Creating an ADA Facility Master Plan

Jean Batchelder, CFM

Almost every facility manager knows that new construction and renovation projects must be in full compliance with the Americans with Disabilities Act Accessibility Guidelines (ADAAG), or as they are now called, the Standards for Accessible Design. However, the majority of facilities professionals have the mistaken impression that if buildings are employee facilities such as corporate offices, warehouses, or manufacturing plants, the ADA has no requirement for barrier removal. This is not the case!

What ADA requirements impact existing facilities? Title III of the ADA applies to both public accommodations and commercial facilities. Public accommodations are places like restaurants, hotels, retail stores, professional service offices such as doctors and lawyers, health clubs, day care centers, etc. These types of businesses are required to make their goods and services available to and usable by people with disabilities, which often means making architectural modifications. The ADA defines commercial facility as private sector, non-residential, and involved in any commercial activity. This encompasses factories, warehouses, corporate office buildings, and any other facility in which employment occurs.

Many commercial facilities have areas which fall under the requirements applying to public accommodations. Examples are buildings with employment offices, credit unions, or medical departments. These functions are "public" in the sense that people other than company employees are able to use them. Requirements for barrier removal in public accommodations apply to these types of spaces in commercial facilities.

The general perception is that the ADA mandates that commercial facilities must comply fully only with regulations for new construction and alterations. So how does the ADA apply to existing (those occupied prior to 1993) commercial facilities? The regulations are detailed in Sections 36.402, Alterations, and 36.403, Alterations: Path of Travel, of the Final Rule. Any alteration made to a commercial facility after January 26, 1992, could trigger these requirements.

It's important to understand how the ADA defines "alteration". How does it coincide with the facility management definition of remodel or renovation? The ADA states that "an alteration is a change to a . . . commercial facility that affects or could affect the usability of the building or facility or any part thereof." Also, "alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, changes or rearrangement in structural parts or elements, and changes or rearrangement in the plan configuration of walls and full-height partitions." This lengthy definition is actually fairly clear: when a facility remodel includes moving walls, the standards for accessible design apply. Note that routine maintenance such as reroofing, painting, asbestos removal, or changes to building systems are generally not considered alterations by ADA definition.

The ADA further says that "an alteration that affects or could affect the usability of or access to an area of a facility that contains a primary function shall be made so 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 . . ." Understanding the ADA's definition of primary function will help clarify this potentially confusing rule. A "primary function" is a major activity for which the facility is intended. This includes areas such as the "dining area of a cafeteria, the meeting rooms in a conference center, as well as offices and other work areas." Mechanical rooms, employee lounges, locker rooms, corridors, and restrooms, among other things, are not areas containing a primary function. In other words, in a commercial facility, the primary functions are those which have to do with actually conducting the business of the company.

When alterations are made to a primary function area, the path of travel serving that area must also have access barriers removed. The path of travel encompasses certain amenities such as the restrooms and drinking fountains serving the altered area. The ADA has allowed that the cost of barrier removal to provide an accessible path of travel will be deemed disproportionate if the cost exceeds 20% of the cost of the alteration to the primary function area. This is known as the "20% path-of-travel rule". It is prudent to budget an extra 20% over and above anticipated remodel costs to address this mandate.

Because offices and other work areas are included in the ADA's description of a primary function area, typical office churn projects may trigger the requirements of this "20% path-of-travel rule". The elements included in the definition of alteration extend to open plan panel systems, production lines, etc. When a churn project "affects or could affect the usability" of an area of your facility, you are required to remove access barriers along the path of travel serving the altered area. This includes modifying the restrooms for wheelchair access and providing usable drinking fountains.

You may have to make a judgment call in determining whether a remodel or alteration meets the ADA definitions and triggers this requirement. When you reconfigure a department's panel system to squeeze in two more employees, you are really not affecting the use of the area. However, if the purpose of your reconfiguration is provide a work area for a new business function, the requirement will most likely be triggered. For instance, when your company develops a new product, you need to provide space for the product's new marketing unit. Perhaps you plan to move your facility services function to another location to free up space at corporate headquarters. Both the space for facilities and the space for the new marketing group will need to be built out in compliance with the ADA standards for accessible design and both will trigger the 20% path-of-travel rule.

Many facility managers realize that the ADA requires them to make modifications to restrooms and drinking fountains when they are undertaking a remodel. However, many do not know exactly what is required of them or how to go about complying. Determining which facility elements should be considered and how to prioritize barrier removal can be confusing. The ADA has simplified this by outlining barrier removal priorities:

1) Provide access from public sidewalks, parking, or public transportation. This might include installing curb cuts or an entrance ramp, widening entrance doors, and providing accessible parking spaces.

2) Provide access to areas, features, and amenities of the building interior. This includes things like widening doors and replacing inaccessible door hardware, providing signage which has raised (tactile) and Braille characters, installing visual alarms, and installing ramps in place of steps along the path of travel.

3) Provide accessible restrooms, including specific types of signage.

4) Take any other measures necessary to assure full accessibility. This includes such things as accessible drinking fountains and public telephones.

Barrier removal should be undertaken in accordance with the above priorities and the highest priority given to those elements that provide the greatest access. This is one of those decision areas requiring the application of common sense. It makes little sense to renovate restrooms for wheelchair accessibility if all entrances into the building are via stairs. Installing a ramped entry into the building will be a higher priority than modifying the restrooms. Your first priority may cost more than 20% of any individual alterations project. Some companies accumulate the 20% from a series of remodel projects into an ADA account and designate this account for implementing expensive ADA projects such as the addition of building ramps or elevators.

Facility managers seldom have the time and/or level of expertise regarding the complex, confusing and often ambiguous mandates of the ADA to adequately integrate these requirements into their facility planning. And frankly, compliance with the ADA is often not a very high priority in commercial facilities. What follows is a process which should help facilities professionals meet both the letter and the spirit of the law.

Creating the ADA Master Plan

1) As with any strategic facility plan, the first step is to determine existing conditions, or in this case, identify which elements do not currently meet the ADA Standards for Accessible Design. This requires a complete analysis of the facility, including the path of travel to the building entrances from public streets and sidewalks, public transportation, and from the parking areas serving the building entrances. There are numerous survey instruments, or checklists, available. Those considered official ADA compliance materials are easy to use and will provide an accurate assessment of existing conditions. The "Checklist for Existing Facilities version 2.1" developed by Barrier Free Environments, Inc. and Adaptive Environments Center, Inc., under a federal grant give a good overview of key elements. The Access Board's "Checklist for Buildings and Facilities" establishes complete criteria for each building element. Parts of this extensive checklist should be used to examine details of potential access barriers. For instance, if restrooms are not currently wheelchair accessible, this checklist should be used to assess deficiencies. By combining the information from both checklists, you will have an overview of general accessibility as well as all the detail you need to bring non-conforming elements into compliance with the design standards. These checklists can be obtained by calling your regional ADA Technical Assistance Center, 1-800-949-4232.

2) All access barriers identified during the existing conditions analysis should be summarized, a potential cost for barrier removal alternatives formulated, and the information included in the facility long- and short- range planning strategies. It is generally wise to integrate an overview of identified barriers into the long-range plan so that the ADA plan is regularly reviewed and updated. Treat this like you would planned maintenance such as roof repairs, chiller replacement, recarpeting, etc. The ADA section of the long-range strategic facility plan could be as simple as this:

ADA Capital Projects, January, 1997

• Restripe handicap parking $ 300
• Install ramp at main entry $ 25,000
• Retrofit alarm system with visual alarms $ 8,000
• Replace door hardware in common spaces $ 9,000
• Modify 2 restrooms for full accessibility $ 5,000
• Replace signage in common use areas (tactile & Braille) $ 2,000
• Replace two drinking fountains with hi-lo units $ 3,500

This plan should be updated annually, or as facility projects occur. By reviewing the ADA information, barrier removal to satisfy the 20% path-of-travel-rule can be budgeted for and implemented in conjunction with routine projects. For instance, if your company is planning a full-floor remodel next year, you might include this ADA information:

 
 SUMMARY OF INACCESSIBLE FEATURES 
                                       
 
  ELEMENT/BARRIER                       RECOMMENDATION          ESTIMATE 
 
32nd Floor - 1997 
 
Doors                          Replace with lever hardware        12,400 
Knobs throughout.              in conjunction with remodel. 
  
 
Room signs                     Add compliant signs at                320 
No tactile and Braille.        permanent, common-use rooms  
                               & spaces.   
 
Cafeteria                      Modify in conjunction with          3,500 
Vending, microware, &          floor remodel.   
paper towels all out of     
reach range.  Sink and 
counter too high.                          
 
Restrooms                      Provide one                         2,000  
Women's has no wheel-chair     fully-accessible stall by                  
accessible stall.              combining two stalls.                      
 
Men's has no wheel-chair       Provide one                         2,000  
accessible stall.              fully-accessible stall by                  
                               combining two stalls.                      
 
No ADA signage (both).         Add signs with tactile,                90  
                               braille, and appropriate                   
                               pictograms.                                
 
Doors too heavy.               Adjust to 5 lbf max.                   80  
 
 
 
32nd Floor Total                                                $ 20,390   
 
 

3) Before implementing barrier removal projects, it is sensible to involve any employees who have disabilities. You may not have any employees with readily-apparent disabilities. Put an item in your company newsletter about your planned ADA work. Let it be known that you are seeking input from people with disabilities; perhaps someone will come forward. Another alternative for obtaining this valuable perspective is to call a local disability organization. Centers for Independent Living are often a good choice; while they advocate for disability rights, they are not activist organizations. Expect to pay them, or if they don't charge, give them a donation to compensate them for their time.

4) Perhaps neither you nor your staff feels qualified to undertake a massive ADA survey and put together a master plan. There are numerous consultants who do this type of work. It's important to find someone who not only knows the law, but uses common sense in applying it. You will want someone who can provide the type of documentation which will be useful during implementation. Can the barriers be compiled in a spreadsheet to be used as a tracking tool? Does the consultant offer design solutions and estimating? Will the person you hire be able to outline acceptable alternatives to expensive architectural modifications? If your building drawings are on CAD, does the consultant have compatible CAD capabilities? You will get the best results if the consultant can provide all of these.

5) Whether your department develops the ADA master plan or you hire a consultant, you will need line-item cost estimates. Often you will be able to find solutions which do not require design and construction, but can be addressed through changes in policy and procedure. These items should be included in your plan, with a zero cost. Your historical cost estimating data for facilities projects is the best guide in projecting barrier removal project costs. The "Means ADA Compliance Pricing Guide" is a good tool for pricing out those types of projects you have never done before, i.e., modifying restrooms for wheelchair use.

6) When finalizing your ADA plan, incorporate a strong dose of common sense. This may sound easy; however, if you really aren't familiar with the nuances of the ADA and go strictly "by the book", you may needlessly spend large amounts of money on things you don't really need to do. Conversely, it is very easy to totally miss something critical to providing good access for people with disabilities. One of the best tools for achieving a comprehensive view of your ADA deficiencies and developing a cohesive plan is to illustrate key items graphically. These drawings of a typical campus site and building floor plan illustrate how drawings can help visualize the overall picture and provide a sense of direction. Applying common sense will be much easier when you are able to integrate the detail you've compiled with this macro-view.

In review, developing a facility ADA master plan involves these steps.

• Determine existing conditions. Complete a comprehensive ADA audit or survey of existing company facilities.
• Summarize and analyze findings. Determine impact of barriers, alternatives for providing access and probable costs. Recording this information on a spreadsheet or in a data base is helpful for future use.
• Integrate ADA information into long- and short- range facility planning. Include a record of barrier removal projects completed, with final costs.
• Prioritize barrier removal. Using drawings and accessibility data, determine where the greatest barriers are. Follow the ADA's recommendations for barrier removal priorities and complete work in conjunction with facility alterations projects.
• Review ADA plans annually and update information to include in annual facility project budgets. Update ADA long-range master plan accordingly.

Is a relocation in your future? All of the rules we have already talked about apply to relocation. The act of simply moving does not trigger ADA requirements, the act of altering spaces does. When considering lease spaces, a good practice is to obtain pertinent ADA information from the landlord or leasing agent. Has the building been surveyed? Have any modifications for accessibility been made? Check into the availability of reserved accessible parking, whether there is a clearly marked accessible entrance, whether the building signage has tactile and Braille characters, and whether the restrooms meet wheelchair access requirements. If building elements do not currently meet the ADA's design standards, you will want to be assured that you will not be assessed for modifications. Standard practice is for the landlord to pay for barrier removal on the building site and in building common use spaces such as the entries, elevator lobbies and restrooms on multi-tenant floors. The tenant usually absorbs the costs associated with barrier removal within the lease space. Your lease should include provisions for any required ADA barrier removal, clearly designating responsible parties. The ADA says that both the landlord and the tenant are responsible for ADA compliance; however, terms of the lease will be considered in the event of complaints or litigation. Given the choice, lease only facilities which are in compliance with the ADA.

ADA requirements continue to perplex even the most informed facility managers. Compliance with this complex law need not be a source of frustration, however. Simply remember these two key points. All new construction and alterations projects are to be completed in accordance with the Standards for Accessible Design outlined in the ADA. Alterations projects which affect the usability of primary function areas trigger the 20% path-of-travel rule, requiring barrier removal on the path of travel and in the building amenities serving the altered area.

This article first appeared in the Facility Management Journal, March/April, 1997