Frequently Asked Questions About Accessible Facility Design
Does ABAAS permit the use of portable ramps or lifts?
No. Portable ramps and lifts are not permitted under ABAAS because they are not permanent components of a building.
Does ABAAS permit the use of partially built-in ramps that require assistance to deploy before use and lifts that require assistance to use?
No. ABAAS requires unassisted use of ramps and lifts.
Does ABAAS permit the use of stairway chairlifts?
No. Stairway chairlifts are not permitted under ABAAS because they do not accommodate an occupied wheelchair.
Does ABAAS permit a parallel approach to accessible drinking fountains?
No. A parallel approach is not allowed under ABAAS, except at certain drinking fountains for children’s use where knee clearances cannot be accommodated because of the lowered height of the unit. Section 602.2 contains an exception that allows a parallel approach to units for children’s use where the spout height is 30 inches maximum above the finish floor or ground and is located 3 1/2 inches maximum from the front edge of the unit, including bumpers.
Are all repair and alteration (R&A) projects required to include costs for upgrading accessibility features?
No. ABAAS defines the term “alteration” in Section F106.5. Normal maintenance, reroofing, painting or wallpapering, or changes to mechanical and electrical systems are not considered alterations unless they affect the usability of the building or facility. For example, if a wall containing doors or doorways must be demolished in order to install new plumbing and vent risers, new doors or doorways that are installed in the rebuilt wall must comply with ABAAS, including providing sufficient clear width, accessible hardware and maneuvering clearances.
ABAAS Section F202.4 requires that alterations to areas containing a primary function include accessible routes, toilet rooms, telephones, and drinking fountains to serve the altered area(s) unless the cost and scope for these accessible features are “disproportionate” to the overall alterations as determined by GSA. Are all spaces within a building considered primary function areas?
No. GSA defines “primary function areas” as those spaces that contain a major activity for which the facility is intended. Primary function areas include areas where services are provided to customers or the public, and offices and other work areas in which the activities of the Federal agency using the facility are carried out. Ancillary spaces such as mechanical rooms, boiler rooms, supply storage rooms, employee lounges or locker rooms, janitorial closets, toilet rooms, corridors and entrances are not primary function areas.
Is there a point at which the costs of providing an accessible path of travel to an altered area containing a primary function are considered “disproportionate” to the cost of the overall alteration and therefore, additional accessible path of travel improvements are not required?
Yes for federally owned and funded properties subject to ABAAS and No for leased facilities. For facilities subject to the ABAAS, the costs of alterations to provide an accessible path of travel to an altered area containing a primary function are disproportionate to the costs of the overall alterations when they exceed 20 percent of the costs of the alterations to the primary function area. If a series of small alterations are made to areas containing a primary function and the costs of any of the alterations considered individually would not result in providing an accessible path of travel to the altered areas, the total costs of the alterations made within the three year period after the initial alteration must be considered when determining whether the costs of alterations to provide an accessible path of travel to the altered areas are disproportionate. Facilities for which new leases are entered into must comply with Section F202.6 of ABAAS without regard to whether the costs of alterations to comply with Section F202.6 are disproportionate to the costs of the overall alterations.
Are alterations to historic properties required to meet ABAAS?
Yes. Alterations to qualified historic buildings and facilities (a building or facility that is listed in or eligible for listing in the National Register of Historic Places, or designated as historic under an appropriate State or local law) are required to meet ABAAS. There are exceptions for alterations to qualified historic buildings and facilities for accessible routes, entrances and toilet facilities when the State Historic Preservation Officer or the Advisory Council on Historic Preservation determines that compliance with the requirements for the specific element would threaten or destroy the historic significance of the building or facility. These exceptions are in Sections F206.2.1, F206.2.3, F206.4 and F213.2, and contain specific requirements for alternative means to achieve access.
Are new leases negotiated by the Federal Government for buildings and facilities required to meet ABAAS?
Yes. All new leases are required to meet ABAAS except (a) buildings or facilities leased for use by officials servicing disasters on a temporary, emergency basis and (b) buildings or facilities leased for 12 months or less (provided that the lease may not be extended or renewed). Lease renewals, lease options, etc, must be treated as new leases.
Can an accessibility complaint corrective action be placed on hold until the next repair project is undertaken?
No. An accessibility complaint corrective action cannot be placed on hold until the next repair project is undertaken. A valid complaint must be corrected at the earliest possible date. By law, the Access Board has 180 days to resolve a complaint. A correction or corrective plan of action must be proposed within that time.
Construction drawings dimensioned in metric were arrived at by multiplying inches by 25.4, giving the metric equivalent in millimeters. Based on this calculation, it seems as if the ABAAS metric equivalents have been rounded up. Can this conversion be used instead?
No. In order to be compliant with ABAAS, the metric equivalents provided in ABAAS must be used.
Does GSA have other design requirements for accessibility?
Yes. Please see the Facilities Standards for the Public Buildings Service, PBS-P100, Section 1.10 (Accessibility Design Standards), Section 3.5 (Exterior Doors), which requires power-assist or automatic doors at all accessible public entrances), Section 9.2 (U.S. Court Facilities, General Requirements, Planning for Accessibility), which contains accessibility requirements for courtroom elements, and Table 9-1 (Accessibility Requirements), which outlines accessibility requirements that apply specifically to courts, including courtrooms, jury and ancillary facilities, and U.S. Marshal Service facilities.