1.10 Accessibility Design Guidelines

It is GSA policy to make all federal buildings accessible without the use of special facilities for the disabled. The intent of this policy is to use standard building products set at prescribed heights and with prescribed maneuvering clearances to allow easy use by disabled employees and visitors. Building elements designated specifically for use by disabled persons should be kept to a minimum.

Charles Evans Whittaker U.S. Courthouse,
Kansas City, MO

Uniform Federal Accessibility Standards (UFAS)
is mandatory on all GSA projects. Current GSA policy also encourages compliance with the requirements of the Americans with Disabilities Act Accessibility Guidelines (ADAAG) where those requirements are stricter than UFAS. The A/E is responsible for checking whether there are local accessibility requirements. If they exist, the most stringent will prevail between local and UFAS/ADA.

The criteria of these standards should be considered a minimum in providing access to the physically disabled. Where dimensions for clearances are stated, allowance should be made in the design for construction tolerances to ensure the finished construction is in full compliance. (Compliance demonstration is mandatory.)

The following information lists provisions where UFAS is more stringent or contains different requirements than ADAAG. The bold type designates which standard should be used.

Federal Office Space
In office space the following two conditions apply:

a. Those where UFAS provisions are clearly more stringent than ADAAG
b. Those where differences are “de minimis,” or where provisions result in an equivalent level of access, do not significantly impact accessibility, or are outdated and no longer serve the intended purpose. In these cases, GSA has the option to choose between
relevant options.

Where UFAS Clearly is More Stringent:

Work Areas. UFAS requires that all areas which may result in employment of physically disabled persons be accessible. ADAAG requires only that people with disabilities be able to approach, enter, and exit a work area (UFAS 4.1.4; ADAAG 4.1.1(3)).

Work Surface Scoping . UFAS requires that 5 percent of all fixed or built-in employee work surfaces be accessible. ADAAG does not require work surfaces in work areas to be accessible. Both UFAS and ADAAG require that 5 percent of fixed tables in public or common use areas be accessible (UFAS 4.1.2(17) and 4.32; ADAAG 4.1.1(3) and 4.1.3(18)).

No Elevator Exception. UFAS has no exception to the elevator requirement and requires elevators in all multistory buildings and facilities. ADAAG provides an exception to the elevator requirement in certain buildings that are under three stories or have less than 3000 square feet per story (UFAS 4.1.2(5); ADAAG 4.1.3(5)Exception 1).

U.S. Courthouse,
White Plains, NY

Entrances in Multi-Grade Buildings. UFAS requires at least one principal entrance at each grade floor level to a building to be accessible. ADAAG requires: (1) that at least 50% of all public entrances be accessible; and (2) that the number of exits required by the applicable building/ fire code be used in determining the total number of accessible entrances required in a building or facility. UFAS would require more accessible entrances in certain “multi-grade” buildings (UFAS 4.1.2(8); ADAAG 4.1.3(8)).

Elevator Controls. UFAS requires elevator controls to be mounted no higher than 48 inches “unless there is a substantial increase in cost,” in which case 1400 mm (54 inches) is allowed. ADAAG allows 1400 mm (54 inches) whenever a parallel approach is provided (UFAS 4.10.12(3); ADAAG 4.10.12(3)).

UFAS/ADAAG Differences “De Minimis”Entrance Signage. UFAS always requires the International Symbol of Accessibility (ISA) at accessible entrances. ADAAG requires the ISA at accessible entrances only when there are inaccessible building entrances in the facility. If all entrances are accessible the ISA is not required under ADAAG (UFAS 4.1.1(7); ADAAG 4.1.2(7)).

Stairs Exception. UFAS exempts stairs from complying with 4.9 only if an elevator connects the same levels the stairs do. ADAAG exempts stairs from section 4.9 when there is any accessible means of vertical access connecting the same levels that are connected by the stairs (UFAS 4.1.2(4); ADAAG 4.1.3(4)).

Handrail Height. UFAS requires that handrails at stairs and ramps be placed with the gripping surface between 800 mm and 900 mm (30 and 34 inches) above the surface of the stair or ramp. ADAAG requires that such gripping surfaces be placed between 900 mm and 1000 mm (34 and 38 inches) (UFAS 4.8.5(5) and 4.9.4(5); ADAAG 4.8.5(5) and 4.9.4(5)).

Tactile Warnings. UFAS requires that doors to hazardous areas be equipped with tactile warnings. This provision is reserved in ADAAG (UFAS 4.1.2(14), 4.13.9, 4.29.3, 4.29.7; ADAAG 4.13.9, 4.29.3).

Pictograms. UFAS requires pictogram symbols to be tactile and does not allow tactile simple serif characters. ADAAG does not require pictogram (pictorial symbols signs) to be raised and does allow the use of simple and sans serif tactile characters. UFAS only allows sans serif characters (UFAS 4.30.4; ADAAG 4.30.4).

Special Occupancies

Assembly Areas

Scoping for 101 or More Fixed Seats. UFAS requires a greater number of wheelchair locations than ADAAG in larger assembly areas where the number of fixed seats exceeds 101 (UFAS 4.1.2(18); ADAAG 4.1.3(19)(a)).

Dispersion for 300 or Fewer Fixed Seats. UFAS requires that wheelchair spaces be dispersed throughout the seating area, regardless of seating capacity. ADAAG requires that wheelchair spaces be provided in more than one location when seating capacity exceeds 300 (UFAS 4.33.3; ADAAG 4.33.3).

Transient Lodging

Scoping. UFAS requires 5 percent of transient lodging facilities to be accessible to persons with mobility impairments which, in very large facilities, would result in a higher number of accessible units than ADAAG would require. As required by the ADA, ADAAG provides for an exception for facilities with five or fewer units that contain the residence of the proprietor. UFAS does not provide for such an exception (UFAS 4.1.4(11); ADAAG 9.1.1 Exception, 9.1.2).

Scoping and Technical Provisions. UFAS has scoping and technical provisions for housing. Section 13 Housing of the ADAAG interim final rule has not been adopted as a standard by the Department of Justice. The Board is considering reserving Section 13 in its entirety when the final guidelines for State and local government facilities is issued (UFAS 4.1.1(5)(d), 4.1.4(11), 4.34; ADAAG – proposes to reserve housing).

Ronald Reagan Building,
Washington, DC.

Restaurants and Cafeterias

Table Aisles. UFAS requires that there be access aisles between tables in restaurants and cafeterias which comply with 4.3 Accessible Routes. ADAAG requires that all accessible fixed tables shall be accessible by means of an access aisle at least 900 mm (36 inches) clear between parallel edges of tables or between a wall and the table edges (UFAS 5.1; ADAAG 5.3).

Vending Machine Controls. UFAS requires that the controls and operating mechanisms of vending machines in restaurants and cafeterias comply with all of 4.27. ADAAG only requires that the spaces where vending machines are located comply with the space allowances and reach ranges requirements (UFAS 5.4; ADAAG 5.8).

Bureau of Labor Statistics

Health Care

Canopy at Passenger Loading Zone. The application of the term “Health Care buildings and facilities” in UFAS, which is not expressly defined, may require more facilities to provide a canopy or roof overhang and a passenger loading zone at their entrances. ADAAG specifically defines “Medical care facilities” which must have a roof canopy or overhang and a passenger loading zone at an accessible entrance (UFAS 6.1; ADAAG 6.1).

Patient Bed Spacing. UFAS requires that there be 900 mm (36 inches) along each side of a bed in patient bedrooms, 1200 mm (48 inches) between beds, 1100 mm (42 inches) between the foot of a bed and the wall, and 1200 mm (48 inches) between the foot of a bed and the foot of the opposing bed. UFAS separately identifies requirements for one-bed rooms, two-bed rooms, and four-bed rooms. ADAAG treats beds in all rooms the same and requires that there be 900 mm (36 inches) along each side of a bed (UFAS 6.3; ADAAG 6.3).


Service Counters. UFAS requires that “a portion” of service counters in mercantile facilities be between 700 mm and 860 mm (28 and 34 inches) high. ADAAG requires a 36 inch length of service counter which is a maximum of 900 mm (36 inches) high (UFAS 7.2; ADAAG 7.2).

Check-Out Counter Height. UFAS requires at least one check-out counter to be no higher than 900 mm (36 inches). ADAAG requires that a specific number of check- out counters be no higher than 970 mm (38 inches) and that the top of the lip of the counter not exceed 1000 mm (40 inches) (UFAS 7.3(2); ADAAG 7.3(2)).


Knee Space at Check-Out Area. UFAS requires that at least one lane at each check-out area provide a counter surface that is between 700 mm and 860 mm (28 to 34 inches) high with knee clearances that is 700 mm (27 inches) high, 800 mm (30 inches) wide and 500 mm (19 inches) deep in libraries. ADAAG requires that at least one lane at each check-out area provide a 900 mm (36-inch) length of counter which is a maximum of 900 mm (36 inches) high. ADAAG does not require knee space (UFAS 8.3; ADAAG 8.3).

Postal Facilities

Customer Service Counters. UFAS requires that the aisles in front of customer service counters in postal facilities be at least 1200 mm (48 inches) wide. ADAAG requires services counters to be on an accessible route 900 mm (36 inches minimum width) (UFAS 9.2; ADAAG 7.2).

Partitions. UFAS requires that in postal facilities all fixed partitions withstand 372 kg/m (250 lb/f) from any direction. ADAAG does not have a similar provision (UFAS 9.2(1); ADAAG – no provision).

Handrails. UFAS requires that in postal facilities, where handrails are provided (regardless of whether they are required or not), the walls must be capable of supporting 372 kg/m (250 lb/f) in any direction. ADAAG requires the support only where handrails are required (UFAS 9.2(2); ADAAG 4.26.3).

Lockers. UFAS has technical requirements for lockers in postal facilities. The scoping in UFAS is vague, providing that “lockers in easily accessible areas must be provided for use by physically disabled people.” ADAAG does not have a similar provision (UFAS 9.5;
ADAAG – no provision).

Attendance Recording Equipment. UFAS requires that attendance recording equipment (i.e. time clocks, etc.) be mounted no higher than 1200 mm (48 inches) in postal facilities and that counter space at these check-in areas be no higher than 900 mm (36 inches) above the floor. ADAAG does not have a similar provision (UFAS 9.6; ADAAG – no provision).

Detention and Correctional Facilities

Scoping. UFAS requires 5 percent of residential units in detention and correctional facilities to be accessible. This figure is greater than the percentage proposed in Section 12 of the final rule on ADAAG for State and local government facilities (UFAS 4.1.4(9); ADAAG 12.4.1). The UFAS and ADA Title III standards do not cover clearly, nor in great detail, many of the facilities which the GSA constructs such as courthouses and detention facilities. These facilities are, however, covered in detail in the Interim Final Guidelines proposed for Title II of the ADA which apply to State and local government facilities

Federal Courthouses

It is GSA design policy that all Federal courtroom designs have the witness stand and jury box accessible, and the judge’s bench, clerks’ station, etc., to be adaptable.

Additions and Alterations
UFAS is more stringent or different than ADAAG.

NASA Auditorium,
Washington, DC

Additions. UFAS requires that if an addition to a building or facility does not provide an accessible route, an accessible entrance, or accessible toilet facilities, and such facilities are provided in the existing building then at least one of each shall be made accessible. ADAAG may require these items to be accessible under the path of travel obligation, depending on the amount of money required to build the addition (UFAS 4.1.5; ADAAG 4.1.5).

Substantial Alterations. UFAS requires greater accessibility when substantial alterations are made to a facility depending on the amount of money spent on the alteration and the size of the building or site. ADAAG requires that when an alteration is made to an area containinga primary function that the path of travel to that altered area and the restrooms, telephones, and drinking fountains that serve that area be made accessible unless the additional cost of doing so would be disproportionate to the overall cost and scope of the original alteration to the primary function area.

The level of disproportionality is set at 20 percent of the cost of the original alteration to the primary function area (UFAS 4.1.6(3); ADAAG 4.1.6(2)).

Alterations. ADAAG provides that in alterations, the requirements of 4.1.3(9), 4.3.10 and 4.3.11 concerning egress and areas of rescue assistance do not apply. UFAS does not have a similar exception (UFAS – no exception; ADAAG 4.1.6(g)).

Both the UFAS and ADAAG references used for this comparison were current as of the date of publication. (The A/E should check all updates to the respective requirements before proceeding with the building design.)

Last Reviewed: 2019-02-26