to floor landings within a tolerance of 1/2 in (13 mm) under rated loading to zero loading conditions. This self-leveling feature shall be automatic and independent of the operating device and shall correct the overtravel or undertravel. 4.10.3 Hall Call Buttons. Call buttons in elevator lobbies and halls shall be centered at 42 in (1065 mm) above the floor. Such call buttons shall have visual signals to indicate when each call is registered and when each call is answered. Call buttons shall be a minimum of 3/4 in (19 mm) in the smallest dimension. The button designating the up direction shall be on top. (See Fig. 20.) Buttons shall be raised or flush. Objects mounted beneath hall call buttons shall not project into the elevator lobby more than 4 in (100 mm). 4.10.4 Hall Lanterns. A visible and audible signal shall be provided at each hoistway entrance to indicate which car is answering a call. Audible signals shall sound once for the up direction and twice for the down direction or shall have verbal annunciators that say "up" or "down." Visible signals shall have the following features: (1) Hall lantern fixtures shall be mounted so that their centerline is at least 72 in (1830 mm) above the lobby floor. (See Fig. 20.) (2) Visual elements shall be at least 2-1/2 in (64 mm) in the smallest dimension. (3) Signals shall be visible from the vicinity of the hall call button

(see Fig. 20). In-car lanterns located in cars, visible from the vicinity of hall call buttons, and conforming to the above requirements, shall be acceptable. Comment: Issue 46. See comment on Issue No. 16, above. Also see attached side by side analysis of the adopted Washington elevator standards and ADAAG standards. [296-81-300. Operation and leveling. The elevator shall be automatic and be provided with a self-leveling feature that will automatically bring the car to the floor landings within a tolerance of plus or minus 1/2 inch under normal loading and unloading conditions. This self-leveling shall within its zone, be entirely automatic and independent of the operating device and shall correct for overtravel or undertravel. The car shall also be maintained approximately level with the landing irrespective of load.] [296-81-355. Hall Buttons. The centerline of the hall call buttons shall be a nominal (42) inches above the floor. The button designating the UP direction shall be on top. Direction buttons, exclusive of border, shall be a minimum of (3/4) inch in size, raised or flush. Visual indication shall be provided to show each call registered and extinguished when the call is answered. Depth of flush buttons when operated shall not exceed (3/8) inch.] [296-81-360. Hall lantern. A visual and audible signal shall be provided at each hoistway entrance, indicating to the prospective passenger which car is answering the call and its direction of travel. The visual signal for each direction shall be at least two and onehalf inches in size and visible from the vicinity of the hall call button. The audible signal shall sound once for the up direction and twice for the down direction. The centerline of the fixture shall be located at least six feet from the floor. The lanterns may be located in the jamb or in the car.] [See below] [Amendment: E.]

[Amendment: E.] [Amendment: E.]

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4.10.5 Raised and Braille Characters on Hoistway Entrances. All elevator hoistway entrances shall have raised and Braille floor designations provided on both jambs. The centerline of the characters shall be 60 in (1525 mm) above finish floor. Such characters shall be 2 in (50 mm) high and shall comply with 4.30.4. Permanently applied plates are acceptable if they are permanently fixed to the jambs. (See Fig. 20). 4.10.6* Door Protective and Reopening Device. Elevator doors shall open and close automatically. They shall be provided with a reopening device that will stop and reopen a car door and hoistway door automatically if the door becomes obstructed by an object or person. The device shall be capable of completing these operations without requiring contact for an obstruction passing through the opening at heights of 5 in and 29 in (125 mm and 735 mm) above finish floor (see Fig. 20). Door reopening devices shall remain effective for at least 20 seconds. After such an interval, doors may close in accordance with the requirements of ASME A17.1-1990. 4.10.7* Door and Signal Timing for Hall Calls. The minimum acceptable time from notification that a car is answering a call until the doors of that car start to close shall be calculated from the following equation: T = D/(1.5 ft/s) or T = D/(445 mm/s) where T total time in seconds and D distance (in feet or millimeters) from a point in the lobby or corridor 60 in (1525 mm)

directly in front of the farthest call button controlling that car to the centerline of its hoistway door (see Fig. 21). For cars with in-car lanterns, T begins when the lantern is visible from the vicinity of hall call buttons and an audible signal is sounded. The minimum acceptable notification time shall be 5 seconds. 4.10.8 Door Delay for Car Calls. The minimum time for elevator doors to remain fully open in response to a car call shall be 3 seconds. [296-81-350. Door jamb marking. The floor designation shall be provided at each hoistway entrance on both sides of jamb visible from within the car and the elevator lobby at a centerline height of (60) inches above the floor. Designations shall be on contrasting color background (2) inches high and raised (.30) inch, and shall be accompanied by Grade 2 Braille. Applied plates permanently attached shall be acceptable.] [296-81-310 Door delay. (1). Hall call. The minimum acceptable initial transfer time from notification that a car is answering a call (lantern and audible signal) until the doors of the car start to close shall be 0 to 5 ft.-4 sec.; 10 ft.-7 sec.; 15 ft.-10 sec.; 20 ft.-13 sec. The distance shall be established from a point in the center of the corridor or lobby (maximum 5 feet) directly opposite the farthest hall button controlling that car to the centerline of the hoistway entrance.] [296-81-310 Door delay. (2). Car call. The minimum acceptable initial transfer time for doors to remain fully open shall be not less than 3 seconds.] [Amendment: E.] NE [Amendment: E.]

[Amendment: E.]

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4.10.9 Floor Plan of Elevator Cars. The floor area of elevator cars shall provide space for wheelchair users to enter the car, maneuver within reach of controls, and exit from the car. Acceptable door opening and inside dimensions shall be as shown in Fig. 22. The clearance between the car platform sill and the edge of any hoistway landing shall be no greater than 1-1/4 in (32 mm). Fig. 22 Minimum Dimensions of Elevator Cars. Diagram (a) illustrates an elevator with a door providing a 36 inch (915 mm) minimum clear width, in the middle of the elevator. The width of the elevator car is a minimum of 80 inches (2030 mm). The depth of the elevator car measured from the back wall to the elevator door is a minimum of 54 inches (1370 mm). The depth of the elevator car measured from the back wall to the control panel is a minimum of 51 inches (1291 mm). Diagram (b) illustrates an elevator with door providing a minimum 36 inch (915 mm) clear width, located to one side of the elevator. The width of the elevator car is a minimum of 68 inches (1730 mm). The depth of the elevator car measured from the back wall to the elevator door is a minimum of 54 inches (1370 mm). The depth of the elevator car measured from the back wall to the control panel is a minimum of 51 inches (1291). 4.10.10 Floor Surfaces. Floor surfaces shall comply with 4.5. 4.10.11 Illumination Levels. The level of illumination at the car controls, platform, and car threshold and landing sill shall be at least 5 footcandles (53.8 lux).

[296-81-315 Car interior. The car interior shall provide space for wheelchair users to enter the car, maneuver within reach of controls and exit the car. (1) Doors shall provide (36) inches clear minimum width. (2) Car depth (51) inches minimum from rear wall to return panel, with (54) inches minimum from rear wall to inside face of cab door. (3) Cab width of cab for side opening door (68) inches minimum, center opening door cab width (80) inches minimum. Clearance between car platform sill and edge of hoistway landing sill shall be (1 1/4) inches maximum. EXCEPTION: Elevators provided in existing schools, institutions, or other buildings specifically authorized by local authorities may have a minimum clear distance between walls or between wall and door including return panels of not less than 54 X 54 inches. Minimum distance from wall to return panel shall be not less than 51 inches.] [296-81-335 Floor covering. Floor covering should have a nonslip hard surface which permits easy movement of wheelchairs. If carpeting is used, it should be securely attached, heavy duty, with a tight weave and low pile, installed without padding.] [296-81-345 Minimum illumination. The minimum illumination shall be in accordance with the latest edition of ANSI A17.1.] [Amendment: E.] [Amendment: E.] [Amendment: E.] 73 ADA/Washington State July 12, 1994

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4.10.12* Car Controls. Elevator control panels shall have the following features: (1) Buttons. All control buttons shall be at least 3/4 in (19 mm) in their smallest dimension. They shall be raised or flush. (2) Tactile, Braille, and Visual Control Indicators. All control buttons shall be designated by Braille and by raised standard alphabet characters for letters, arabic characters for numerals, or standard symbols as shown in Fig. 23(a), and as required in ASME A17.1-1990. Raised and Braille characters and symbols shall comply with 4.30. The call button for the main entry floor shall be designated by a raised star at the left of the floor designation (see Fig. 23(a)). All raised designations for control buttons shall be placed immediately to the left of the button to which they apply. Applied plates, permanently attached, are an acceptable means to provide raised control designations. Floor buttons shall be provided with visual indicators to show when each call is registered. The visual indicators shall be extinguished when each call is answered. (3) Height. All floor buttons shall be no higher than 54 in (1370 mm) above the finish floor for side approach and 48 in (1220 mm) for front approach. Emergency controls, including the emergency alarm and emergency stop, shall be grouped at the bottom of the panel and shall have their centerlines no less than 35 in (890 mm) above the finish floor (see Fig. 23(a) and (b)). Fig. 23 Car Controls. Fig. 23(a) Panel Detail. The diagram illustrates the symbols used for the following control buttons: main entry floor, door closed, door open, emergency alarm, and emergency stop. The diagram further states that the octagon symbol for the emergency stop shall be raised but the X (inside the octagon) is not. (4) Location. Controls shall be located on a front wall if cars have center opening doors, and at the side wall or at the front wall next to the door if cars have side opening doors (see Fig. 23(c) and (d)).

[296-81-320 Car controls. At least one set of controls shall be readily accessible from a wheelchair upon entering an elevator. The centerline of the alarm button and emergency stop switch shall be at nominal (35) inches and the highest floor buttons no higher than (54) inches from the floor where side approach is provided. (48) inches maximum where forward approach is required. Floor registration buttons, exclusive of border, shall be a minimum of (3/4) inch in size, raised or flush. Visual indication shall be provided to show each call registered and extinguished when call is answered. Depth of flush buttons when operated shall not exceed (3/8) inch. Markings shall be adjacent to the controls on a contrasting color background to the left of the controls. Letters or numbers shall be a minimum of (5/8) inch high and raised (.030) inch. All control buttons shall be designated by Braille. Applied plates permanently attached shall be acceptable. Emergency controls shall be grouped together at the bottom of the control panel. Symbols as indicated shall be used to assist in readily identifying essential controls (see ANSI A17.1, page 114, Rule 211.1). Controls not essential to the operation of the elevator may be located as convenient.] [Amendment: E. Although the ADA requires all panels to be at wheelchair-accessible height and WAC only requires 1, having several control panels at different heights can serve more people (higher panels help people who have difficulty bending). As long as all panels are accessible to people with visual impairments, this is alright.] NE

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4.10.13* Car Position Indicators. In elevator cars, a visual car position indicator shall be provided above the car control panel or over the door to show the position of the elevator in the hoistway. As the car passes or stops at a floor served by the elevators, the corresponding numerals shall illuminate, and an audible signal shall sound. Numerals shall be a minimum of « in (13 mm) high. The audible signal shall be no less than 20 decibels with a frequency no higher than 1500 Hz. An automatic verbal announcement of the floor number at which a car stops or which a car passes may be substituted for the audible signal. 4.10.14* Emergency Communications. If provided, emergency two-way communication systems between the elevator and a point outside the hoistway shall comply with ASME A17.1-1990. The highest operable part of a two-way communication system shall be a maximum of 48 in (1220 mm) from the floor of the car. It shall be identified by a raised symbol and lettering complying with 4.30 and located adjacent to the device. If the system uses a handset then the length of the cord from the panel to the handset shall be at least 29 in (735 mm). If the system is located in a closed compartment the compartment door hardware shall conform to 4.27. Controls and Operating Mechanisms. The emergency intercommunication system shall not require voice communication. [296-81-325 Car position indicator signal. A visual car position indicator shall be provided above the car control panel or above the door. (1) As the car passes or stops at a floor, the corresponding numbers shall illuminate and an audible signal shall sound. (2) Numerals shall be a minimum (1/2) inch high. (3) Audible signal shall be no less than (20) decibels with frequency no higher than 1500 Hz. (4) An automatic verbal announcement of the floor number may be

substituted for the audible signal.] [296-81-330 Telephone or intercommunicating system. An emergency two-way communication system shall be provided between the elevator and a point outside the hoistway that shall comply with ASME/ANSI A17.1-1990, and the following: (1) Highest operable part of system shall be maximum (48) inches from the floor. (2) System shall be identified by raised symbol and lettering located adjacent to the device. Characters shall be (5/8) inch to (2) inches high, raised (1/32) inch, upper case, sans serif or simple serif type, and shall be accompanied by Grade 2 Braille. (3) If system uses a handset, minimum cord length shall be (29) inches. (4) If located in a closed compartment, door shall be operable with one hand, shall not require tight grasping, pinching, or twisting of the wrist, and shall require a maximum force of (5) lbf. (5) The emergency communication system shall not require voice communication. (Voice only system is inaccessible to persons with speech or hearing impairments.)] [296-81-340 Handrails. A handrail shall be provided on all walls of the car that are not used for normal exits. There shall be a space of one and one-half inches between the wall and the rail. The rail shall be at a nominal height of between thirty-two and thirty-five inches from the floor. The hand grip portion of handrails shall be not less than one and one-quarter inches or more than two inches in width, shall be basically oval or round in cross-section, and shall have smooth surfaces with no sharp corners. Handrails that approach each other or a blank car wall in the interior corners of the car need not be returned to the wall. If the end of the handrail presents an abrupt end on the closing jamb wall to persons entering a car that has a single-slide or two-speed entrance, the handrail end shall be returned to the wall.] [Amendment: E.] [Amendment: E.]

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4.11 Platform Lifts (Wheelchair Lifts). 4.11.1 Location. Platform lifts (wheelchair lifts) permitted by 4.1 shall comply with the requirements of 4.11. 4.11.2* Other Requirements. If platform lifts (wheelchair lifts) are used, they shall comply with 4.2.4, 4.5, 4.27, and ASME A17.1 Safety Code for Elevators and Escalators, Section XX, 1990. 4.11.3 Entrance. If platform lifts are used then they shall facilitate unassisted entry, operation, and exit from the lift in compliance with 4.11.2. See below. Comment: Issue 47. See comment on Issue No. 18, above. 51-20-3105 (c) 3. All platform lifts used in lieu of an elevator shall be capable of independent operation and shall comply with Chapter 296-81 of the Washington Administrative Code. [296-81-007. National Elevator Code Adopted. ... (5) The American National Standard Safety Code for Elevators, Dumbwaiters, Escalators, and Moving Walks, ANSI A17.1, 1990 Edition is adopted as the standard for elevators, dumbwaiters, escalators, and moving walks installed on or after July 1, 1992, with the exceptions of ANSI A17.1, Part XIX, and ANSI A17.1, Part V, Section 513, which is replaced by chapter 296-94 WAC.]

[Amendment: E.]

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4.13.6 Maneuvering Clearances at Doors. Minimum maneuvering clearances at doors that are not automatic or power-assisted shall be as shown in Fig. 25. The floor or ground area within the required clearances shall be level and clear. Fig. 25 Maneuvering Clearances at Doors. NOTE: All doors in alcoves shall comply with the clearances for front approaches. Diagram (a) Front Approaches--Swinging Doors. Front approaches to pull side of swinging doors shall have maneuvering space that extends 18 in (455 mm) minimum beyond the latch side of the door and 60 in (1525 mm) minimum perpendicular to the doorway. Front approaches to push side of swinging doors, equipped with both closer and latch, shall have maneuvering space that extends 12 in (305 mm) minimum beyond the latch side of the door and 48 in (1220 mm) minimum perpendicular to the doorway. Front approaches to push side of swinging doors, not equipped with latch and closer, shall have maneuvering space that is the same width as door opening and extends 48 in (1220 mm). minimum perpendicular to the doorway. Diagram (b) Hinge Side Approaches. Hinge-side approaches to pull side of swinging doors shall have maneuvering space that extends 36 in (915 mm) minimum beyond the latch side of the door if 60 in (1525 mm) minimum is provided perpendicular to the doorway or maneuvering space that extends 42 in (1065 mm) minimum beyond the latch side of the door shall be provided if 54 in (1370 mm) minimum is provided perpendicular to the doorway. Hinge-side approaches to push side of swinging doors, not equipped with both latch and closer, shall have a maneuveringspace of 54 in (1370 mm) minimum, parallel to the doorway and

42 in (1065 mm) minimum, perpendicular to the doorway. 51-20-3106 (j) 3. Maneuvering Clearances at Doors. Except as provided in Section 3106 (aa) (3106 (aa) is dwelling units), all doors shall have minimum maneuvering clearances as follows: A. Where a door must be pulled to be opened, an unobstructed floor space shall extend at least 18 inches beyond the strike jamb. B. Where a door must be pushed to be opened and is equipped with a closer and a latch, an unobstructed floor space shall extend at least 12 inches beyond the strike jamb. [... D. Where a door must be pulled to be opened, an unobstructed floor space shall be provided that extends 60 inches, perpendicular to the doorway. E. Where a door must be pushed to be opened an unobstructed floor space shall extend 48 inches perpendicular to the doorway.] NE Provisions do not contain enough detail to ensure access at doors. For example, ADAAG Fig. 25 requires maneuvering clearances that range in size from 60 inches by 52 inches to 48 inches by 32 inches, depending on door swing, approach, etc. Although provisions in sections 51-20-3304 (i) and (j) compensate in some ways, the provisions are still inadequate.

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Hinge side approaches to push side of swinging doors, equipped with both latch and closer, shall have maneuvering space of 54 in (1370 mm) minimum, parallel to the doorway, 48 in (1220 mm) minimum perpendicular to the doorway. Diagram (c) Latch Side Approaches--Swinging Doors. Latch-side approaches to pull side of swinging doors, with closers, shall have maneuvering space that extends 24 in (610 mm) minimum beyond the latch side of the door and 54 in (1370 mm) minimum perpendicular to the doorway. Latch-side approaches to pull side of swinging doors, not equipped with closers, shall have maneuvering space that extends 24 in (610 mm) minimum beyond the latch side of the door and 48 in (1220 mm) minimum perpendicular to EXCEPTION: Entry doors to acute care hospital bedrooms for in-patients shall be exempted from the requirement for space at the latch side of the door (see dimension "x" in Fig. 25) if the door is at least 44 in (1120 mm) wide. 51-20-3304 (i) Floor Level at Doors. Regardless of the occupant load, there shall be a floor or landing on each side of a door. When access for persons with disabilities is required by Chapter 31, the floor or landing shall not be more than 1/2 inch lower than the threshold of the doorway. When such access is not required, such dimension shall not exceed 1 inch. Landings shall be level except for exterior landings, which may have a slope not to exceed 1/4 inch per foot. 51-20-3304 (j) Landings at Doors. Landings shall have a width not less than the width of the stairway or the width of the door, whichever is the greater. Doors in the fully open position shall not reduce a required dimension by more than 7 inches. when a landing serves an occupant load of 50 or more, doors in any position shall not reduce the landing dimension to less than onehalf its required width. Landings shall have a length measured in the direction of travel of not less than 44 inches. Comment: Issue 48. The provisions of Section 3106(j)3 were amended in November 1992 to provide clear areas measured perpendicular to the door. (See page 604e of the Published Code.) In developing the Washington regulations, it was felt that the 11 different approach requirements were confusing and unnecessary. Most doors are hinged swing doors. Few manually operated doors

are slide opening doors. With the 1992 amendments, we believe that the maneuvering clearance standards are comparable. The Washington Code simplifies the doors and maneuvering clearances from the variety in ADA. This simplifies compliance and enforcement and is more likely to result in accessible construction of doorways. The ADA and ANSI standards are still available as alternate designs which can be approved by the building official. NE See above. [N.E. WAC fails to address hinge-side approaches and latch-side approaches. WAC still does not address sliding/folding doors.]

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3/23/94 letter from Washington State Building Code Council Issue 48 - In order to simplify the Washington regulations, the maneuvering clearance requirements were condensed into three basic requirements contained in Section 3106(j). These three are the forward approach to a door where the door swings toward the user, a forward approach to a door where the door swings away from the user, and two doors in series. As stated in our response of August 20, 1993, our regulations simplify compliance and enforcement and is more likely to result in accessible construction of doorways. We have recently issued a specific interpretation, number 94-02, that allows the use of ANSI A117.1-1992 door clearances as alternatives to the three standards in the code. Maneuvering clearances at doors must be looked at in conjunction with other requirements of the State Building Code which are provided in Chapter 33 on Exiting (egress). The primary provisions which will affect maneuvering clearances are the

requirements for minimum corridor widths (Sec. 3305). Most corridors must be a minimum of 44 inches in width, unless the occupant load is less than 49 persons. In addition, the code prohibits doors in any position from reducing the width of a corridor by more than half of the required width. We assume that you understand that if a door is in the wall of a room, that adequate maneuvering clearances will always be present unless the door is in a corner. We have therefore focused our comparison on where maneuvering clearances might be most restricted and that is where a door is located on a corridor wall. Figure 25 of the ADAAG illustrates 9 different maneuvering clearances for doors. We have compared the effect of the Washington State Code in comparison to the ADAAG diagrams and provide the following analysis. It should be noted that the footnote in Figure 25 states that doors in alcoves must comply with clearances for a front approach. The ADAAG does not define an alcove. The Washington Code presumes a forward approach in all situations, in which case it is completely consistent with the ADAAG.

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A. Front Approaches - Swinging Doors: The front approaches as diagrammed in Figure 25(a) are reflected specifically in the Washington language in Section 3106(j). B. Hinge Side Approaches - Swinging Doors: Two basic conditions are noted: 1. Doors swing into the approach. Please refer to attached Diagram A. Under the Washington code this would be treated as a forward approach door and the required maneuvering clearance is shown in black. In this case ADA would require additional clearance on the latch side of the door. If the design of the building is such that this door was at the end of a

corridor, the additional clearance would be missing. If the corridor continues, then only the crosshatched area labeled A would not be provided. It should be noted that the maneuvering clearance required for this door when approached in a forward approach is deemed adequate with only 18 inches on the latch side, but if the approach is from behind the door 18 inches is not sufficient, even though a person would have to turn and essentially make a forward approach to this door. While it appears that the Washington code is not identical to the ADAAG, there is no loss in maneuverability. 2. Doors swing away from approach: Two conditions are noted in Figure 25(b), doors with, or without, closers. For doors without both a closer and a latch, a smaller maneuvering clearance is shown in ADAAG. See Diagram B. Again the Washington regulations for this door are shown in black, the comparable ADAAG design is shown in red. In this instance, the overall maneuvering space required by the Washington Code is greater than ADAAG. If the approaching corridor is only 36 inches in width, a small area shown crosshatched (A) would not be present, but the area labeled (B) would be present which is substantially greater. Where a door in this condition has both a closer and a latch, a greater width is required. Again, as illustrated in Diagram C, the potentially lost space (A) is more than compensated by the Washington required maneuvering space (B). [#B.1. N.E. ADA Standards require a space 60" by 72" for a hinge side parallel approach. Washington only requires 60" by 54". There is a loss of maneuverability because the person does not make simply a front approach, as Washington assumes, but rather, the person has to continue beyond the door before attempting to maneuver into a forward approach position. The crosshatched area is an essential part of the minimum maneuvering space because it allows the person room to move from the side of the door into the forward approach position. #B.2. N.E. For a hinge side parallel approach on the push side of a door, the ADA Standards require a space 48" by 54". Also, the ADA requires the 54" dimension to begin at the latch side of the door. The Washington requirement overlaps the ADA requirement only partially

because it does not require the 54" dimension to begin at the latch side. Therefore, Washington allows the maneuvering space to be in a different place than the ADA requires. Washington assumes that the size of the maneuvering space is all that matters. In fact, the size, the shape, and the position of the maneuvering space all matter and different sizes, shapes and positions are needed depending on the direction of approach to the door.]

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C. Latch Side Approaches - Swinging Doors: 1. Doors swing into approach: Two conditions are noted in the left hand portion of Figure 25(c), doors with, or without, closers. For doors without a closer a smaller maneuvering clearance is shown in ADAAG. See Diagram D. Where the approaching corridor is only 36 or 44 inches wide, a minor portion of maneuvering space would not be present as shown in the crosshatched area (A), however a substantially greater area of maneuvering space is provided in the area shown as (B). Where the door has a closer, See Diagram E, the potentially missing space (A) is slightly larger than noted in the preceding case, but it is still compensated by a significant increase in maneuvering space at (B). 2. Doors swing away from approach: Again two conditions are noted depending on whether or not a closer is present. Where a door does not have a closer, (See Diagram F) a small area of ADAAG maneuvering clearance (A) would not be present where a corridor is only 36 inches in width, which would be compensated for by the additional area (B) which results from compliance with the Washington requirements.

Where the door does have a closer a minor amount of space may not be provided as shown by the crosshatched area A in Diagram G. D. Sliding Doors: 1. Forward approach. The maneuvering space will be adequate in all cases since the minimum corridor widths of 36 or 44 inches are equal to or greater than the width of shown in the ADAAG Figure 25(d). The depth will be provided, or else this would not be a forward approach of someone traveling down a corridor or across a room to this door. 2. Slide or latch side approaches. For doors located on a typical corridor of 44 inches, the maneuvering space shown in ADAAG Figures 25(e) and 25(f) will be present, or the corridor will not be in compliance with other provisions of our code.

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4.13.7 Two Doors in Series. The minimum space between two hinged or pivoted doors in series shall be 48 in (1220 mm) plus the width of any door swinging into the space. Doors in series shall swing either in the same direction or away from the space between the doors (see Fig. 26). 4.13.8* Thresholds at Doorways. Thresholds at doorways shall not exceed 3/4 in (19 mm) in height for exterior sliding doors or 1/2 in (13 mm) for other types of doors. Raised thresholds and floor level changes at accessible doorways shall be beveled with a slope no greater than 1:2 (see 4.5.2). Interpretation No. 94-02. Question: Do the requirements for door

clearances as defined in this section apply to all approaches including parallel, or are they applicable only to a forward approach? Answer: In order to simplify all potential options into a concise format, the door standards were written for the most stringent conditions with the reasoning that if doors always met these standards full compliance would also be met. Section 3101(d) allows the approval of alternate methods of construction, design, or technologies provided that they supply equivalent or greater accessibility. The CABO/ANSI A117.1-1992 Section 4.13 provides description and diagramming of suitable alternate standards for all types of door operations. It was not the intent of the code to prohibit the use of these alternatives. 51-20-3106 (j) 3.C. Where two doors are in a series, the minimum distance between two hinged or pivoted doors shall be 48 inches in addition to any needed for door swing. [Doors in series shall swing either in the same direction or away from the space between the doors.] Comment: Issue 49. Section 3106(j)3C was amended to add the following sentence: "Doors in series shall swing either in the same direction, or away from the space between the doors." (See page 604e of the Published Code.) With this addition the provisions are equivalent to the ADAAG. 51-20-3106 (j) 4. Thresholds at Doors. Thresholds at doors shall comply with Section 3106. 51-20-3106 (f) Changes in Level. Accessible routes of travel and accessible spaces within buildings shall have continuous common floor or ramp surfaces. Abrupt change in height greater than 1/4 inch shall be beveled to 1 vertical in 2 horizontal. Changes in level greater than 1/2 inch shall be accomplished by means of a ramp meeting the requirements of 3106 (h) [ a curb ramp meeting the requirements of Section 3106(d)7, or an elevator or platform lift meeting the requirements of Section 3105(d)]. For Type B dwelling units, see also Section 3106(aa). Comment: Issue 50. Section 3106(j)4 was amended to simplify the reference to Section 3106. See page 604e of the Published Code. [N.E. Front approach is not the "most stringent." It is

only different from the requirements for the other approaches.] [Amendment: E.] [Amendment: E.]

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4.15.3 Spout Location. The spouts of drinking fountains and water coolers shall be at the front of the unit and shall direct the water flow in a trajectory that is parallel or nearly parallel to the front of the unit. The spout shall provide a flow of water at least 4 in (100 mm) high so as to allow the insertion of a cup or glass under the flow of water. On an accessible drinking fountain with a round or oval bowl, the spout must be positioned so the flow of water is within 3 in (75 mm) of the front edge of the fountain. 51-20-3106 (m) 3. ...Spouts shall be located in the front of the unit and shall direct a water flow not less than 4 inches in height, in a trajectory parallel to the front of the unit. [Recessed units shall be installed such that the spout is not recessed beyond the plane of the wall.] Comment: Issue 51: There is a typographical error in the side by side analysis and the text in ADAAG and WSR regulations is the same that the spout must be "at" the front of the unit. To clarify the application to round or oval bowls, the Council has issued Interpretation No. 93-34. Interpretation No. 93-34. Question: For water fountains with round or oval bowls, how far

back can the spout be located and still be considered "at the front" of the unit? Answer: The intent of the Code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guideline. On round or oval bowls, the spout must be positioned so the flow of water is within three (3) inches of the front edge of the fountain.

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4.15.5 Clearances.

(1) Wall- and post-mounted cantilevered units shall have a clear knee space between the bottom of the apron and the floor or ground at least 27 in (685 mm) high, 30 in (760 mm) wide, and 17 in to 19 in. (430 mm to 485 mm) deep (see Fig. 27(a) and (b)). Such units shall also have a minimum clear floor space 30 in by 48 in (760 mm by 1220 mm) to allow a person in a wheelchair to approach the unit facing forward. (2) Free-standing or built-in units not having a clear space under them shall have a clear floor space at least 30 in by 48 in (760 mm by 1220 mm) that allows a person in a wheelchair to make a parallel approach to the unit (see Fig. 27(c) and (d)). This clear floor space shall comply with 4.2.4.

51-20-3106 (m) Water Fountains. 1. Clear Floor Space. Walland post-mounted cantilevered units shall have a minimum clear floor space in front of the units 30 inches in width by 48 inches in depth to allow a forward approach. Free-standing or built-in units not having a clear space under them shall have a clear floor space at least 30 inches in depth by 48 inches in width in order to allow a person in a wheelchair to make a parallel approach to the unit. 2. Knee space. Wall- and post-mounted cantilevered units shall have knee space in accordance with Section 3106(b) 2. B. The knee space shall be not less than 19 inches in depth. 51-20-3106 (m) 5. Water Fountains in Alcoves. Where a unit is installed in an alcove greater than 3 inches in depth, the alcove shall be not less than 48 inches in width. A minimum 24 inches of clear space shall be provided from the spout to the nearest side wall of the alcove. [Moved to 3106(m)3.] Comment: Issue 52. This reference in Sec. 3106(m)2 was corrected to a reference to Sec. 3106(b)4C. See page 604k of the Published Code.

[P.E. but 3106(b)4C addresses when knee clearance can be included in clear floor space. 3106(m) is addressing what knee/toe clearance is required at water fountains. The connection is not entirely clear but the specifications are equivalent.]

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4.16.2 Clear Floor Space. Clear floor space for water closets not in stalls shall comply with Fig. 28. Clear floor space may be arranged to allow either a left-handed or right-handed approach. Fig. 28 Clear Floor Space at Water Closets. For a front transfer to the water closet, the minimum clear floor space at the water closet is a minimum 48 inches (1220 mm) in width by a minimum of 66 inches (1675 mm) in length. For a diagonal transfer to the water closet, the minimum clear floor space is a minimum of 48 inches (1220 mm) in width by a minimum of 56 inches (1420 mm) in length. For a side transfer to the water closet, the minimum clear floor space is a minimum of 60 inches (1525 mm) in width by a minimum of 56 inches (1420 mm) in length. (4.16.2, A4.22.3) 51-20-3106 (k) 5.A. Clear Floor Space. The lateral distance from the center line of the water closet to the nearest obstruction [excluding] grab bars, shall be 18 inches on one side and [not less than 42] inches on the other side. In other than stalls, a clear floor space not less than 32 inches measured perpendicular to the wall on which the water closet is mounted, shall be provided in front of the water closet. EXCEPTION: A lavatory may be located within the clear floor space required for a water closet provided that knee and toe clearances for the lavatory comply with subsection 7 below and: A. In Type B dwelling units the edge of the lavatory shall be located not less than 15 inches from the centerline of the water closet; or B. In all other occupancies the edge of the lavatory shall be located not less than 18 inches from the centerline of the water closet. Comment: Issue 53. Section 3106(k)3A provides the dimension requirements for Wheelchair Accessible Toilet Stalls. This section requires such stalls to be at least 60 inches in width. This provision must also be complied with in addition to the clear floor space requirements for the water closet which happens to be in

the toilet stall. Therefore if a lavatory were to be installed in the clear floor space of a water closet in a toilet stall, the toilet stall would not comply with the minimum width of 60 inches. PNE A clarification is needed as to where the lavatory is allowed to be in clear floor area. The ADA does not allow a lavatory in the clear floor area in stalls. [N.E. The stall would still be 60 inches wide, it would just have a lavatory in it. That lavatory will inhibit a side transfer to the water closet, even if there is knee space under it. The problem raised has not been addressed. In addition, 32" in front of the water closet will not make a total of 66" depth of clear space, as required by ADA (it will only be 61-62").]

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4.16.4* Grab Bars. Grab bars for water closets not located in stalls shall comply with 4.26 and Fig. 29. The grab bar behind the water closet shall be 36 in (915 mm) minimum. Fig. 29(a) Back Wall. A 36 inch (915 mm) minimum length grab bar is required behind the water closet mounted at a height between 33 and 36 inches (840-915 mm). The grab bar must extend a minimum of 12 inches (305) beyond the center of the water closet toward the side wall and a minimum of 24 inches (610 mm) toward the open side for either a left or right side approach. Fig. 29(b) Side Wall. A 42 inch (1065 mm) minimum

length grab bar is required to the side of the water closet spaced 12 inches (305 mm) maximum from the back wall and extending a minimum of 54 inches (1370 mm) from the back wall at a height between 33 and 36 inches (840-915 mm). The toilet paper dispenser shall be mounted at a minimum height of 19 inches (485 mm). (4.16.3, 4.16.4, 4.16.6) 4.16.5* Flush Controls. Flush controls shall be hand operated or automatic and shall comply with 4.27.4. Controls for flush valves shall be mounted on the wide side of toilet areas no more than 44 in (1120 mm) above the floor. 4.16.6 Dispensers. Toilet paper dispensers shall be installed within reach, as shown in Fig. 29(b). Dispensers that control delivery, or that do not permit continuous paper flow, shall not be used. Fig. 29(b)...The toilet paper dispenser shall be mounted at a minimum height of 19 inches (485 mm). (4.16.3, 4.16.4, 4.16.6) 51-20-3106 (k) 5. C. Grab Bars. Grab bars shall be installed at one side and the back of the water closet. The top of grab bars shall be not less than 33 inches and not more than 36 inches above and parallel to the floor. Grab bars located at the side shall be a minimum 42 inches in length with the front end positioned not less than 18 inches in front of the water closet. Grab bars located at the back shall be a minimum of 36 inches in length. Grab bars shall be mounted not more than 9 inches behind the water closet seat. See also Section 3106(k)11. 51-20-3106 (k) 5. D. Flush Controls. Flush controls shall be mounted for use from the wide side of the water closet area and not more than 44 inches above the floor. [Flush valves shall comply with Section 3106(c).] 51-20-3106 (k) 5. E. Dispensers and Receptacles. Toilet paper and other dispensers or receptacles shall be installed within easy reach of the water closet, and shall not interfere with [unobstructed floor space] grab bar utilization. Comment: Issue 54. While the WSR standards limit the location of toilet paper dispenser, the actual design of those dispensers is considered to be outside the scope of equipment regulated by the building code. The WSR standards do prohibit placement of dispensers so as to preclude interference with use of the grab bars.

[Amendment: N.E. The requirements for placement of the side grab bar are insufficient. WAC's requirement that the front of the bar be 18" in front of the water closet would make the bar extend only 48" from the back wall, whereas ADA requires it to extend 54" from the back wall. This extra extension is needed by people who need to reach forward to pull to a standing position. Also, WAC does not specify placement of the back grab bar in relation to the side wall. The ADA's placement requirements ensure that a diagonal transfer will be possible if needed.] [Amendment: E.] [E.]

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4.17.6 Grab Bars. Grab bars complying with the length and positioning shown in Fig. 30(a), (b), (c), and (d) shall be provided. Grab bars may be mounted with any desired method as long as they have a gripping surface at the locations shown and do not obstruct the required clear floor area. Grab bars shall comply with 4.26.

4.19.3 Clear Floor Space. A clear floor space 30 in by 48 in (760 mm by 1220 mm) complying with 4.2.4 shall be provided in front of a lavatory to allow forward approach. Such clear floor space shall adjoin or overlap an accessible route and shall extend a maximum of 19 in (485 mm) underneath the lavatory (see Fig. 32). Fig. 32 Clear Floor Space at Lavatories. The minimum depth of the lavatory is 17 inches (430 mm). (4.19.3, 4.24.5) 4.19.5 Faucets. Faucets shall comply with 4.27.4. Lever-operated, push-type, and electronically controlled mechanisms are examples of acceptable designs. If self-closing valves are used the faucet shall remain open for at least 10 seconds. 4.20 Bathtubs. 4.20.1 General. Accessible bathtubs shall comply with 4.20. 51-20-3106 (k) 5. C. Grab Bars. Grab bars shall be installed at one side and the back of the water closet. The top of grab bars shall be not less than 33 inches and not more than 36 inches above and parallel to the floor. Grab bars located at the side shall be a minimum 42 inches in length with the front end positioned not less than 18 inches in front of the water closet. Grab bars located at the back shall be a minimum of 36 inches in length. Grab bars shall be mounted not more than 9 inches behind the water closet seat. See also Section 3106 (k) 11. 51-20-3106 (k) 7. A. Clear Floor Space. A clear floor space not less than 30 inches (in width) by 48 inches (in depth) shall be provided in front of lavatories and sinks. [The clear floor space may include knee and toe clearances not to exceed 19 inches extending under the lavatory or sink.] 51-20-3106(k) 7. E. Faucets. Faucet control handles shall be located not more than 17 inches from the front edge of the lavatory, sink or counter, and shall comply with Section 3105 (c). Self-closing valves shall remain open for at least 10 seconds per operation. 51-20-3106 (c) Controls and Hardware 1. Operation. Handles, pulls, latches, locks and other operating devices on doors,

windows, cabinets, plumbing fixtures and storage facilities shall have a lever or other shape which will permit operation by wrist or arm pressure and does not require tight grasping, pinching or twisting to operate. Doors shall comply with Section 3304. [The force to activate controls on lavatories and water fountains and flush valves on water closets and urinals shall not be greater than 5 pounds.] 51-20-3106 (k) 9. Bathtubs. [Amendment: See above.] [Amendment: E.]

[Amendment: E.] PNE See below.

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4.20.2 Floor Space. Clear floor space in front of bathtubs shall be as shown in Fig. 33. Fig. 33 Clear Floor Space at Bathtubs. (4.20.2, 4.20.3, 4.20.4) Fig. 33(a) With Seat in Tub. If the approach is parallel to the bathtub, a 30 inch (760mm) minimum width by 60 inch (1525 mm) minimum length clear space is required alongside the bathtub. If the approach is perpendicular to the bathtub, a 48 inch (1220

mm) minimum width by 60 inch (1525 mm) minimum length clear space is required. Fig. 33(b) With Seat at Head of Tub. If the approach is parallel to the bathtub, a 30 inch (760 mm) minimum width by 75 inch (1905 mm) minimum length clear space is required alongside the bathtub. The seat width must be 15 inches (380 mm) and must extend the full width of the bathtub. 51-20-3106 (k) 9. A. Clear Floor Space. A clear floor space not less than 60 inches in length shall be provided along the tub. Where the required seat is located at the end of the tub, the clear floor space shall be not less than 75 inches in length. The clear floor space shall be not less than 30 inches in width where access to the space is parallel to the tub and not less than 48 inches in width where access to the space is at right angles to the tub. A lavatory which complies with Subsection 5, above, may be located in the clear floor space of the tub. PNE This appears to be generally equivalent in intent but language must be more precise. As written, the lavatory could be located anywhere within the clear floor area, where as ADAAG only allows a complying lavatory at the end of the tub where the controls are located.

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Comment: Issue 55. Section 3102 defines clear floor space as unobstructed ground or floor space. Section 3106(b)4A requires a minimum clear floor space of 30 by 48 inches. In addition, the Washington regulations provide standards clarifying that which is unobstructed floor space in Section 3106(b)3. This last provision

clarifies that a space can be clear and unobstructed even where fixtures such as counters or lavatories project into the clear floor space at minimum heights above the floor. The provisions in Sections 3106(k)9A and (k)10B which allow lavatory complying with Section 3106(k)7 to be located in the clear floor space of an accessible bathtub or roll-in shower is limited by the provisions of 3106(k)7 and those sections cited in the preceding paragraph. If a lavatory was located in the clear floor space of a tub or shower in such a way to eliminate the unobstructed floor space, the net result would be that the required floor space would not be provided. The combinations of provisions forces the lavatory to the end of the clear floor space. Further if the lavatory was positioned in a manner that obstructed access to the grab bars and/or the controls, one purpose of the clear floor space would again be defeated. Finally, it should be noted again, that the lavatory allowed by the Washington regulations must be an accessible lavatory, one which provided knee and toe clearances. The ADAAG has no such limit on the lavatory, and it could easily obstruct access to grab bars and controls. [N.E. The problem is that WAC allows the lavatory to be at either end of the tub. The ADA requires it to be at the foot end of the tub, because if it were at the head end of the tub, it would obstruct transfer onto the seat.] 89 ADA/Washington State July 12, 1994

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4.20.5 Controls. Faucets and other controls complying with 4.27.4 shall be located as shown in Fig. 34. Fig. 34 Grab Bars at Bathtubs. (4.20.3, 4.20.4, 4.20.5) Fig. 34(a) With Seat in Tub. At the foot of the tub, the grab bar shall be 24 inches (610 mm) minimum in length measured from the outer edge of the tub. On the back wall, two grab bars are required. The grab bars mounted on the back (long) wall shall

be a minimum 24 inches (610 mm) in length located 12 inches (305 mm) maximum from the foot of the tub and 24 inches (610 mm) maximum from the head of the tub. One grab bar shall be located 9 inches (230 mm) above the rim of the tub. The others shall be 33 to 36 inches (840 mm to 910 mm) above the bathroom floor. At the head of the tub, the grab bar shall be a minimum of 12 inches (305 mm) in length measured from the outer edge of the tub. Fig. 34(b) With Seat at Head of Tub. At the foot of the tub, the grab bar shall be a minimum of 24 inches (610 mm) in length measured from the outer edge of the tub. On the back wall, two grab bars are required. The grab bars mounted on the back wall shall be a minimum of 48 inches (1220 mm) in length located a maximum of 12 inches (305 mm) from the foot of the tub and a maximum of 15 inches (380 mm) from the head of the tub. Heights of grab bars are as described above. Figure 34 Grab Bars at Bathtubs. (a) and (b) require controls to be "offset," located in an area between the open edge and the midpoint of the tub. 51-20-3106 (c) Controls and Hardware 1. Operation. Handles, pulls, latches, locks and other operating devices on doors, windows, cabinets, plumbing fixtures and storage facilities shall have a lever or other shape which will permit operation by wrist or arm pressure and does not require tight grasping, pinching or twisting to operate. ...[The force to activate controls on lavatories and water fountains and flush valves on water closets and urinals shall not be greater than 5 pounds.] 51-20-3106 (k) 9. D. Controls and Fixtures. Faucets and other controls shall be located above the tub rim and below the grab bars, shall be not more than 24 inches laterally from the clear floor space and shall comply with Section 3105 (c). Comment: Issue 56. The intent of the WSR provisions was to provide equivalent facilitation to that of the ADA. The allowed distance is within the reach ranges specified in Sec. 4.2 of the ADA. In addition, under the Washington Code, any lavatory installed next to the controls must meet accessibility standards and have knee and toe clearance underneath, these controls will be reachable, whereas under ADAAG which does not require the provision of knee and toe clearance, the controls will not be as accessible as those provided in compliance with the Washington

Code. NE ADA drawing requires controls to be offset between the open edge of the tub and the centerline. [N.E. The 24 inch measurement to the controls is not equivalent. ADA requires the controls to be offset between the midpoint of the tub and the outer edge of the tub, so they can be reached from a wheelchair at the outer edge of the tub. 24 inches is too far into the tub. The midpoint of the tub is likely to be 15-16 inches from the edge.]

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01-03881 4.21.2 Size and Clearances. Except as specified in 9.1.2, shower stall size and clear floor space shall comply with Fig. 35(a) or (b). The shower stall in Fig. 35(a) shall be 36 in by 36 in (915 mm by 915 mm). Shower stalls required by 9.1.2 shall comply with Fig. 57(a) or (b). The shower stall in Fig. 35(b) will fit into the space required for a bathtub. Fig. 35 Shower Size and Clearances. Fig. 35(a) 36 inches by 36 inches (915 mm by 915 mm) Stall (Transfer Shower). The clear floor space shall be a minimum of 48 inches (1220 mm) in length by a minimum of 36 inches (915 mm) in width and allow for a parallel approach. The clear floor space shall extend 1 foot beyond the shower wall on which the seat is mounted. Fig. 35(b) 30 inches by 60 inches (760 mm by 1525 mm) Stall (Roll-in Shower). The clear floor space alongside the shower shall be a minimum of 60 inches (1220 mm) in length by a minimum of 36 inches (915 mm) in width. 51-20-3106 (k) 10. A. Configuration. Shower stalls shall

have one of the following configurations. (i) Transfer shower stalls shall be 36 inches by 36 inches, nominal, and shall have a seat; or, (ii) Roll-in shower stalls shall be not less than 30 inches in depth by 60 inches in length. 51-20-3106 (k) 10 B. Clear Floor Space. A clear floor space not less than 48 inches in length shall be provided adjacent to shower stalls. For roll-in shower stalls, the clear floor space shall be not less than (60) inches in [length]. [A clear floor space shall not be less than 36 inches in width.] A lavatory which complies with Subsection [7] above, may be located in the clear floor space of a roll-in shower.

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4.21.3 Seat. A seat shall be provided in shower stalls 36 in by 36 in (915 mm by 915 mm) and shall be as shown in Fig. 36. The seat shall be mounted 17 in to 19 in (430 mm to 485 mm) from the bathroom floor and shall extend the full depth of the stall. In a 36 in by 36 in (915 mm by 915 mm) shower stall, the seat shall be on the wall opposite the controls. Where a fixed seat is provided in a 30 in by 60 in minimum (760 mm by 1525 mm) shower stall, it shall be a folding type and shall be mounted on the wall adjacent to the controls as shown in Fig. 57. The structural strength of seats and their attachments shall comply with 4.26.3. Fig. 36 Shower Seat Design.

The diagram illustrates an L-shaped shower seat extending the full depth of the stall. The seat shall be located 1-1/2 inches (38 mm) maximum from the wall. The front of the seat (nearest to the opening) shall extend a maximum 16 inches (330 mm) from the wall. The back of the seat (against the back wall shall extend a maximum of 23 inches (582 mm) from the side wall and shall be a maximum of 15 inches (305 mm) deep. Comment: Issue 57. The printing of Section 3106(k) 10B in the side by side analysis is incomplete, thus the analysis is in error. The complete section reads as follows: [see above]. See also comment on Issue No. 55, above. 51-20-3106 (k) 10 C. Seats. In transfer shower stalls, a seat shall be mounted not less than 17 inches and not more than 19 inches above the floor, and shall extend the full depth of the stall. The seat shall be located on the wall opposite the controls and shall be mounted not more than 1-1/2 inches from the shower walls. The seat shall be not more than 16 inches in width. EXCEPTION: A section of the seat not more than 15 inches in length and adjacent to the wall opposite the clear space, may be not more than 23 inches in width. In roll-in shower stalls, a fold down seat complying with the dimensional requirements of this subsection, may be installed. Comment: Issue 58. Clarification of seat and control location in showers as regulated by the WSR in Sec. 3106(k)10 has been clarified by Council Interpretation No. 93-36. [N.E. For transfer shower, the clear floor space must be configured so that it extends 12 inches beyond the seat wall.]

[N.E. WAC does not require that the seat be L-shaped. The seat needs to be L-shaped so that people can sit in the corner and use the two walls for support.]

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01-03883 4.21.5 Controls. Faucets and other controls complying with 4.27.4 shall be located as shown in Fig. 37. In shower stalls 36 in by 36 in (915 mm by 915 mm), all controls, faucets, and the shower unit shall be mounted on the side wall opposite the seat. Fig. 37 Grab Bars at Shower Stalls. Fig. 37(a) 36 inches by 36 inches (915 mm by 915 mm) Stall. The diagram illustrates an L-shaped grab bar that is located along the full depth of the control wall (opposite the seat) and halfway along the back wall. The grab bar shall be mounted between 33 to 36 inches (840-915 mm) above the shower floor. The bottom of the control area shall be a maximum of 38 inches (965 mm) high and the top of the control area shall be a maximum of 48 inches (1220 mm) high. The controls and spray unit shall be within 18 inches (455 mm) of the front of the shower. Fig. 37(b) 30 inches by 60 inches (760 mm by 1525 mm) Stall. The diagram illustrates a U-shaped grab bar that wraps around the stall. The grab bar shall be between 33 to 36 inches (840-915 mm) high. The controls are placed in an area between 38 inches and 48 inches (965 mm and 1220 mm) above the floor. If the controls are located on the back (long) wall they shall be located 27 inches (685 mm) from the side wall. The shower head and control area may be located on either side wall. Interpretation No. 93-36. Question: Can the controls of a shower be located on any wall of the enclosure of an accessible shower? What is the relationship between the controls and the seat installed in a shower? Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guideline. In a transfer shower stall, the seat must be located along a side wall. The controls must be located on the other side wall opposite to the seat. For a roll-in shower stall, the controls must be located on the back, or long, wall opposite the clear floor area and located to one side or the other of the midpoint of the wall. Where a seat is installed in a roll-in shower, it must be located along

the end wall closest to the controls. 51-20-3106 (k) 10 E. Controls and Fixtures. Faucets and other controls shall be located on the same wall as the shower spray unit, and shall be installed not less than 38 inches or more than 48 inches above the shower floor and shall comply with Section 3106(c)... NE Language should be more precise here to ensure that controls are useable. ADAAG is very specific about location of controls when placed on back wall and location of controls adjacent to a fold down seat in a roll-in/transfer shower.

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4.22.6 Lavatories and Mirrors. If lavatories and mirrors are provided, then at least one of each shall comply with 4.19. Comment: Issue 59. Clarification of seat and control location in showers as regulated by the WSR in Sec. 3106(k) 10 has been clarified by Council Interpretation No. 93-36. Interpretation No. 93-36. Question: Can the controls of a shower be located on any wall of the enclosure of an accessible shower? What is the relationship between the controls and the seat installed in a shower? Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guideline. In a transfer shower stall, the seat must be located along a

side wall. The controls must be located on the other side wall opposite to the seat. For a roll-in shower stall, the controls must be located on the back, or long, wall opposite the clear floor area and located to one side or the other of the midpoint of the wall. Where a seat is installed in a roll-in shower, it must be located along the end wall closest to the controls. 51-20-3105 (b) 3. Lavatories, Mirrors and Towel Fixtures. At least one accessible lavatory shall be provided within any toilet facility. Where mirrors, towel fixtures and other toilet and bathroom accessories are provided, at least one of each shall be accessible. 51-20-3106 (k) 7. Lavatories and Sinks. A. Clear Floor Space. A clear floor space not less than 30 inches [in width] by 48 inches [in depth] shall be provided in front of lavatories and sinks [to allow a forward approach. The clear floor space may include knee and toe clearances not to exceed 19 inches extending under the lavatory or sink]. 51-20-3106 (k) 8. Mirrors, Dispensers and Other Fixtures. Mirrors or shelves shall be installed so that the bottom of the mirror or the top of the shelf is within 40 inches of the floor... [N.E. This interpretation does not provide specifications for placement of controls in relation to side wall/front of shower (i.e. 18 in for transfer: 27 in for roll-in.) Merely offsetting them may not put them close enough to the seat. This is a real problem because the accessibility requirements provide only minimum dimensions. If someone were to build a roll-in shower with a back wall 84 inches long and simply offset the controls at 40 inches from the seat wall, the controls would not be reachable from the seat.] [Amendment: E.]

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4.23.4 Water Closets. If toilet stalls are provided, then at least one shall be a standard toilet stall complying with 4.17; where 6 or more stalls are provided, in addition to the stall complying with 4.17.3, at least one stall 36 in (915 mm) wide with an outward swinging, self-closing door and parallel grab bars complying with Fig. 30(d) and 4.26 shall be provided. Water closets in such stalls shall comply with 4.16. If water closets are not in stalls, then at least one shall comply with 4.16. 4.24.5 Clear Floor Space. A clear floor space at least 30 in by 48 in (760 mm by 1220 mm) complying with 4.2.4 shall be provided in front of a sink to allow forward approach. The clear floor space shall be on an accessible route and shall extend a maximum of 19 in (485 mm) underneath the sink (see Fig. 32). 4.26.3 (5) Grab bars shall not rotate within their fittings. 51-20-3105 (b) 2. Toilet Facilities. ...In each toilet facility in other occupancies, at least one wheelchair accessible toilet stall with an accessible water closet shall be provided. In addition, when there are 6 or more water closets within a toilet facility, at least one other accessible toilet stall complying with Section 3106 (k) 4. also shall be installed. 51-20-3106 (k) 3. Wheelchair Accessible Toilet Stalls. A. Dimensions. Wheelchair accessible toilet stalls shall be at least 60 inches in width. Where wall-hung water closets are installed, the depth of the stall shall be not less than 56 inches. Where floor-mounted water closets are installed, the depth of the stall shall be not less than 59 inches. Entry to the compartment shall have a clear width of 32 inches. Toilet stall doors shall not swing into the clear floor space required for any fixture. Except for door swing, a clear unobstructed access not less than 48 inches in width shall be provided to toilet stalls. EXCEPTION: [Moved to B] [Partitions may project not more than one inch, in the aggregate, into the required width of the stall]

51-20-3106 (k) 4. Ambulatory Accessible Toilet Stalls. ambulatory accessible toilet stalls shall be at least 36 inches in width, with an outward swinging, self-closing door. Grab bars shall be installed on each side of the toilet stall and shall comply with Sections 3106 (k) 4. C. and 3106 (k) 9. 51-20-3106 (k) 7. Lavatories and Sinks. A. Clear Floor Space. A clear floor space not less than 30 inches [in width] by 48 inches [in depth] shall be provided in front of lavatories and sinks [to allow a forward approach. The clear floor space may include knee and toe clearances not to exceed 19 inches extending under the lavatory or sink]. Comment: Issue 60. In order for grab bars to meet the loading requirement, rotation in the fittings is not feasible because it is physically impossible for grab bars to rotate and still meet the structural standards in Sec. 3106(k)11. [Amendment: E.] [Amendment: E.] [E.]

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4.27.4 Operation. Controls and operating mechanisms shall be operable with one hand and shall not require tight grasping,

pinching, or twisting of the wrist. The force required to activate controls shall be no greater than 5 lbf (22.2 N). 4.28.2* Audible Alarms. If provided, audible emergency alarms shall produce a sound that exceeds the prevailing equivalent sound level in the room or space by at least 15 dbA or exceeds any maximum sound level with a duration of 60 seconds by 5 dbA, whichever is louder. Sound levels for alarm signals shall not exceed 120 dbA. 51-20-3106 (c) 1. Operation. Handles, pulls, latches, locks and other operating devices on doors, windows, cabinets, plumbing fixtures and storage facilities, shall have a lever or other shape which will permit operation by wrist or arm pressure and does not require tight grasping, pinching or twisting to operate. [The force to activate controls on lavatories and water fountains and flush valves on water closets and urinals shall not be greater than 5 pounds.] 51-20-3106 (o) Alarms. 1. Audible Alarms. Audible alarms shall produce a sound in accordance with [the Fire Code]. Appendix. Chapter 31 Division IV. 51-20-92118 (b) Audible Alarms. Audible alarms shall exceed the prevailing equivalent sound level in the room or space by at least 15 decibels, or shall exceed any maximum sound level with a duration of 30 seconds by 5 decibels, whichever is louder. Sound levels for alarm signals shall not exceed 120 decibels. [Uniform Fire Code, Article 14, S 14.103(b). System Design. Fire alarm systems, automatic fire detectors, emergency voice alarm communication systems and notification devices shall be designed, installed and maintained in accordance with U.F.C. Standards Nos. 14-1 and 14-2 and other nationally recognized standards. U.F.C. Appendix S A-2-8-4. To ensure that audible evacuation signals are clearly heard, it is recommended that their sound level be at least 15 dBA above the equivalent sound level or 5 dBA above the maximum sound level having a duration of at least 60 seconds (whichever is greater) measured 5 ft (1.5 m) above the floor in the occupiable area.] [Amendment: E:]

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Comment: Issue 61. The provision has been amended to read: "Audible alarms shall produce a sound in accordance with the Fire Code." The Uniform Fire Code and the Uniform Fire Code Standards are part of the adoption of the Washington State Building Code. They are not appendix provisions which local jurisdictions have an option to enforce. These regulations are enforced on an equal basis with all other construction codes in the state. The audible standards in the Fire Code are equivalent to the ADA standards. Attached is a copy of the adopting action which was taken concurrently with the original adoption of WAC 51-20. The Fire Code was a referenced document and part of the overall hearing process for these regulations. It should be noted that the Fire Code gives the Fire official authority to regularly inspect buildings and if a system is not meeting a performance standard, the official can require the system to be changed. In this case if the building is occupied by a use which is noisier than anticipated, or ambient sound levels change over time, the fire official can have the sound level of the audible alarms raised to be above the ambient levels. [The sound level provisions are only in an Appendix in the Fire Code. They are merely a "recommendation" and, therefore, unenforceable. However, these are "non-code" items and such omissions are not covered by the certification determination. 28 C.F.R. S 36.607(a)(1).]

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4.28.3* Visual Alarms. Visual alarm signal appliances shall be integrated into the building or facility alarm system. If single station audible alarms are provided then single station visual alarm signals shall be provided. Visual alarm signals shall have the following minimum photometric and location features: (1) The lamp shall be a xenon strobe type or equivalent. (2) The color shall be clear or nominal white (i.e., unfiltered or clear filtered white light). (3) The maximum pulse duration shall be two-tenths of one second (0.2 sec) with a maximum duty cycle of 40 percent. The pulse duration is defined as the time interval between initial and final points of 10 percent of maximum signal. (4) The intensity shall be a minimum of 75 candela. (5) The flash rate shall be a minimum of 1 Hz and a maximum of 3 Hz. (6) The appliance shall be placed 80 in (2030 mm) above the highest floor level within the space or 6 in (152 mm) below the ceiling, whichever is lower. (7) In general, no place in any room or space required to have a

visual signal appliance shall be more than 50 ft (15 m) from the signal (in the horizontal plane). In large rooms and spaces exceeding 100 ft (30 m) across, without obstructions 6 ft (2 m) above the finish floor, such as auditoriums, devices may be placed around the perimeter, spaced a maximum 100 ft (30 m) apart, in lieu of suspending appliances from the ceiling. (8) No place in common corridors or hallways in which visual alarm signalling appliances are required shall be more than 50 ft (15 m) from the signal. 51-20-3106(o) 2. Visible Alarms. Visible alarms shall be located not less than 80 inches above floor level, or 6 inches below the ceiling, whichever is lower, and at an interval of not less than 50 feet horizontal, in rooms, corridors and hallways. In rooms or spaces exceeding 100 feet in horizontal dimension, with no obstructions exceeding 6 feet in height above the finished floor, visible alarms may be placed around the perimeter at intervals not to exceed 100 feet horizontally.

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01-03889 4.28.4* Auxiliary-Alarms. Units and sleeping accommodations shall have a visual alarm connected to the building emergency alarm system or shall have a standard 110-volt electrical receptacle into which such an alarm can be connected and a means by which a signal from the building emergency alarm system can trigger such an auxiliary alarm. When visual alarms are in place the signal shall be visible in all areas of the unit or room. Instructions for use of the auxiliary alarm or receptacle shall be provided. [Visible alarm signals shall comply with the following criteria: [A]. The lamp shall be a xenon strobe type [or equivalent]. [B]. The color shall be clear [or] unfiltered white light.

[C]. The maximum pulse duration shall be two-tenths of one second (0.2 sec) with a maximum duty cycle of 40 percent. The pulse duration is defined as the time interval between initial and final point of 10 percent of maximum signal.] [D]. The intensity shall be a minimum of 75 candela 4[E]. The flash rate shall be a minimum of 1 Hz and a maximum of 3 Hz. Comment: Issue 62. The performance standards for visible alarms have been moved from the appendix to the main body of the code at Section 3106(o) as part of the amendments of November 1992. See page 6041 of the Published Code. 51-20-3105 (d) 9. Alarms. [Where provided] Alarm systems shall include both audible and visible alarms. [Visible] alarm devices shall be located in all [assembly areas;] common-use areas including toilet rooms and bathing facilities[;] hallways, and lobbies [; and hotel guest rooms as required by Section 3103(a)8C. EXCEPTIONS: 1. Alarm systems in Group I, Division 1.1 and 1.2 Occupancies may be modified to suit standard health care design practice 2. Visible alarms are not required in Group R, Division 1 apartment buildings]. [Amendment: E.]

[Amendment: E.]

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4.29.3 Detectable Warnings on Doors To Hazardous Areas. (Reserved). 4.29.5 Detectable Warnings at Hazardous Vehicular Areas. If a walk crosses or adjoins vehicular way, and the walking surfaces are not separated by curbs, railings, or other elements between the pedestrian areas and vehicular areas, the boundary between the areas shall be defined by a continuous detectable warning which is 36 in (915 mm) wide, complying with 4.29.2. 4.29.6 Detectable Warnings at Reflecting Pools. The edges of reflecting pools shall be protected by railings, walls, curbs, or detectable warnings complying with 4.29.2. 51-20-3106 (d) [8]. Vehicular Areas. Where an accessible route of travel crosses or adjoins a vehicular way, and where there are no curbs, railings or other elements [which separate the pedestrian and vehicular areas, and which are] detectable by a person who has severe vision impairment the boundary between the areas shall be defined by a continuous detectable warning not less than 36 inches wide, complying with Section 3106 ( [o]). Comment: Issue 63. The reference has been corrected to 3106(q) in the November 1992 amendments. [Amendment: E.] [Amendment: E.] [Amendment: E. because ADA requirement has been suspended until July 26, 1996.] 100 ADA/Washington State July 12, 1994

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4.30.4* Raised and Brailled Characters and Pictorial Symbol Signs (Pictograms). Letters and numerals shall be raised 1/32 in, upper case, sans serif or simple serif type and shall be accompanied with Grade 2 Braille. Raised characters shall be at least 5/8 in (16 mm) high, but no higher than 2 in (50 mm). Pictograms shall be accompanied by the equivalent verbal description placed directly below the pictogram. The border dimension of the pictogram shall be 6 in (152 mm) minimum in height. 51-20-3106 (p) 5. Raised and Brailled Characters and Pictorial Symbol Signs (Pictograms).

[Characters and symbols on tactile signs shall be raised at least 1/32 inch. Raised characters and symbols shall be upper case characters. Raised characters and symbols shall be between 5/8 inch and 2 inches in height. Raised characters shall be accompanied by Braille in accordance with this section. B. Braille. Braille shall be separated from the corresponding raised characters or symbols. Braille shall be Grade 2. C. Pictograms. Where provided, pictograms shall be accompanied by the equivalent verbal description placed directly below the pictogram. The border dimension of the pictogram shall be not less than 6 inches in height.] [Amendment: N.E. No longer requires simple typeface.]

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4.30.7* Symbols of Accessibility. (1) Facilities and elements required to be identified as accessible by 4.1 shall use the international symbol of accessibility. The symbol shall be displayed as shown in Fig. 43(a) and (b). Fig. 43 International Symbols. Fig. 43(a) Proportions, International Symbol of Accessibility. The diagram illustrates the International Symbol of Accessibility on a grid background. Fig. 43(b) Display Conditions, International Symbol of Accessibility. The symbol contrast shall be light on dark, or dark on light. (2) Volume Control Telephones. Telephones required to have a volume control by 4.1.3(17)(b) shall be identified by a sign containing a depiction of a telephone handset with radiating sound waves. (3) Text Telephones. Text telephones required by 4.1.3(17)(c). shall be identified by the international TDD symbol (Fig 43(c)). In addition, if a facility has a public text telephone, directional signage indicating the location of the nearest text telephone shall be placed adjacent to all banks of telephones which do not contain a text telephone. Such directional signage shall include the international TDD symbol. If a facility has no banks of telephones, the directional signage shall be provided at the entrance (e.g., in a building directory). (4) Assistive Listening Systems. In assembly areas where permanently installed assistive listening systems are required by 4.1.3(19)(b) the availability of such systems shall be identified with signage that includes the international symbol of access for hearing loss (Fig 43(d)). 51-20-3103 (b) 4. Signs. A. International Symbol of Access. 1. International Symbol of Access. A. General. The International Symbol of Access shall be as shown below. (Note: picture of International Access Symbol.)[This is now 3106(p) 1 A]

51-20-3106 (p) 1. B. Text Telephones. Text Telephones required by Section 3105 (d) 2. shall be identified by the International Text Telephone symbol as shown below: (Note International TDD Symbol pictured.) 51-20-3106 (p) 1. C. Assistive Listening Systems. Permanently installed assistive listening systems that are required by Section 3103 (a) 2. B. shall be identified by the International Symbol of Access for Hearing Loss as shown below: (Note: International Symbol of Access for Hearing Loss pictured.) 51-20-3106 (p) 1. D. Volume Control Telephones. Telephones required by Section 3105 (d) 2. to have volume controls shall be identified by a handset with radiating sound waves. Comment: Issue 64. To clarify the application of the WSR, the Council has issued Interpretation No. 93-37.

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01-03893 4.31.3 Mounting Height. The highest operable part of the telephone shall be within the reach ranges specified in 4.2.5 or 4.2.6. 4.31.7 Telephone Books. Telephone books, if provided, shall be located in a position that complies with the reach ranges specified in 4.2.5 and 4.2.6. 4.32.3 Knee Clearances. If seating for people in wheelchairs is provided at tables or counters, knee spaces at least 27 in (685 mm) high 30 in (760 mm) wide, and 19 in (485 mm) deep shall be provided (see Fig. 45). Interpretation No. 93-37. Question: If public telephones are provided in more than one location in a building, or at a building and its site, and Sec. 3105(d)2 requires the provision of a text telephone (TDD), is any signage required to indicate the location of the text

telephone? Answer: Yes. The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guideline. Directional signage indicating the location of the nearest text telephone shall be placed next to all banks of public telephone which do not include a text telephone. If there are no banks of telephones (i.e., only single telephone), this directional signage must be posted at the entrance. 51-20-3106 (n) 2. Height. The highest operable part of a telephone shall be within the reach ranges specified in Sections 3106 (b) 2.D. or 3106 (b) 2.E. Comment: Issue 65. The references in Sec. 3106(n)2 have been changed to Sec. 3106(b)4 in the November 1992 amendments. See page 604k of the Published Code. Comment: Issue 66. Since telephone books are neither building construction or equipment, their location is not included in the Washington State Building Code. 51-20-3106 (s) 2. Knee Clearances. Knee space at tables, counters, and sinks shall be provided in accordance with Section 3106 (b) 2. B. No projection which might obstruct the arm of a wheelchair may intrude into this clearance height, within 24 inches horizontally from the table edge. Comment: Issue 67. The reference has been changed to Sec. 3106(b)4C in the November 1992 amendments. See Section 3106(s)2 on page 604o of the Published Code. [E. as interpreted.]

[Amendment: E.] [Such omissions of non-code items are not covered by the certification determination.] [N.E. WAC fails to require 19 inch minimum depth. (Also, 3106(b)4C addresses when knee clearance can be treated as part of clear space. It doesn't address knee clearance

requirements generally.)]

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4.33.3 Placement of Wheelchair Locations. Wheelchair areas shall be an integral part of any fixed seating plan and shall be provided so as to provide people with physical disabilities a choice of admission prices and lines of sight comparable to those for members of the general public. They shall adjoin an accessible route that also serves as a means of egress in case of emergency. At least one companion fixed seat shall be provided next to each wheelchair seating area. When the seating capacity exceeds 300, wheelchair spaces shall be provided in more than one location. Readily removable seats may be installed in wheelchair spaces when the spaces are not required to accommodate wheelchair users. EXCEPTION: Accessible viewing positions may be clustered for bleachers, balconies, and other areas having sight lines that require slopes of greater than 5 percent. Equivalent accessible viewing positions may be located on levels having accessible egress. 4.33.5 Access to Performing Areas. An accessible route shall connect wheelchair seating locations with performing areas, including stages, arena floors, dressing rooms, locker rooms, and other spaces used by performers. 4.34 Automated Teller Machines. 4.34.1 General. Each automated teller machine required to be accessible by 4.1.3 shall be on an accessible route and shall comply

with 4.34. 4.34.2 Clear Floor Space. The automated teller machine shall be located so that clear floor space complying with 4.2.4 is provided to allow a person using a wheelchair to make a forward approach, a parallel approach or both, to the machine. 51-20-3106 (u) 1. A. Location. Wheelchair spaces shall be an integral part of any fixed seating plan and shall be dispersed throughout the seating area. Spaces shall adjoin an accessible route of travel that also serves as a means of egress and shall be located to provide lines of sight comparable to those for all viewing areas. EXCEPTION: Accessible viewing positions may be clustered for bleachers, balconies, and other areas having sight lines that require slopes of greater than 5 percent. Equivalent accessible viewing positions may be located on levels having accessible egress. Comment: Issue 68. The intent of the WSR provision is for wheelchair spaces to be "an integral part of any fixed seating plan" and has to be adjacent to companion seating in order to be considered integral. Appendix 51-20-93120. See below. Comment: Issue 69. See comment on Issue No. 27, above. Appendix 51-20-93120(c) Clearance and Reach Range. Free standing or built-in units not having a clear floor space under them shall comply with Sections 3106(c)2 and 3, and provide for parallel approach and both a forward and side reach to the unit allowing a person with a wheelchair to access the controls. PNE No specific provision for companion seating adjacent to accessible wheelchair locations. [N.E. It is not clear that "integral" means wheelchair seats must have adjacent companion seats.] [Still no scoping. However, as discussed above, the fact that an item is not addressed in a submitted code means it is not

considered for purposes of certification.]

[E.]

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4.34.3 Reach Ranges. (1) Forward Approach Only. If only a forward approach is possible, operable parts of all controls shall be placed within the forward reach range specified in 4.2.5. (2) Parallel Approach Only. If only a parallel approach is possible, operable parts of controls shall be placed as follows:

(a) Reach Depth Not More Than 10 in (255 mm). Where the reach depth to the operable parts of all controls as measured from the vertical plane perpendicular to the edge of the unobstructed clear floor space at the farthest protrusion of the automated teller machine or surround is not more than 10 in (255 mm), the maximum height above the finished floor or grade shall be 54 in (1370 mm). (b) Reach Depth More Than 10 in (255 mm). Where the reach depth to the operable parts of any control as measured from thevertical plane perpendicular to the edge of the unobstructed clear floor space at the farthest protrusion of the automated teller machine or surround is more than 10 in (255 mm), the maximum height above the finished floor or grade shall be as follows: Reach Depth In Mm 10 255 11 280 12 305 13 330 14 355 15 380 16 405 17 430 18 455 19 485 20 510 21 535 22 560 23 585 24 610 Maximum Height In Mm 54 1370 53 1/2 1360 53 1345 52 1/2 1335 51 1/2 1310 51 1295 50 1/2 1285 50 1270 49 1/2 1255 49 1245 48 1/2 1230 47 1/2 1205 47 1195 46 1/2 1180 46 1170

Appendix 51-20-93120(c) Clearance and Reach Range. Free standing or built-in units not having a clear floor space under them shall comply with Sections 3106(c)2 and 3, and provide for parallel approach and both a forward and side reach to the unit allowing a person with a wheelchair to access the controls. [WAC should adopt the new language.]

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4.34.3 (3) Forward and Parallel Approach. If both a forward and parallel approach are possible, operable parts of controls shall be placed within at least one of the reach ranges in paragraphs (1) or (2) of this section. (4) Bins. Where bins are provided for envelopes, waste paper, or other purposes, at least one of each type provided shall comply with the applicable reach ranges in paragraph (1), (2), or (3) of this section. EXCEPTION: Where a function can be performed in a substantially equivalent manner by using an alternate control, only one of the controls needed to perform that function is required to comply with this section. If the controls are identified by tactile markings, such markings shall be provided on both controls. 4.34.4 Controls. Controls for user activation shall comply with 4.27.4. 4.34.4 5 Equipment for Persons with Vision Impairments. Instructions and all information for use shall be made accessible to and independently usable by persons with vision impairments. 5.3 Access Aisles. All accessible fixed tables shall be accessible by means of an access aisle at least 36 in (915 mm) clear between parallel edges of tables or between a wall and the table edges. Appendix 51-20-93120(b) Controls. Controls for user activation shall comply with Section 3106(c).

Appendix 51-20-93120(d) Equipment for Persons with Vision Impairments. Instructions and all information for use shall be made accessible to and independently usable by persons with vision impairments. 51-20-3106(v) 1. Restaurants and Cafeterias. 1. Aisles. Aisles to fixed tables required to be accessible shall comply with 3106 (s). 51-20-3106 (t) Aisles. All aisles [required to be accessible]. including check out aisles, food service lines and aisles between fixed tables, shall be not less than 36 inches in width. Comment: Issue 70. The reference has been changed to Sec. 3106(t) in the November 1992 amendments. See page 604o of the Published Code (Sec. 3106(v)). [See above.] [See above.] [Amendment: E.]

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5.5 Food Service Lines. Food service lines shall have a minimum clear width of 36 in (915 mm), with a preferred clear width of 42 in (1065 mm) to allow passage around a person using a wheelchair. Tray slides shall be mounted no higher than 34 in (865 mm) above

the floor (see Fig. 53). If self-service shelves are provided, at least 50 percent of each type must be within reach ranges specified in 4.2.5 and 4.2.6. 51-20-3106 (v) 2. Food Service Lines A. Clear Floor Space. Food service lines shall comply with Section 3106 (t) (3106 (t) requires 36 inch aisle width). 51-20-3106 (v) 2. B. Height. Tray slides shall be mounted not more than 34 inches in height above the floor. 51-20-3105 (d) 6. Storage. [Facilities]. In other than Group R, Division 1 apartment buildings, where fixed or built-in storage facilities such as cabinets, shelves, closets and drawers are provided in accessible spaces, at least one of each type provided shall contain storage space complying with Section 3106 (r). Comment: Issue 71. To clarify these provisions the Council has issued Interpretations No. 93-38 and 93-42. Interpretation No. 93-38 Question: How many shelves must be in reach ranges where the code states "Not all self-service shelves and display units need be located within reach ranges required by Sec. 3106(b)4?" In Sec. 3106(v)2D, is the reference to Sec. 3106(s) correct in establishing the location of shelves and dispensing devices for tableware, dishware, food, beverages, and condiments in restaurants and cafeterias? Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent with the ADA Accessibility Guidelines. Where self-service shelves are provided in restaurants and cafeterias, at least 50 percent of each type shall be within the reach ranges of Sec. 3106(b). The proper reference in Section 3106(v)2D is to Sec. 3106(r). NE ADAAG requires 50% of self service shelves in food service lines to be accessible. WSR has no specific provision, only a general provision (see 3105 (d) 6). [N.E. The code says 1 has to be accessible. When an interpretation contradicts the code, the code will be given priority.] [Amendment: The removal of the requirement that self-service shelves be on an accessible route seems to be a problem. The

interpretation helps, but is not sufficient.]

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5.6 Tableware and Condiment Areas. Self-service shelves and dispensing devices for tableware, dishware, condiments, food and beverages shall be installed to comply with 4.2 (see Fig. 54). Fig. 54 Tableware Areas. The maximum height is 54 inches (1370 mm). Interpretation No. 93-42. Question: Self-service shelving and display units in retail occupancies are required to be located on an accessible route. See also wording of 3106(r)2. 1. Does this mean each and every clothing rack at Nordstroms or Target must be on an accessible route or just the area where racks may be installed? 2. The Section is unclear as to how many of the shelves in these self-service areas, must be within the reach ranges. Answer: 1. Access is required between permanent fixtures or furniture which are shown on the plans and to the area where portable racks may be located. 2. Except in restaurant and cafeterias, the number of shelves which are in reach ranges is not limited. Some must be, but there is no set minimum percentage. For restaurants and cafeterias, see interpretation No. 93-38. 51-20-3106 (v) 2. D. Tableware and Condiment Areas. Self-

service shelves and dispensing devices for tableware, dishware, condiments, food and beverages shall be installed to comply with Section 3106 (s). Comment: Issue 72. The intent was to refer to Section 3106(r). To correct this reference the Council has issued Interpretation No. 93-38. Interpretation No. 93-38 Question: How many shelves must be in reach ranges where the code states "Not all self-service shelves and display units need be located within reach ranges required by Sec. 3106(b)4?" In Sec. 3106(v)2D, is the reference to Sec. 3106(s) correct in establishing the location of shelves and dispensing devices for tableware, dishware, food, beverages, and condiments in restaurants and cafeterias? Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent with the ADA Accessibility Guidelines. Where self-service shelves are provided in restaurants and cafeterias, at least 50 percent of each type shall be within the reach ranges of Sec. 3106(b). The proper reference in Section 3106(v)2D is to Sec. 3106(r). PNE Clarification needed. 3106 (s) is not correct section. [N.E. It is not sufficient to correct an error in the code by issuing an interpretation.]

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5.8 Vending Machines and Other Equipment. Spaces for vending machines and other equipment shall comply with 4.2 and shall be located on an accessible route.

6. MEDICAL CARE FACILITIES. 6.1 General. Medical care facilities included in this section are those in which people receive physical or medical treatment or care and where persons may need assistance in responding to an emergency and where the period of stay may exceed twenty-four hours. In addition to the requirements of 4.1 through 4.35, medical care facilities and buildings shall comply with 6. (1) Hospitals - general purpose hospitals, psychiatric facilities, detoxification facilities - At least 10 percent of patient bedrooms and toilets, and all public use and common use areas are required to be designed and constructed to be accessible. (2) Hospitals and rehabilitation facilities that specialize in treating conditions that affect mobility, or units within either that specialize in treating conditions that affect mobility - All patient bedrooms and toilets, and all public use and common use areas are required to be designed and constructed to be accessible. (3) Long term care facilities, nursing homes - At least 50 percent of patient bedrooms and toilets, and all public use and common use areas are required to be designed and constructed to be accessible. Comment: Issue 73. ADAAG does not specifically regulate the vending machines, only the spaces in which they are located. The machines themselves and their location and installation are viewed as beyond the scope of building code regulation. Since the Washington code requires universal accessibility in all spaces regardless of function, and does not allow spaces to be inaccessible, the locations available for vending machine installation are accessible on accessible routes. 51-20-3103 (a) 6. Group I Occupancies. All Group I Occupancies shall be accessible in all public use, common use and employee use areas, and shall have accessible patient rooms, cells and treatment or examination rooms as follows: 51-20-3103(a) 6. A. In Group I Division 1.1 hospitals which specialize in treating conditions that affect mobility, all patient rooms in each nursing unit, including associated toilet rooms and bathrooms.

51-20-3103 (a) 6. B. In Group I, Division 1.1 hospitals which do not specialize in treating conditions that affect mobility, at least 1 in every 10 patient rooms in each nursing unit, including associated toilet rooms and bathrooms. 51-20-3103 (a) 6. C. In Group I, Division 1.1 and Division 2 nursing homes and long-term care facilities, at least 1 in every 2 patient rooms, including associated toilet rooms and bathrooms. 51-20-3103 (a) 6. D. In Group I, Division 3, mental health Occupancies, at least 1 in every 10 patient rooms, including associated toilet rooms and bathrooms. Comment: Issue 74. Section 3103(a)6 has been amended to add a new Section F which reads: "In Group I Occupancies, all treatment and examination rooms shall be accessible." See page 600 of the Published Code.

[Amendment: E.]

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7.4 Security Bollards. Any device used to prevent the removal of shopping carts from store premises shall not prevent access or egress to people in wheelchairs. An alternate entry that is equally convenient to that provided for the ambulatory population is acceptable. 8.5 Stacks. Minimum clear aisle width between stacks shall comply with 4.3, with a minimum clear aisle width of 42 in (1065

mm) preferred where possible. Shelf height in stack areas is unrestricted (see Fig. 56). Comment: Issue 75. The Washington State Regulations did not include specific regulation of security bollards because it was believed that special attention was not necessary. Such bollards are simply one item which could interfere with an accessible route or accessible route of egress and would be prohibited. See 51-20-3106 (x) 3. Above. Comment: Issue 76. Section 3106(y)3 was amended in November 1992 to delete the word "reference" so that the accessible aisle requirements apply to all stacks. See page 604q of the Published Code. [E.] [E.] 111 ADA/Washington State July 12, 1994

01-03902

9.1 Hotels, Motels, Inns, Boarding Houses, Dormitories, Resorts and Other Similar Places of Transient Lodging. 9.1.1 General. All public use and common use areas are required to be designed and constructed to comply with section 4 (Accessible Elements and Spaces: Scope and Technical Requirements). EXCEPTION: Sections 9.1 through 9.4 do not apply to an establishment located within a building that contains not more than five rooms for rent or hire and that is actually occupied by the proprietor of such establishment as the residence of such proprietor.

51-20-3103(a) 8. Group R. Occupancies. A. General. All Group R Occupancies shall be accessible as provided in this chapter. Public-and common use areas and facilities such as recreational facilities, laundry facilities, garbage and recycling collection areas, mailbox locations, lobbies, foyers and management offices, shall be accessible. [EXCEPTION: Common- or public-use facilities accessory to buildings not required to contain either Type A or Type B dwelling units in accordance with Section 3103(a)8B.] B. Number of Dwelling Units. In all Group R, Division 1 apartment buildings the total number of Type A dwelling units shall be as required by Table No. 31-B. All other dwelling units shall be designed and constructed to the requirements for Type B units as defined in this chapter. EXCEPTIONS: 1. Group R Occupancies containing [no more than] three dwelling units.... 51-20-3103 (a)8.C. Hotels and Lodging Houses. In all hotels and lodging houses, accessible guest rooms, including associated bathing, shower and toilet facilities, shall be provided in accordance with Table No. 31-C.... ....In addition public-use and common-use areas of all hotels and lodging houses shall be accessible. EXCEPTION: Group R, Division 3 lodging houses that are occupied by the owner or proprietor of the lodging house. 51-20-3103 (a) 8. E. Congregate Residences. In congregate residences with multi-bed rooms or spaces, a percentage equal to the minimum number of accessible rooms required by Table No. 31-C shall be accessible in accordance with Section 3106 (z). EXCEPTION: Congregate residences with 10 or fewer occupants need not be accessible. Comment: Issue 77. Congregate residences as intended by the UBC definition have non transient residents. The exemption in WSR has no effect on equivalency with the ADA. See also Council Interpretation No. 93-39. 112 01-03903 Interpretation 93-39: ADA/Washington State July 12, 1994

Question: For purposes of accessibility requirements of Chapter 31, how should buildings such as homeless shelters, halfway houses, transient group homes, and similar social service establishments where people may sleep or temporarily reside be classified? Similarly, how should apartments or condominium complexes be classified where some or all of the units are rented to short term quests. Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent with the ADA Accessibility Guidelines. For the purpose of determining accessibility requirements per Chapter 31, uses such as homeless shelters, halfway houses, transient group homes, and similar facilities should be reviewed on a case be case basis. While these uses are "residential" in nature, if the residents are considered transient, classification as R-1 hotel, or R-3 lodging house is more appropriate. Some may need to be classified either in an I (Institutional) or B (Business) category. If services are provided at the site such as job or health counseling, classification should be in a category which requires accessibility. These uses should not be categorized as congregate residence when the residents are essentially transient. Apartments or condominiums which are rented on a short term basis to transient guests should be categorized as either a Group R-1, hotel, or Group R-3 lodging house with appropriate accessibility provided. 113 01-03904 9.1.2 Accessible Units, Sleeping Rooms, and Suites. Accessible sleeping rooms or suites that comply with the requirements of 9.2 (Requirements for Accessible Units, Sleeping Rooms, and Suites) shall be provided in conformance with the table below. In addition, in hotels, of 50 or more sleeping rooms or suites, additional accessible sleeping rooms or suites that include a roll-in shower shall also be provided in conformance with the table below. Such accommodations shall comply with the requirements of 9.2, 4.21, and Figure 57(a) or (b). Fig. 57 Roll-in Shower with Folding Seat. ADA/Washington State July 12, 1994

Diagram (a): Where a fixed seat is provided in a 30 inch minimum by 60 inch (716 mm by 1220 mm) minimum shower stall, the controls and spray unit on the back (long) wall shall be located a maximum of 27 inches (685 mm) from the side wall where the seat is attached. (4.21.2, 9.1.2) Diagram (b): An alternate 36 inch minimum by 60 inch (915 mm by 1220 mm) minimum shower stall is illustrated. The width of the stall opening stall shall be a minimum of 36 inches (915 mm) clear located on a long wall at the opposite end of the shower from the controls. The shower seat shall be 24 inches (610 mm) minimum in length by 16 inches (330 mm) minimum in width and may be rectangular in shape. The seat shall be located next to the opening to the shower and adjacent to the end wall containing the shower head and controls. (4.21.2, 9.1.2, A4.23.3) Number of Rooms Accessible Rooms Showers 1 to 25 26 to 50 51 to 75 76 to 100 101 to 150 151 to 200 201 to 300 301 to 400 401 to 500 1 1 2 2 3 4 4, plus one for each additional 100 over 400 501 to 1000 2% of total 1001 and over 20 plus 1 for each 100 over 1000 51-20-3103 (a) 8:C. Hotels and Lodging Houses. In all hotels and lodging houses, accessible guest rooms, including associated bathing, shower and toilet facilities, shall be provided in accordance with Table No. 31-C... ...In addition public-use and common-use areas of all hotels and lodging houses shall be accessible. EXCEPTION: Group R, Division 3 lodging houses that are occupied by the owner or proprietor of the lodging house. Table No. 31-C-Number of 1 2 3 4 5 6 7 8 9 Rooms with Roll-in

Accessible Rooms and Roll-in Showers Total Number Minimum Required Rooms With of Rooms1 Accessible Rooms1 Roll-in Showers 1 to 25 1 26 to 50 2 51 to 75 3 1 76 to 100 4 1 101 to 150 5 2 151 to 200 6 2 201 to 300 7 3 301 to 400 8 4 401 to 500 9 4, plus 1 for every 100 rooms or fraction thereof, over 400. 501 to 1000 2% of total Over 1000 20 plus 1 for every 100 rooms or fraction thereof, over 1000 1 For congregate residences the numbers in these columns shall apply to beds rather than rooms. 114 01-03905 9.2 Requirements for Accessible Units, Sleeping Rooms and Suites. 9.2.1 General. Units, sleeping rooms, and suites required to be accessible by 9.1 shall comply with 9.2. Comment: Issue 78. The Council has issued Interpretation No. 93-40 to clarify the requirements for the three accessible rooms standards. Interpretation No. 93-40. Question: The code seems to require three different types of accessible rooms: an accessible room with roll-in type showers: an accessible room with another type of bathing facility; and rooms with features to assist persons with hearing impairments. Must the three categories be satisfied independently, or can the various requirements be combined in the same room? ADA/Washington State July 12, 1994

Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent with the ADA Accessibility Guidelines. Each requirement for the three categories of rooms must be complied with independently of the other requirements. For example, in a 100 guest room motel, four (4) rooms must be wheelchair accessible, one (1) more room must be wheelchair accessible and provide a roll-in shower, and four (4) more rooms must provide equipment for persons with hearing impairments. In addition, the five wheelchair accessible rooms must also provide the equipment for persons with hearing impairments. 51-20-3106 (z) [H]otels and Congregate Residences. See below. Comment: Issue 79. The DOJ analysis contains a typographical error in translating the provisions of WSR Section 3106(z), the correct title is "Hotels and Congregate Residences." See the comment on to Issue No. 19, above. [E.] [E.] 115 01-03906 9.2.2(6) Where provided as part of an accessible unit, sleeping room, or suite, the following spaces shall be accessible and shall be on an accessible route: (a) the living area. (b) the dining area. (c) at least one sleeping area. (d) patios, terraces, or balconies. EXCEPTION: The requirements of 4.13.8 and 4.3.8 do not apply where it is necessary to utilize a higher door threshold or a change in level to protect the integrity of the unit from wind/water damage. Where this exception results in patios, terraces or balconies that are not at an accessible level, equivalent facilitation shall be provided. (e.g., Equivalent facilitation at a hotel patio or balcony might consist of providing raised decking or a ramp to provide accessibility). (e) at least one full bathroom (i.e., one with a water closet, ADA/Washington State July 12, 1994

a lavatory, and a bathtub or shower). (f) if only half baths are provided, at least one half bath. (g) carports, garages or parking spaces. 51-20-3103 (a) 8. C. Hotels and Lodging Houses. In all hotels and lodging houses, accessible guest rooms, including associated bathing, shower and toilet facilities, shall be provided in accordance with Table No. 31-C. Where provided in accessible guest rooms the following facilities shall be accessible: dining areas; kitchens; kitchenettes, wet bars; patios; balconies; terraces; or similar facilities. EXCEPTION: Kitchens in Type B dwelling units need not comply with Section 3106 (1) 1. 51-20-3106 (z) 2. Accessible Route of Travel. An accessible route complying with Section 3103 (b) 2. shall connect all accessible spaces and elements including telephones, patios, terraces, balconies, carports, garages or parking spaces with all accessible sleeping rooms. Comment: Issue 80. See the comment on Issue No. 19, above. Also, Section 3103(a)BA requires all public and common use areas of a Group R occupancy to be accessible. The definition of hotel contained in Section 409 of the UBC should also be noted. PNE Although carports, parking garages, or parking spaces must be connected by an accessible route to the unit, it doesn't specifically state they must be accessible. Interpretation needed. [E.] 116 01-03907 9.2.2(8) Sleeping room accommodations for persons with hearing impairments required by 9.1 and complying with 9.3 shall be provided in the accessible sleeping room or suite. 9.4 Other Sleeping Rooms and Suites. Doors and doorways designed to allow passage into and within all sleeping units or other ADA/Washington State July 12, 1994

covered units shall comply with 4.13.5. Comment: Issue 81. Section 3107 states the parking requirement. If the parking is provided in garages or carports (a B-1 or B-3 or M-1 occupancy) then that occupancy must also be accessible per section 3103(a). Like ADAAG, the WSR do not require parking to be provided, but where provided, it must be accessible according to Section 3107. Sec. 3107(a)6 states that accessible parking must be the closest to the accessible entrance and where there are multiple accessible entrances, the accessible parking must be distributed at the various entrances. As a result, if a hotel design includes parking located at individual units, those units which are required to be accessible will have to have accessible entrances and the parking nearest those entrances will need to be the location of accessible parking. Comment: Issue 82. See comment on Issue No. 78, above. 51-20-3106 (z) 3. Doors. Doors within all sleeping rooms, suites or other covered units shall comply with Section 3106 (j). Comment: Issue 83. The intent of the WSR regulations is to apply to all the doors of the guest rooms - including entry to the room - not just those "within" the room. To clarify the application of the WSR the Council has issued Interpretation No. 93-41. Interpretation No. 93-41. Question: What doors are covered by this requirement [Section 51-20-3106(z)3]? Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent to the ADA Accessibility Guideline. All doors which enter a guest room from common corridors or spaces and doors within the guest room providing access to other rooms in the guest room unit, or to adjacent units, must meet the standards for accessible doors. This requirement applies to all of the guest rooms in a hotel, not just those which must meet other accessibility standards. [N.E. S3103(a)7 requires accessibility of M-1 occupancies only if they are "private garages and carports which contain accessible parking serving Type A dwelling units." Accessible hotel rooms are not Type A dwelling units. The ADA would

require a carport that was designated for an accessible hotel room to be accessible. WAC would not.] [E.] [E.] 117 01-03908 9.5 Transient Lodging in Homeless Shelters, Halfway Houses, Transient Group Homes, and Other Social Service Establishments. 9.5.1 New Construction. In new construction all public use and common use areas are required to be designed and constructed to comply with section 4. At least one of each type of amenity (such as washers, dryers and similar equipment installed for the use of occupants) in each common area shall be accessible and shall be located on an accessible route to any accessible unit or sleeping accommodation. EXCEPTION: Where elevators are not provided as allowed in 4.1.3(5), accessible amenities are not required on inaccessible floors as long as one of each type is provided in common areas on accessible floors. 51-20-3108 (a) 8. Group Occupancies. A. General. All Group R Occupancies shall be accessible as provided in this chapter. Public- and common-use areas and facilities such as recreational facilities, laundry facilities, garbage and recycling collection areas, mailbox locations, lobbies, foyers and management offices, shall be accessible. 51-20-3103 (a) 8. E. Congregate Residences. In congregate residences with multi-bed rooms or spaces, a percentage equal to the minimum number of accessible rooms required by Table No. 31-C shall be accessible in accordance with Section 3106 (z). EXCEPTION: Congregate residences with 10 or fewer occupants need not be accessible. 118 01-03909 9.5.2 Alterations. ADA/Washington State July 12, 1994 ADA/Washington State July 12, 1994

(1) Social service establishments which are not homeless shelters: (a) The provisions of 9.5.3 and 9.1.5 shall apply to sleeping rooms and beds. (b) Alteration of other areas shall be consistent with the new construction provisions of 9.5.1. (2) Homeless shelters. If the following elements are altered, the following requirements apply: (a) at least one public entrance shall allow a person with mobility impairments to approach, enter and exit including a minimum clear door width of 32 in (815 mm). (b) sleeping space for homeless persons as provided in the scoping provisions of 9.1.2 shall include doors to the sleeping area with a minimum clear width of 32 in (815 mm) and maneuvering space around the beds for persons with mobility impairments complying with 9.2.2(1). (c) at least one toilet room for each gender or one unisex toilet room shall have a minimum clear door width of 32 in (815 mm), minimum turning space complying with 4.2.3, one water closet complying with 4.16, one lavatory complying with 4.19 and the door shall have a privacy latch; and, if provided, at least one tub or shower shall comply with 4.20 or 4.21, respectively. (d) at least one common area which a person with mobility impairments can approach, enter and exit including a minimum clear door width of 32 in (815 mm). (e) at least one route connecting elements (a), (b), (c) and (d) which a person with mobility impairments can use including minimum clear width of 36 in (915 mm), passing space complying with 4.3.4, turning space complying with 4.2.3 and changes in levels complying with 4.3.8. (f) homeless shelters can comply with the provisions of (a)-(e) by providing the above elements on one accessible floor. See comments above. 119 01-03910 ADA/Washington State July 12, 1994

Comment: Issue 84. See comment on Issue No. 19, above. Interpretation 93-39: Question: For purposes of accessibility requirements of Chapter 31, how should buildings such as homeless shelters, halfway houses, transient group homes, and similar social service establishments where people may sleep or temporarily reside be classified? Similarly, how should apartments or condominium complexes be classified where some or all of the units are rented to short term guests. Answer: The intent of the code, as provided in Sec. 3101(a), is to provide standards equivalent with the ADA Accessibility Guidelines. For the purpose of determining accessibility requirements per Chapter 31, uses such as homeless shelters, halfway houses, transient group homes, and similar facilities should be reviewed on a case be case basis. While these uses are "residential" in nature, if the residents are considered transient, classification as R-1 hotel, or R-3 lodging house is more appropriate. Some may need to be classified either in an I (Institutional) or B (Business) category. If services are provided at the site such as job or health counseling, classification should be in a category which requires accessibility. These uses should not be categorized as congregate residence when the residents are essentially transient. Apartments or condominiums which are rented on a short term basis to transient guests should be categorized as either a Group R-1, hotel, or Group R-3 lodging house with appropriate accessibility provided. [E.] 120 01-03911 9.5.3. Accessible Sleeping Accommodations in New Construction. Accessible sleeping rooms shall be provided in conformance with the table in 9.1.2 and shall comply with 9.2 Accessible Units, Sleeping Rooms and Suites (where the items are provided). Additional sleeping rooms that comply with 9.3 Sleeping Accommodations for Persons with Hearing Impairments shall be ADA/Washington State July 12, 1994

provided in conformance with the table provided in 9.1.3. In facilities with multi-bed rooms or spaces, a percentage of the beds equal to the table provided in 9.1.2 shall comply with 9.2.2(1). 10. TRANSPORTATION FACILITIES. 10.1 General. Every station, bus stop, bus stop pad, terminal, building or other transportation facility, shall comply with the applicable provisions of 4.1 through 4.35, sections 5 through 9, and the applicable provisions of this section. The exceptions for elevators in 4.1.3(5) exception 1 and 4.1.6(1)(k) do not apply to a terminal, depot, or other station used for specified public transportation, or an airport passenger terminal, or facilities subject to Title II. 51-20-3103 (a) 8. C. Hotels and Lodging Houses. In all hotels and lodging houses, accessible guest rooms, including associated bathing, shower and toilet facilities, shall be provided in accordance with Table No. 31-C. In addition, sleeping rooms or suites for persons with hearing impairments shall be provided in accordance with Table No. 31-D. In addition, public-use and common-use areas of all hotels and lodging houses shall be accessible. 51-20-3103 (a) 8. E. Congregate Residences. In congregate residences with multi-bed rooms or spaces, a percentage equal to the minimum number of accessible rooms required by Table No. 31-C shall be accessible in accordance with Section 3106 (z). EXCEPTION: Congregate residences with 10 or fewer occupants need not be accessible. [E. See Interpretation 93-39.] [Washington does not address transportation facilities separately.] 121 01-03912 10.2 Bus Stops and Terminals. ADA/Washington State July 12, 1994

10.2.1 New Construction. (1) Where new bus stop pads are constructed at bus stops, bays or other areas where a lift or ramp is to be deployed, they shall have a firm, stable surface; a minimum clear length of 96 inches (measured from the curb or vehicle roadway edge) and a minimum clear width of 60 inches (measured parallel to the vehicle roadway) to the maximum extent allowed by legal or site constraints; and shall be connected to streets, sidewalks or pedestrian paths by an accessible route complying with 4.3 and 4.4. The slope of the pad parallel to the roadway shall, to the extent practicable, be the same as the roadway. For water drainage, a maximum slope of 1:50 (2%) perpendicular to the roadway is allowed. (2) Where provided, new or replaced bus shelters shall be installed or positioned so as to permit a wheelchair or mobility aid user to enter from the public way and to reach a location, having a minimum clear floor area of 30 inches by 48 inches, entirely within the perimeter of the shelter. Such shelters shall be connected by an accessible route to the boarding area provided under paragraph (1) of this section. (3) Where provided, all new bus route identification signs shall comply with 4.30.5. In addition, to the maximum extent practicable, all new bus route identification signs shall comply with 4.30.2 and 4.30.3. Signs that are sized to the maximum dimensions permitted under legitimate local, state or federal regulations or ordinances shall be considered in compliance with 4.30.2 and 4.30.3 for purposes of this section. EXCEPTION: Bus schedules, timetables, or maps that are posted at the bus stop or bus bay are not required to comply with this provision. (Not addressed.) 122 01-03913 ADA/Washington State July 12, 1994

10.2.2 Bus Stop Siting and Alterations. (1) Bus stop sites shall be chosen such that, to the maximum extent practicable, the areas where lifts or ramps are to be deployed comply with section 10.2.1(1) and (2).

(2) When new bus route identification signs are installed or old signs are replaced, they shall comply with the requirements of 10.2.1(3). (Not addressed.) 123 01-03914 ADA/Washington State July 12, 1994

10.3 Fixed Facilities and Stations. 10.3.1 New Construction. New stations in rapid rail, light rail, commuter rail, intercity bus, intercity rail, high speed rail, and other fixed guideway systems (e.g., automated guideway transit, monorails, etc.) shall comply with the following provisions, as applicable. (1) Elements such as ramps, elevators or other circulation devices, fare vending or other ticketing areas, and fare collection areas shall be placed to minimize the distance which wheelchair users and other persons who cannot negotiate steps may have to travel compared to the general public. The circulation path, including an accessible entrance and an accessible route, for persons with the circulation path for the general public. Where the circulation path is different, signage complying with 4.30.1, 4.30.2, 4.30.3, 4.30.5, and 4.30.7(1) shall be provided to indicate direction to and identify the accessible entrance and accessible route. (2) In lieu of compliance with 4.1.3(8), at least one entrance to each station shall comply with 4.14, Entrances. If different entrances to a station serve different transportation fixed routes or groups of fixed routes, at least one entrance serving each group or route shall comply with 4.14, Entrances. All accessible entrance shall, to the maximum extent practicable, coincide with those used by the majority of the general public. (3) Direct connections to commercial, retail, or residential facilities shall have an accessible route complying with 4.3 from the point of connection to boarding platforms and all transportation system elements used by the public. Any elements provided to facilitate future direct connections shall be on an accessible route connecting boarding platforms and all transportation system elements used by the public. (4) Where signs are provided at entrances to stations identifying

the station or the entrance, or both, at least one sign at each entrance shall comply with 4.30.4 and 4.30.6. Such signs shall be placed in uniform locations at entrances within the transit to the maximum extent practicable. EXCEPTION: Where the station has no defined entrance, but signage is provided, then the accessible signage shall be placed in a central location. 51-20-3101 (a) General. Buildings or portions of buildings shall be accessible to persons with disabilities as required by this chapter. 51-20-3101 (a) 1. General. Accessibility to temporary or permanent buildings or portions thereof shall be provided for all occupancy classifications except as modified by this chapter. (P.E. to the extent transportation stations are buildings. WAC does not address minimizing distance. WAC does not address accessible entrances for different fixed routes. WAC does not address accessible direct connections.) 124 01-03915 ADA/Washington State July 12, 1994

(5) Stations covered by this section shall have identification signs complying with 4.30.1, 4.30.2, 4.30.3, and 4.30.5. Signs shall be placed at frequent intervals and shall be clearly visible from within the vehicle on both sides when not obstructed by another train. When station identification signs are placed close to vehicle windows (i.e., on the side opposite from boarding) each shall have the top of the highest letter or symbol below the top of the vehicle window and the bottom of the lowest letter or symbol above the horizontal mid-line of the vehicle window. (6) Lists of stations, routes, or destinations served by the station and located on boarding areas, platforms, or mezzanines shall comply with 4.30.1, 4.30.2, 4.30.3, and 4.30.5. A minimum of one sign identifying the specific station and complying with 4.30.4 and 4.30.6 shall be provided on each platform or boarding area. All signs referenced in this paragraph shall, to the maximum extent practicable, be placed in uniform locations within the transit system.

(7)* Automatic fare vending, collection and adjustment (e.g., addfare) systems shall comply with 4.34.2, 4.34.3, 4.34.4, and 4.34.5. At each accessible entrance such devices shall be located on an accessible route. If self-service fare collection devices are provided for the use of the general public, at least one accessible device for entering, and at least one for exiting, unless one device serves both functions, shall be provided at each accessible point of entry or exit. Accessible fare collection devices shall have a minimum clear opening width of 32 inches; shall permit passage of a wheelchair; and, where provided, coin or card slots and controls necessary for operation shall comply with 4.27. Gates which must be pushed open by wheelchair or mobility aid users shall have a smooth continuous surface extending from 2 inches above the floor to 27 inches above the floor and shall comply with 4.13. Where the circulation path does not coincide with that used by the general public, accessible fare collection systems shall be located at or adjacent to the accessible point of entry or exit. (8) Platform edges bordering a drop-off and not protected by platform screens or guard rails shall have a detectable warning. Such detectable warnings shall comply with 4.29.2 and shall be 24 inches wide running the full length of the platform drop-off. 125 01-03916 ADA/Washington State July 12, 1994

(9) In stations covered by this section, rail-to-platform height in new stations shall be coordinated with the floor height of new vehicles so that the vertical difference, measured when the vehicle is at rest, is within plus or minus 5/8 inch under normal passenger load conditions. For rapid rail, light rail, commuter rail, high speed rail, and intercity rail systems in new stations, the horizontal gap, measured when the new vehicle is at rest, shall be no greater than 3 inches. For slow moving automated guideway "people mover" transit systems, the horizontal gap in new stations shall be no greater than 1 inch. EXCEPTION 1: Existing vehicles operating in new stations may have a vertical difference with respect to the new platform within plus or minus 1-1/2 inches. EXCEPTION 2: In light rail, commuter rail and intercity rail systems where it is not operationally or structurally feasible to meet the horizontal gap or vertical difference requirements, mini-high platforms, car-borne or platform-mounted lifts, ramps or bridge

plates, or similar manually deployed devices, meeting the applicable requirements of 36 C.F.R. part 1192, or 49 C.F.R. part 38 shall suffice. (10) Stations shall not be designed or constructed so as to require persons with disabilities to board or alight from a vehicle at a location other than one used by the general public. (11) Illumination levels in the areas where signage is located shall be uniform and shall minimize glare on signs. Lighting along circulation routes shall be of a type and configuration to provide uniform illumination. [Not addressed.] 126 01-03917 ADA/Washington State July 12, 1994

(12) Text Telephones: The following shall be provided in accordance with 4.31.9: (a) If an interior public pay telephone is provided in a transit facility (as defined by the Department of Transportation) at least one interior public text telephone shall be provided in the station. (b) Where four or more public pay telephones serve a particular entrance to a rail station and at least one is in an interior location, at least one interior public text telephone shall be provided to serve that entrance. Compliance with this section constitutes compliance with section 4.1.3(17)(c). (13) Where it is necessary to cross tracks to reach boarding platforms, the route surface shall be level and flush with the rail top at the outer edge and between rails, except for a maximum 2-1/2 inch gap on the inner edge of each rail to permit passage of wheel flanges. Such crossings shall comply with 4.29.5. Where gap reduction is not practicable, an above-grade or below-grade accessible route shall be provided. (14) Where public address systems are provided to convey information to the public in terminals, stations, or other fixed facilities, a means of conveying the same or equivalent information to persons with hearing loss or who are deaf shall be provided. (15) Where clocks are provided for use by the general public, the clock face shall be uncluttered so that its elements are clearly

visible. Hands, numerals, and/or digits shall contrast with the background either light-on-dark or dark-on-light. Where clocks are mounted overhead, numerals and/or digits shall comply with 4.30.3. Clocks shall be placed in uniform locations throughout the facility and system to the maximum extent practicable. (16) Where provided in below grade stations, escalators shall have a minimum clear width of 32 inches. At the top and bottom of each escalator run, at least two contiguous treads shall be level beyond the comb plate before the risers begin to form. All escalator treads shall be marked by a strip of clearly contrasting color, 2 inches in width, placed parallel to and on the nose of each step. The strip shall be of a material that is at least as slip resistant as the remainder of the tread. The edge of the tread shall be apparent from both ascending and descending directions. 51-20-3105 (d) 2. Telephones. ...Where four or more public telephones are provided at a building site, and at least one is in an interior location, at least one interior telephone shall be a text telephone in accordance with Section 3106 (n). Where interior public pay phones are provided in transportation facilities ... at least one interior text telephone shall be provided. [E.] [Not addressed.] [Not addressed.] [Not addressed.] [Not addressed.] 127 01-03918 ADA/Washington State July 12, 1994

(17) Where provided, elevators shall be glazed or have transparent panels to allow an unobstructed view both in to and out of the car. Elevators shall comply with 4.10. EXCEPTION: Elevator cars with a clear floor area in which a 60 inch diameter circle can be inscribed may be substituted for the minimum car dimensions of 4.10, Fig. 22.

(18) Where provided, ticketing areas shall permit persons with disabilities to obtain a ticket and check baggage and shall comply with 7.2. (19) Where provided, baggage check-in and retrieval systems shall be on an accessible route complying with 4.3, and shall have space immediately adjacent complying with 4.2. If unattended security barriers are provided, at least one gate shall comply with 4.13. Gates which must be pushed open by wheelchair or mobility aid users shall have a smooth continuous surface extending from 2 inches above the floor to 27 inches above the floor. 10.3.2 Existing Facilities: Key Stations. Not reproduced because key stations are covered by title II of the ADA only and, therefore, section 10.3.2 is inapplicable to title III entities. 10.3.3 Existing Facilities: Alterations. (1) For the purpose of complying with 4.1.6(2) Alterations to an Area Containing a Primary Function, an area of primary function shall be as defined by applicable provisions of 49 C.F.R. 37.43(c) (Department of Transportation's ADA Rule) or 28 C.F.R. 36.403 (Department of Justice's ADA Rule). 51-20-3105 (d) 7. C. Counters and Windows. Where customer sales and service counters or windows are provided, a portion of the counter, or at least one window, shall be accessible in accordance with Section 3106 (x) 2. [Not addressed.] [P.E.] [Not addressed.] [See above discussion of path of travel at Standard 4.1.6 (2).] 128 01-03919 10.4 Airports. 10.4.1 New Construction. ADA/Washington State July 12, 1994

(1) Elements such as ramps, elevators or other vertical circulation devices, ticketing areas, security checkpoints, or passenger waiting areas shall be placed to minimize the distance which wheelchair users and other persons who cannot negotiate steps may have to travel compared to the general public. (2) The circulation path, including an accessible entrance and an accessible route, for persons with disabilities shall, to the maximum extent practicable, coincide with the circulation path for the general public. Where the circulation path is different, directional signage complying with 4.30.1, 4.30.2, 4.30.3 and 4.30.5 shall be provided which indicates the location of the nearest accessible entrance and its accessible route. (3) Ticketing areas shall permit persons with disabilities to obtain a ticket and check baggage and shall comply with 7.2. (4) Where public pay telephones are provided, and at least one is at an interior location, a public text telephone shall be provided in compliance with 4.31.9. Additionally, if four or more public pay telephones are located in any of the following locations, at least one public text telephone shall also be provided in that location: (a) a main terminal outside the security areas; (b) a concourse within the security areas; or (c) a baggage claim area in a terminal. Compliance with this section constitutes compliance with section 4.1.3(17)(c). (5) Baggage check-in and retrieval systems shall be on an accessible route complying with 4.3, and shall have space immediately adjacent complying with 4.2.4. If unattended security barriers are provided, at least one gate shall comply with 4.13. Gates which must be pushed open by wheelchair or mobility aid users shall have a smooth continuous surface extending from 2 inches above the floor to 27 inches above the floor. 51-20-3103 (a) 1. General. Accessibility to temporary or permanent buildings or portions thereof shall be provided for all occupancy classifications except as modified by this chapter. 51-20-3105 (d) 7. C. Counter and Windows. Where customer sales and service counters or windows are provided a portion of the counter or at least one window, shall be accessible in accordance with Section 3106 (x) 2.

51-20-3105 (d) 2. Telephones. ...Where four or more public telephones are provided at a building site, and at least one is in an interior location, at least one interior telephone shall be a text telephone in accordance with Section 3106 (h). Where interior public pay phones are provided in transportation facilities ... at least one interior text telephones shall be provided. [Washington does not specifically address airports.] [P.E. if airports are considered buildings.] [Does not address minimizing distance.] [P.E.] [E.] [Not addressed.] 129 01-03920 ADA/Washington State July 12, 1994

(6) Terminal information systems which broadcast information to the general public through a public address system shall provide a means to provide the same or equivalent information to persons with a hearing loss or who are deaf. Such methods may include, but are not limited to, visual paging systems using video monitors and computer technology. For persons with certain types of hearing loss such methods may include, but are not limited to, an assistive listening system complying with 4.33.7. (7) Where clocks are provided for use by the general public the clock face shall be uncluttered so that its elements are clearly visible. Hands, numerals, and/or digits shall contrast with their background either light-on-dark or dark-on-light. Where clocks are mounted overhead, numerals and/or digits shall comply with 4.30.3. Clocks shall be placed in uniform locations throughout the facility to the maximum extent practicable. (8) Security Systems. (Reserved). 10.5 Boat and Ferry Docks. (Reserved).

[Not addressed.] [Not addressed.] 130 01-03921 ADA/Washington State July 12, 1994