     Common ADA Errors and Omissions in New Construction and
                           Alterations

U.S. Department of Justice

Civil Rights Division

Disability Rights Section

(seal of the U.S. Department of Justice)

Common ADA Errors and Omissions in New Construction and
Alterations

Introduction

The ADA requires that new construction and alterations to
existing facilities comply with the ADA Standards for Accessible
Design1 (Standards). ADA requirements for new construction and
alterations include detailed provisions for elements, spaces,
and facilities. Successful accessibility is often measured in
inches, so attention to detail can make the difference between
achieving access and excluding or injuring someone. When the
ADA's minimum requirements are not met, the results can limit or
exclude a person with a disability and can be dangerous. For
example, when a curb ramp extends into an access aisle at an
accessible parking space, a person using a wheelchair may not be
able to get out of the car or van. When the slope of a sidewalk
that is an accessible route becomes steeper than 1 to 20,
railings and edge protection are required for safe use. Objects
that project into circulation spaces from the side or that do
not provide at least 80 inches of head clearance can be
extremely hazardous to people who are blind or who have low
vision.

(illustration showing a man going down a ramp in a wheelchair
and falling out of the wheelchair after it rolls off the edge of
a ramp because the ramp lacks edge protection)

This document lists a sampling of common accessibility errors or
omissions that have been identified through the Department of
Justice's ongoing enforcement efforts. The specific requirement
of the Standards that has not been met follows each
error/omission. All references to figures can be found in the
Standards. The list of errors/omissions provides examples of
common deficiencies. It is not intended to be comprehensive or
exhaustive. Any failure to comply with the Standards violates
the ADA.

For additional information about the design and construction
requirements of the Americans with Disabilities Act (ADA),
contact the Department of Justice ADA Information Line. This
free service provides answers to general and technical questions
about ADA requirements and is a source for free ADA materials
including the ADA Standards for Accessible Design. You may reach
the ADA Information Line at: 800 - 514 - 0301 (voice) or 800 -
514 - 0383 (TTY).

ADA information is also available on the Department's ADA Home
Page on the World Wide Web at
(http://www.usdoj.gov/crt/ada/adahom1.htm).

Footnote 1 State and local governments currently have the option
to choose the Standards or the Uniform Federal Accessibility
Standard (UFAS).

Parking

Error/Omission:

     The built-up curb ramp projects into the access aisle.

     The accessible parking space and access aisle is not
     level in all directions.

Result:

     When an access aisle has a sloped surface, a
     wheelchair may roll away from a car or van preventing
     the wheelchair user from getting out of the vehicle.
     The sloped surface also prevents a van-mounted
     wheelchair lift from being fully-lowered to the access
     aisle surface.

Requirement:

     4.6.3* Parking Spaces. ...Parking spaces and access
     aisles shall be level with surface slopes not
     exceeding 1:50 (2%) in all directions.

Error/Omission:

     There is no accessible route from accessible parking
     to an accessible entrance.

Result:

     A person using a wheelchair, scooter, or walker has no
     way of getting from the accessible parking space to
     the building entrance. Often when there is an
     inaccessible walkway provided for others, wheelchair
     users must use a roadway or vehicular route which can
     be dangerous.

Requirement:

     4.6.3* Parking Spaces. ...Parking access aisles shall
     be part of an accessible route to the building or
     facility entrance and shall comply with 4.3.

Footnote * Asterisk denotes that related, non-mandatory material
is in the Appendix to the Standards.

(illustration showing an overhead view of a van and a car parked
in accessible parking spaces that share an access aisle. A
person using a wheelchair is positioned next to the drivers side
of the car and the door to the car is open. A dashed line with
an arrowhead shows the accessible route from the access aisle to
the sidewalk.)

Error/Omission:

     No van accessible spaces are provided in the parking
     area.

Result:

     A person who uses a van equipped with a wheelchair
     lift has inadequate space to lower the wheelchair lift
     and get out of the vehicle.

Requirement:

     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.

Accessible Route - Exterior

Error/Omission:

     The pedestrian routes on a site from public
     transportation stops, accessible parking spaces,
     passenger loading zones, and public streets and
     sidewalks to the accessible entrance(s) are not
     accessible.

Result:

     People with disabilities cannot travel from the site
     entry points to the accessible entrance(s). In some
     cases, people must use vehicular routes which can be
     dangerous.

Requirement:

     4.1.2 (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.

Curb Ramps

Error/Omission:

     Curb ramp that is located across a circulation path
     has steep unprotected side flares.

Result:

     People walking across the curb ramp may trip and be
     injured. People who use wheelchairs can tip over if
     they accidentally roll over the non-flared sides.

Requirement:

     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 guardrails, 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)).

(illustration showing a flared curb ramp located in a sidewalk
area that is adjacent the access aisle of an accessible parking
space. People can walk across the curb ramp while using the
sidewalk and can use the curb ramp to get from the access aisle
to the sidewalk.)

Ramps

Error/Omission:

     Landing areas where ramps change direction (e.g.,
     switchbacks or 90&deg; turns) are too small.

Result:

     Wheelchair users are unable to go up or down the ramp
     because there is not enough space to turn on a level
     surface. This makes the ramp unusable.

Requirement:

     4.8.4* (3) If ramps change direction at landings, the
     minimum landing size shall be 60 in by 60 in (1525 mm
     by 1525 mm).

Error/Omission:

     Parts of an accessible route with slopes that exceed
     1:20 lack required features including handrails and
     edge protection.

Result:

     When a walkway or other pedestrian surface has a slope
     greater then 1:20, it is more difficult to maintain
     control of a wheelchair. Wheelchair users may also not
     be able to climb up the sloped route without railings.
     Lack of edge protection may result in injury if a
     wheelchair user rolls off the side of the route.
     People who use a mobility device such as crutches, a
     cane, or a walker may lose their balance or fall while
     using a sloped section that does not have handrails or
     edge protection.

(illustration showing a man going down a ramp in a wheelchair
and falling out of the wheelchair after it rolls off the edge of
a ramp because the ramp lacks edge protection)

Requirement:

     4.8.1* General. Any part of an accessible route with a
     slope greater than 1:20 shall be considered a ramp and
     shall comply with 4.8.

Stairs

Error/Omission:

     Handrail extensions are not provided at the top and
     bottom risers.

Result:

     People who use crutches or a cane or who have limited
     balance may fall at the top or bottom of the stairs
     because they have no railing to hold onto as they make
     the transition from the steps to the landing.

Requirement:

     4.9.4(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.

(illustration showing the handrail extensions on the top and
bottom sections of the stair)

Doors

Error/Omission:

     Adequate maneuvering clearance is not provided at
     doors, including doors to accessible toilet stalls.

Result:

     A person using a wheelchair cannot open the door
     without a clear level area in front of and adjacent to
     the door that provides a place to maneuver.

(illustration showing a plan view of a person using a wheelchair
trying to pull a hinged door toward them to open it. No clear
space is provided adjacent to the latch side of the door.)

Requirement:

     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.

     4.17.5* Doors. Toilet stall doors, including door
     hardware, shall comply with 4.13. If toilet stall
     approach is from the latch side of the stall door,
     clearance between the door side of the stall and any
     obstruction may be reduced to a minimum of 42 in (1065
     mm) (Fig. 30).

(illustration showing a plan view of an accessible door that has
clear floor space next to the latch side of the door on the pull
side and adequate maneuvering space in front of the door. A
person using a walker is pulling the door open while the walker
is positioned in the clear space next to the latch.)

Error/Omission:

     The shape of the door hardware requires tight
     grasping, pinching, and twisting of the wrist to use.

Result:

     The door cannot be opened if the user cannot operate
     the latch or handle.

Requirement:

     4.13.9* Door Hardware. Handles, pulls, latches, locks,
     and other operating devices on accessible doors shall
     have a shape that is easy to grasp with one hand and
     does not require tight grasping, tight pinching, or
     twisting of the wrist to operate. Lever-operated
     mechanisms, push-type mechanisms, and U-shaped handles
     are acceptable designs. When sliding doors are fully
     open, operating hardware shall be exposed and usable
     from both sides. Hardware required for accessible door
     passage shall be mounted no higher than 48 in (1220
     mm) above finished floor.

(illustration showing a hand pushing down on a lever handle to
open the door)

Circulation Paths

Error/Omission:

     Objects protrude into circulation paths from the side
     or from posts.

     Objects that overhang circulation paths do not provide
     clear headroom.

(illustration of a blind person walking into the side of a
wall-mounted drinking fountain that is a protruding object)

Result:

     People who are blind or who have low vision can be
     seriously injured when they cannot detect an object by
     using the sweep of their cane.

Requirement:

     4.1.2 (3) All objects that protrude from surfaces or
     posts into circulation paths shall comply with 4.4.

     4.1.3 (2) All objects that overhang or protrude into
     circulation paths shall comply with 4.4.

     4.4.1* General. Objects projecting from walls (for
     example, telephones) with their leading edges between
     27 in and 80 in (685mm 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)).

(illustration of a wall-mounted Automated Teller Machine (ATM)
with a wing wall installed adjacent to the ATM to eliminate the
protruding object hazard.)

     4.4.2 Head Room. Walks, halls corridors, passageways,
     aisles, or other circulation spaces shall have 80 in
     (2030 mm) minimum clear head room (see Fig. 8(a)). If
     vertical clearance of an area adjoining an accessible
     route is reduced to less than 80 in (nominal
     dimension), a barrier to warn blind or
     visually-impaired persons shall be provided (see Fig.
     8(c-1)).

Toilet Rooms and Bathrooms

Error/Omission:

     Where toilet rooms or bathrooms are provided, not all
     public and common use toilet rooms and bathrooms
     (including locker rooms and toilet rooms for employee
     use) are accessible.

Result:

     People with disabilities are restricted to a limited
     number of toilet rooms and may have to travel long
     distances to the accessible toilet room while others
     can use any toilet room.

Requirement:

     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.

Error/Omission:

     Toilet rooms with 6 or more toilet stalls lack a 36"
     wide "ambulatory" toilet stall.

Result:

     Too few accessible stalls are provided for people with
     mobility disabilities. People who walk with crutches,
     a cane, a walker, or who have limited balance
     generally find it easier and safer to use a stall that
     has parallel grab bars.

Requirement:

     4.22.4, 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.

(illustration of a woman who uses crutches and leg braces
sitting down on a toilet. She is using the two parallel grab
bars.)

Error/Omission:

     The door to the toilet room swings into the required
     clear floor space at accessible fixtures, controls,
     and dispensers.

Result:

     The entry door to the toilet room cannot be fully
     opened when a wheelchair user is using the accessible
     fixture, control, or dispenser. For example, if a
     person using a wheelchair is positioned in the clear
     floor space at the paper towel dispenser and that
     clear floor space overlaps the space needed to swing
     the door open, the door cannot be fully-opened.

Requirement:

     4.22.3*, 4.23.3* Clear Floor Space. The accessible
     fixtures and controls required in 4.22.4, 4.22.5,
     4.22.6, 4.22.7 and 4.23.4, 4.23.5, 4.23.6, and 4.23.7
     shall be on an accessible route. An unobstructed
     turning space complying with 4.2.3 shall be provided
     within an accessible toilet room. The clear floor
     space at fixtures and controls, the accessible route,
     and the turning space may overlap.

Error/Omission:

     When a transfer shower is used, it is often larger
     than the required 36" x 36" size.

Result:

     People with disabilities may be injured when using a
     transfer shower that is too large. Users may slide off
     the seat and fall onto the floor of the shower while
     reaching for the shower controls and hand-held
     showerhead.

(illustration showing a plan view of a transfer shower with a
man sitting on the folding seat and his wheelchair positioned
outside the shower adjacent to the seat.)

Requirement:

     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.

(illustration showing a 36 in by 36 in shower compartment
equipped with seat, hand-held shower head, grab bar and shower
curtain.)

Signage

Error/Omission:

     Where permanent room identification signage is
     provided, it is mounted in the wrong location.

Result:

     People who are blind or visually impaired are trained
     to look in a consistent location for tactile signs.
     They cannot find the sign if it is not mounted in the
     correct location.

Requirement:

     4.1.3(16)(a) Signs which designate permanent rooms and
     spaces shall comply with 4.30.1, 4.30.4, 4.30.5 and
     4.30.6.

     4.30.6 Mounting Location and Height. Where permanent
     identification is provided for rooms and spaces, signs
     shall be installed on the wall adjacent to the latch
     side of the door. Where there is no wall space to the
     latch side of the door, including at double leaf
     doors, signs shall be placed on the nearest adjacent
     wall. Mounting height shall be 60 in (1525 mm) above
     the finish floor to the centerline of the sign.
     Mounting location for such signage shall be so that a
     person may approach within 3 in (76 mm) of signage
     without encountering protruding objects or standing
     within the swing of a door.

(illustration showing a sign designating room number 131 with
raised characters and Braille. The sign is mounted next to the
latch side of the door.)

Visual Alarms

Error/Omission:

     No visual alarms are provided although an audible
     alarm system is installed.

Result:

     People who are deaf have no way of knowing that a
     building emergency has been declared while others who
     can hear are alerted by the audible alarm. This is
     especially true of toilet rooms, and study carrel
     areas where occupants cannot observe others leaving
     the facility.

Requirement:

     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.

     4.28.1 General. Alarm systems required to be
     accessible by 4.1 shall comply with 4.28. At a
     minimum, visual signal appliances shall be provided in
     buildings and facilities in each of the following
     areas: restrooms and any other general usage areas
     (e.g., meeting rooms), hallways, lobbies, and any
     other area for common use.

Drinking Fountains

Error/Omission:

     All drinking fountains are mounted with the spout at
     36" A.F.F.

Result:

     People who have difficulty stooping or bending over
     are not able to get a drink from the accessible 36"
     high drinking fountain.

Requirement:

     4.1.3(10)* Drinking Fountains:

     (a) Where only one drinking fountain is provided on a
     floor there shall be a drinking fountain which is
     accessible to individuals who use wheelchairs in
     accordance with 4.15 and one accessible to those who
     have difficulty bending or stooping. (This can be
     accommodated by the use of a "hi-lo" fountain; by
     providing one fountain accessible to those who use
     wheelchairs and one fountain at a standard height
     convenient for those who have difficulty bending; by
     providing a fountain accessible under 4.15 and a water
     cooler; or by such other means as would achieve the
     required accessibility for each group on each floor.)

     (b) Where more than one drinking fountain or water
     cooler is provided on a floor, 50% of those provided
     shall comply with 4.15 and shall be on an accessible
     route.

Restaurants

Error/Omission:

     Food service queuing areas are too narrow and do not
     provide adequate clear width for turns.

Result:

     People who use wheelchairs cannot get to the counter
     to purchase or pick up food. Sometimes they get into
     the queuing area and get trapped.

Requirement:

     4.3.3 Width. The minimum clear width of an accessible
     route shall be 36 in (915 mm) except at doors (see
     4.13.5 and 4.13.6). If a person in a wheelchair must
     make a turn around an obstruction, the minimum clear
     width of the accessible route shall be as shown in
     Fig. 7(a) and (b).

Error/Omission:

     Condiment or utensil items are placed above the reach
     range or are not located on an accessible route.

Result:

     Wheelchair users cannot obtain condiments and other
     items because the items are out of reach or there is
     no way to get to the items.

Requirement:

     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).

Transient Lodging

Error/Omission:

     In hotels, motels, or other lodging facilities of 50
     or more sleeping rooms, no rooms with roll-in showers
     are provided, or the roll-in showers that are provided
     lack a fold-down seat.

Result:

     People who must use a roll-in shower or a shower with
     a fold-down seat cannot bathe. When a roll-in shower
     is provided without a folding seat, guests may resort
     to using guest room furniture in the shower.

(illustration showing a person using a wheelchair in a roll-in
shower that is not equipped with a fold-down seat.)

Requirement:

     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).

Error/Omission:

     Wheelchair-accessible rooms are not equipped with
     visual alarms and notification devices.

Result:

     People who are deaf or hard of hearing and who also
     need to use a guest room with accessible features have
     no accommodation.

Requirement:

     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 room or
     suite.

Error/Omission:

     Doors into and within guest rooms that are not
     accessible guest rooms do not provide at least 32"
     clear opening width.

Result:

     People who use a wheelchair, scooter, or walker are
     unable to enter standard guest rooms and are excluded
     from accommodations when accessible guestrooms are
     occupied.

Requirement:

     9.4 Other Sleeping Rooms and Suites. Doors and
     doorways designed to allow passage into and within all
     sleeping units or other covered units shall comply
     with 4.13.5.

(illustration showing a man who is using a wheelchair passing
through a doorway. The door is equipped with round doorknobs.)

Reproduction of this document is encouraged.


.

