GSA National ABAAS standards.pdf

NATIONAL

ACCESSIBILITY

PROGRAM

STANDARDS, POLICIES AND PROCEDURES

U.S GENERAL SERVICES ADMINISTRATION

1GSA National Accessibility Program Ed. 14. 1

1 PURPOSE

2 HISTORY OF ACCESSIBLE FACILITY DESIGN AT GSA

3 GSA’S NATIONAL ACCESSIBILITY PROGRAM

4 U.S. ACCESS BOARD

5 ACCESSIBLE FACILITY DESIGN PROCESS

6 ABA MODIFICATION AND WAIVER REQUESTS

7 ACCESS BOARD COMPLAINTS

8 FREQUENTLY ASKED QUESTIONS ABOUT

ACCESSIBLE FACILITY DESIGN

TABLE OF CONTENTS

Cover: Front Entrance Ramp and Stair - Edith Green-Wendell Wyatt Federal Building, Portland, Oregon

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New E Street Entrance Lobby - GSA Headquarters, Washington, DC

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PURPOSE

The U.S. General Services Administration (GSA) is committed to implementing the Architectural Barriers Act of 1968 (ABA). To do so, the agency constructs new facilities that are accessible to persons with disabilities and incorporates the most current accessible-design requirements into its alterations of existing buildings.

It also leases accessible facilities. GSA takes pride in accommodating all Americans.

GSA’s National Accessibility Program makes information about accessible design available to all individuals responsible for designing, constructing, altering, leasing, and operating the agency’s inventory.

To that end, this desk guide is intended to assist the Regional Accessibility Officers who manage GSA’s National Accessibility Program, as well as GSA’s Public Buildings Service (PBS) employees responsible for overseeing the design, construction, alteration, leasing, and operation of the agency’s inventory. Architects

4GSA National Accessibility Program Ed. 14. 1 and engineers under contract to GSA to design new facilities or alterations should also look to the guide as a vital resource. This document compiles the background, program operating procedures, and resources that support GSA’s efforts to fully comply with the accessibility requirements of the historic ABA legislation.

STANDARDS, POLICIES, PROCEDURES

AND ABAAS

The Architectural Barriers Act (ABA) of 1968 covers all federal facilities designed, built, altered or leased with federal funds. In addition, it is U.S.

General Services Administration policy that all of its buildings and facilities are accessible to persons with disabilities, without the need for special equipment or designated space. In 2006 GSA adopted the Architectural Barriers Act

Accessibility Standard, or ABAAS, to fulfill this purpose. ABAAS applies to both owned and leased properties in the GSA inventory. As landlord of federal civilian workplaces, GSA is in the unique position of implementing or resolving accessibility for all facilities covered by the ABA except military, postal and housing facilities.

ABAAS is divided into 10 parts. The first two chapters cover application, administration and scoping requirements of the standard. Moreover, they are prefixed by the letter F, as in F206.4 or

F206.4.1, to designate that they apply only to federal buildings and facilities.

While ABAAS and the design standards of the Americans with Disabilities Act share common technical requirements, there are important differences in Chapters 1 and 2 pertaining to application, administration and scoping due to the differences between the ABA and ADA statutes.

The remaining chapters of ABAAS contain technical requirements for, sites, facilities, buildings, special rooms and spaces such as toilet rooms, bathing facilities, and kitchens, and elements such as: doors, ramps, elevators, stairs, platform lifts, plumbing fixtures, signs, communication systems and work surfaces. Technical requirements specify details like clearances and reach ranges.

The current ABA standards have been harmonized to a significant extent with industry standards and model building codes, including the International Building

Code. By GSA policy, a specific ABAAS technical requirement is superseded in cases where a project’s state or locality has a more stringent requirement.

Architects and engineers often underestimate the complexity of ABAAS.

Indeed, navigating the standard involves understanding many scoping and technical variables, yet ABAAS’s overall mandate is clear: to ensure the accessibility of facilities designed, built, altered or leased with federal funds as required by the ABA.

GSA’s “National Accessibility Program:

Standards, Policies and Procedures” is a companion to ABAAS. Although reading this publication is no substitute for learning the intricacies of ABAAS, “Standards, Policies and Procedures” does place the standard in historical context and highlights some of its most queried technical requirements. Perhaps more important, “Standards, Policies and

Procedures” explains the administration of ABAAS—which itself contains variables and exceptions. GSA’s accessibility officers, as well as the staff of the U.S.

Access Board, are available to assist with technical and administrative queries alike.

Please see chapters 3 and 4 for contact information.

http://www.access-board.gov/ada-aba/aba-standards-gsa.cfm http://www.access-board.gov/ada-aba/aba-standards-gsa.cfm

5GSA National Accessibility Program Ed. 14. 1

Entrance Ramp and Stairs - William Jefferson Clinton Federal Building, Washington, DC

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HISTORY OF

ACCESSIBLE FACILITY

DESIGN AT GSA

In 1959 the American Standards Association—a private-sector standard-setting organization now known as the American National Standards Institute, or ANSI—spearheaded the first serious effort to accommodate the needs of persons with disabilities in the built environment. Responding to a request by The President’s Committee on Employment of the Physically Handicapped, the association held a general conference of allied organizations that recommended development of voluntary accessible-design standards for buildings. The President’s Committee on Employment of the Physically Handicapped co-sponsored the recommendation with the National Society for Crippled Children and Adults (later renamed the National Easter Seal Society).

ACCESSIBILITY MILESTONES

1959 » American Standards Association conference recommends voluntary accessible-design standards for buildings

1961 » Publication of “American National

Standard Specifications for Making

Buildings and Facilities Accessible to, and

Usable by, The Physically Handicapped”;

today known as the American National

Standards Institute (ANSI) A117.1

1965 » Establishment of National

Commission on Architectural Barriers to Vocational Rehabilitation of the

Handicapped (NCAB) in the Department of

Health, Education, and Welfare

1968 » NCAB issues “Design for All

Americans”

1968 » Congress passes the Architectural

Barriers Act (ABA), requiring facilities designed, constructed, altered, or leased with certain federal funds or grants to be accessible to persons with disabilities

ANSI A117.1

7GSA National Accessibility Program Ed. 14. 1

In 1961 ANSI published the first nationally recognized design standards for accessibility. ANSI A117.1, “American National Standard Specifications for Making Buildings and Facilities Accessible to, and Usable by, The Physically Handicapped,” was based on research conducted by the University of Illinois and funded by the Easter Seal Research Foundation.

Originally voluntary, the ANSI standard became enforceable when state and local governments began adopting it toward the end of the decade.

In 1969, subsequent to the passage of the Architectural Barriers Act (ABA), GSA adopted ANSI A117.1 as its first standard for accessible design. Five years later the standard received federal input from the U.S. Department of Housing and Urban Development (HUD), which joined the ANSI secretariat in charge of it.

Architectural Barriers Act In 1968 Congress passed the ABA to require accessibility for persons with disabilities in facilities that are designed, built, or altered by or on behalf of the United States of America. The act also applies to federally leased properties and to non-federally owned facilities that are constructed or altered with certain types of federal funding. The ABA designates the U.S. Department

1969 » GSA adopts ANSI A117.1 as its first, voluntary standard for accessible design

1973 » Congress passes the Rehabilitation

Act of 1973, Section 502 of which creates the Architectural and Transportation

Barriers Compliance Board—today known as the U.S. Access Board

1974 » Department of Housing and

Urban Development joins secretariat of committee in charge of ANSI A117.1 standard

1975 » James S. Jeffers is appointed the first Executive Director of the U.S. Access

Board

1980 » ANSI releases an improved accessible design standard, A117.1-1980

1980 » GSA publishes a mandatory “GSA

Accessibility Standard,” based on ANSI

A117.1-1980

1982 » U.S. Access Board publishes the

“Minimum Guidelines and Requirements for Accessible Design” (MGRAD) as the basis for ABA standards

1984 » “Uniform Federal Accessibility

Standards” (UFAS), based on MGRAD, are published by the four federal standard-setting agencies designated to implement the ABA (DOD, GSA, HUD and USPS)

1988 » Congress passes the Fair Housing

Amendments Act, which requires accessible features in certain covered multifamily dwellings

1990 » Congress passes the Americans with Disabilities Act (ADA) which prohibits discrimination on the basis of disability

8GSA National Accessibility Program Ed. 14. 1 of Defense (DoD), the U.S. General Services Administration (GSA), the U.S. Department of Housing and Urban Development (HUD), and the U.S. Postal Service (USPS) as the four federal agencies responsible for creating the accessibility standards that implement the ABA.

Rehabilitation Act The Rehabilitation Act of 1973 prohibits discrimination against persons with disabilities in programs conducted or financially assisted by the U.S. government, federal employment, and federal contractor employment. The Rehabilitation Act also created the U.S. Access Board, to enforce the ABA and to develop and maintain accessible-design guidelines that set the baseline for the ABA’s mandatory standards.

Uniform Federal Accessibility Standards In 1984 the four federal standard-setting agencies—DoD, GSA, HUD, and USPS—published the “Uniform Federal Accessibility Standards” (UFAS) as the first government-wide implementing standard of the ABA. The basis for the common accessibility standard was the “Minimum Guidelines and Requirements for Accessible Design,” or MGRAD, which the United States Access Board published in 1982.

in the private and state and local government sectors, and requires access to programs and services, transportation, the built environment, employment, and communication.

1991 » U.S. Access Board publishes the “ADA Accessibility Guidelines”

(ADAAG) for buildings, facilities and transportation vehicles, which serve as the basis for standards implemented by the Department of Justice and the

Department of Transportation

1991 » Department of Justice adopts

ADAAG as the “ADA Standards for

Accessible Design”

1991 » Department of Transportation

(DOT) publishes “ADA Standards for

Transportation Facilities” and “ADA

Standards for Transportation Vehicles” based on the Access Board’s ADAAG

1992 » Although ADAAG is not applicable to federal facilities, GSA adopts policy of following UFAS or ADAAG requirements— whichever is more stringent—for projects

1998 » U.S. Access Board amends ADAAG to include guidelines for state and local government facilities and building elements designed for children’s use

2000 » U.S. Access Board amends

ADAAG to include guidelines for play areas

2002 » U.S. Access Board amends

ADAAG to include guidelines for recreation facilities

2004 » U.S. Access Board jointly updates ADAAG and its ABA Accessibility

9GSA National Accessibility Program Ed. 14. 1

Later in 1984 GSA issued a policy on accessibility in leased space, because leased facilities were not included in UFAS. For GSA, these two publications required all new, renovated, and leased federal civilian workplaces under its control to be accessible to persons with disabilities.

Americans with Disabilities Act In 1990 Congress passed the Americans with Disabilities Act (ADA), which prohibits discrimination against persons with disabilities in employment, telecommunications, and state and local governments’ activities and services. The ADA also establishes accessibility requirements for the design, construction, and alteration of state and local government facilities and private-sector facilities, namely places of public accommodation and commercial activity. The ADA does not apply to federally owned or leased properties.

Architectural Barriers Act Accessibility Standard (ABAAS) GSA adopted the “Architectural Barriers Act Accessibility Standard” (ABAAS) in 2006 as its new implementing standard for the ABA. It is based on the ADA/ABA Accessibility Guidelines published in the Federal Register by the U.S. Access Board in 2004.

Guidelines, synchronizing their scoping and technical criteria, which are published as the “Americans with Disability Act and

Architectural Barriers Act Accessibility

Guidelines.”

2005 » U.S. Postal Service publishes

“Standards for Facility Accessibility,” based on the ADA-ABA Accessibility Guidelines of 2004

2006 » GSA publishes the “Architectural

Barriers Act Accessibility Standard”

(ABAAS), based on the ADA-ABA

Accessibility Guidelines; ABAAS applies to both owned and leased facilities

2006 » DOT publishes the “ADA Standards for Transportation Facilities,” based on the

ADA-ABA Accessibility Guidelines

2008 » Department of Defense publishes the “ABA Accessibility Standard for

Department of Defense Facilities,” based on the ADA/ABA Accessibility Guidelines

2010 » Department of Justice publishes the “ADA Standards for Accessible Design,” based on the ADA/ABA Accessibility

Guidelines; applies to ADA facilities except for transportation facilities

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New E Street Entrance Doors - GSA Headquarters, Washington, DC

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GSA’S NATIONAL

ACCESSIBILITY PROGRAM

GSA’s long-running National Accessibility Program has focused on providing barrier-free facilities as required by the ABA. In 1969, the agency adopted ANSI A117.1 as its first standard for accessible design; through most of the following decade, GSA’s Public Buildings Service conducted a voluntary program for retrofitting owned and leased facilities to comply with that standard. When a more comprehensive ANSI standard was released in 1980, GSA used it as a basis for creating its “GSA Accessibility Standard,” published later that same year. The “GSA Accessibility Standard” was mandatory for GSA facilities until the development of UFAS and related policy for leased space in 1984.

After passage of the Americans with Disabilities Act in 1990, ADA accessibility standards for commercial and public facilities (ADAAG) were published in July 1991. Although the new standards were not

PROGRAM HISTORY

STANDARDS VERSUS GUIDELINES

Section 502 of the Rehabilitation Act of

1973 established the U.S. Access Board to enforce compliance with the accessibility requirements of the ABA. Congress took another step toward that goal in

1978, when it passed amendments to the Rehabilitation Act that authorized the Access Board to establish minimum guidelines for the standards used to enforce the ABA.

Guidelines are not enforceable until they are formally adopted as standards by the

ABA’s four standard-setting agencies, a group that includes GSA. Under the arrangement established in 1978, in

1982 the U.S. Access Board published

“Minimum Guidelines and Requirements for Accessible Design,” and MGRAD formed the basis of 1984’s “Uniform

Federal Accessibility Standards.” This process was repeated in 2004 when the

Access Board published new accessible-design guidelines in the Federal Register, and two years later GSA adopted them as the “Architectural Barriers Act Accessibility

Standard.”

12GSA National Accessibility Program Ed. 14. 1 applicable to federal facilities, they were in some respects more stringent than UFAS. So a proactive GSA adopted the policy of following UFAS or ADAAG—whichever had the more rigorous requirement—for all new design and construction projects started after July 8, 1992. Other federal agencies soon followed GSA’s lead.

In 2006, GSA adopted the ABA portions of the U.S.

Access Board’s ADA-ABA Accessibility Guidelines as its new accessibility standard for facility design to replace UFAS. This current standard is called the Architectural Barriers Act Accessibility Standard, or ABAAS, and applies to both owned and leased facilities.

It bears repeating that the ADA does not apply to federally owned or leased properties, including GSA’s inventory. ABAAS has the same technical requirements as ADA accessible-design standards, but these standards differ in application, administration, and scoping.

Program Responsibilities GSA’s National Accessibility Program resides in the Office of the Chief Architect. The program is managed by a National Accessibility Officer and implemented by 11 Regional Accessibility Officers. The program is responsible for ensuring that ABAAS requirements

The whole arc of guidelines and standards points upward. Accessibility standards in the United States have evolved and greatly improved over time. ANSI A117.1 presented rudimentary technical requirements, but lacked details like the dimensions of accessible toilet stalls and parking spaces, and contained no scoping requirements.

Current standards provide scoping and technical requirements that reflect an enlightened understanding of the needs of persons with disabilities.

http://www.access-board.gov/guidelines-and-standards/buildings-and-sites/about-the-aba-standards/aba-standards http://www.access-board.gov/guidelines-and-standards/buildings-and-sites/about-the-aba-standards/aba-standards

13GSA National Accessibility Program Ed. 14. 1 are incorporated into the designs of all new, altered, and leased facilities. View complete listing of Accessibility Officers.

In addition, GSA’s National Accessibility Program manages the accessibility complaint process for GSA’s owned and leased facilities; sets accessibility policy; and interprets ABAAS for GSA staff, government tenant agencies, architects, designers, private citizens, and accessibility organizations.

The program’s National Accessibility Officer also specifically serves as the GSA liaison to the U.S.

Access Board. The Rehabilitation Act of 1973 establishes GSA’s Administrator as a permanent member of its governing board, and the National Accessibility Officer is responsible for briefing the Administrator or his or her designee on relevant accessibility issues prior to board meetings. The National Accessibility Officer serves as a non-voting proxy for the Administrator or designee at board meetings in case of his or her absence, as well. The Administrator looks to the Office of the Chief Architect and the National Accessibility Program for guidance on the subject generally.

http://www.gsa.gov/portal/category/21630 http://www.gsa.gov/portal/category/21630

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Entrance Ramp - Department of Transportation Headquarters, Washington, DC

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U.S. ACCESS BOARD

Several years after the 1968 passage of the Architectural Barriers Act, Congress observed that compliance had been uneven, and that the four federal agencies designated by the ABA to implement federal standards for accessibility had not created them. Consequently, when Congress considered the Rehabilitation Act of 1973, it conceived a separate federal agency to enforce the ABA and expedite development of accessible-design standards for implementation. Section 502 of this law established the U.S. Access Board to ensure federal compliance with the ABA and to propose solutions to environmental barriers addressed in the ABA.

The Access Board is devoted to accessibility for persons with disabilities. It has a permanent staff of approximately 30 federal employees, and a 25-person governing board whose membership comprises 12 federal agency representatives and 13

4A. ITS COMPOSITION AND PURPOSE

http://www.access-board.gov/

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Presidential appointees serving 4-year terms on a rotating basis.

GSA’s Administrator, or his or her designee, fills one of the 12 federal slots of the governing board;

a majority of the 13 Presidential appointees must have a disability. The governing board oversees the Access Board’s mission, priorities, budget, research programs, and development of accessible-design guidelines and outreach goals.

Today the Access Board is responsible for accessible-design guidelines for the built environment, transportation vehicles, and telecommunications equipment, and accessibility standards for electronic and information technology and medical diagnostic equipment under a variety of laws, including the ABA and ADA. It provides technical assistance and training for all these design criteria, and enforces the implementing standards of the ABA for federally funded facilities.

The Access Board does not oversee or enforce Section 504 of the Rehabilitation Act, which protects qualified individuals from disability-based discrimination in federally conducted or federally funded programs. These requirements are set by individual agencies and enforcement is coordinated and overseen by the Department of Justice.

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The Access Board functions as a coordinating body among federal agencies. It also directly represents the public, particularly persons with disabilities, through its website and presentations, as well as formal meetings that are often attended by representatives of various disability advocacy groups.

4B. THE ACCESS BOARD AND ABA

ACCESSIBLE-DESIGN CRITERIA

A key mission of the Access Board is establishing accessible-design criteria for buildings and facilities, and it is continually developing or updating these criteria. Since 1978, the Access Board has been responsible for issuing accessible-design guidelines for federally funded facilities.

In 1990 that role expanded after Congress passed the Americans with Disabilities Act, which empowered the Board to develop accessible design guidelines for state and local government facilities, places of public accommodation, commercial facilities, and transportation facilities and vehicles. Subsequent laws passed by Congress further expanded the board’s mission to cover access to telecommunications equipment, electronic and information technology in the federal sector, and medical diagnostic equipment.

ABA Enforcement The ABA compliance process emphasizes informal

18GSA National Accessibility Program Ed. 14. 1 resolution. When informal resolution cannot be achieved, the Access Board can initiate formal proceedings before an administrative law judge to obtain an order of compliance. For GSA properties, penalties for non-compliance can include withholding or suspension of federal funds with respect to the building or facility found to be non-compliant with the agency’s Architectural Barriers Act Accessibility Standard (ABAAS). Penalties can be imposed in proportion to the level of non-compliance found.

ABA Information Assistance The U.S. Access Board provides information about the ABA by telephone, fax, or email. Design professionals and others can contact the Access Board for general information, as well as technical assistance concerning specific ABA requirements, including those contained in ABAAS—GSA’s current implementing standard of the ABA.

Contact the Access Board at:

Phone (voice): (202) 272-0080 toll free: (800) 872-2253 Phone (TTY): (202) 272-0082 toll free: (800) 993-2822 Fax: (202) 272-0081 Email: TA@access-board.gov Information about the Access Board and its current activities may be found at http://www.access-board.gov mailto:TA%40access-board.gov?subject=

19GSA National Accessibility Program Ed. 14. 1

Training The Access Board provides training on all of its guidelines and standards to various groups and organizations at locations across the country.

Training may cover accessible-design requirements for private, state and local government facilities, federal facilities, telecommunications equipment, and electronic and information technology.

The Access Board tailors training to the needs and interests of each audience. It is a particularly valuable resource to designers and architects, facility operators and managers, transportation professionals, disability advocates, and members of other professions and groups that work with any of the Board’s guidelines and standards. In Board training sessions, time is typically reserved for question-and-answer segments. This kind of interaction helps the Access Board to gauge the information needs of various audiences.

Training sessions are held at the request of, or in partnership with, organizations or groups holding conferences and seminars whose agendas include accessibility, the ABA, or the ADA. Due to budget constraints, the Access Board usually requests reimbursement of travel costs for its participation.

Board policy requires that these events be conducted in accessible facilities, with accessible communication

20GSA National Accessibility Program Ed. 14. 1 formats upon request. The Access Board often arranges additional training sessions once it is scheduled to be in a particular area.

For more information or to request training from the Board, contact the Board’s Training Coordinator at training@access-board.gov (email), (202) 272-0017 (voice) or (202) 272-0082 (TTY).

Virtual Training AccessibilityOnline represents a collaborative training program between the ADA National Network and the Access Board. The program includes a series of free webinars and audio conferences held on a monthly basis, on a variety of topics concerning accessibility in the built environment, information and communication technologies, and transportation.

They are coordinated and hosted by the Great Lakes ADA Center on behalf of the ADA National Network as a mechanism to provide accurate and quality training on ADA accessible-design guidelines, ABA accessible-design guidelines, and electronic and information technology accessibility standards (Section 508).

Archived copies of previous Board webinars are available on the webinar site. Webinar attendees can also earn continuing education credits (CEUs).

mailto:training%40access-board.gov?subject= http://www.accessibilityonline.org/ http://adata.org/ http://www.access-board.gov/ http://www.adagreatlakes.org/ http://www.adagreatlakes.org/

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Approach to Main Entrance - United States Courthouse, Cedar Rapids, Iowa

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ACCESSIBLE FACILITY

DESIGN PROCESS

Successful integration of accessibility into the design process requires a project team to carefully consider synergies across disciplines from a project’s earliest stages.

A project team must also foresee conflicts because sustainability, historic preservation, security, and visual expression can compete with and sometimes interfere with goals of accessible design. The following are a few examples involving GSA property types:

· Sustainable energy performance:

A new federal courthouse has lowered office and corridor lighting power density, as mandated by an Executive Order to reduce energy consumption.

Building occupants and visitors with low vision are adversely affected by the requirements, because they require brighter lighting.

5A. IDENTIFYING CONFLICTING GOALS

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· Sustainable stormwater management:

A parking lot for a new federal building is designed with pervious pavers to help meet stormwater-management goals. The openings between pavers measure 5/8 inch. The architect is unaware that ABAAS Section 302.3 (Floor and Ground Surfaces, Openings) requires a maximum opening of 1/2 inch along the accessible route to the building.

· Historic preservation:

A historic federal building has a monumental entrance raised 5 feet above grade, accessible only by stairs. The State Historic Preservation Officer has determined that altering the entrance to include a wheelchair ramp would destroy historic fabric, and instead supports an option to convert a window opening near grade, adjacent to the main entrance, into a wheelchair lift. GSA, meanwhile, objects to the cost of that option, although the lift would allow disabled persons to experience the historic building lobby like their able-bodied counterparts.

In this case, ABAAS Section F206.4 (Entrances) provides an exception that allows an alternative existing locked entrance with a notification system to provide access. The locked entrance is selected as a “no cost” option, although persons with disabilities will have a diminished entry experience.

· Security:

A new federal courthouse has 4-foot-square security planters installed at the site perimeter, spaced 2 feet, 10 inches apart. The planters that

24GSA National Accessibility Program Ed. 14. 1 intersect the accessible route into the building are in violation of ABAAS Section 403.5.1 (Clearances, Clear Width), which requires a minimum clearance of 3 feet between planters crossing the accessible route

· Visual expression:

For a new federal building located on a steeply sloping site, the entrance location requires pedestrians to negotiate a 10-foot grade change from a street-level public transit stop. The architect has designed a series of landscaped terraces and stairs to transition from street level to the entry plaza, but has used an enclosed elevator to accommodate persons with disabilities, because ramps would “compromise” the intended visual expression. Two months after opening, mechanical problems force the elevator out of service.

5B. DESIGN REVIEWS

Design Reviews in GSA’s Regions By working together from a project’s concept phase to synergize program goals and identify potential conflicts, a project team can produce a thoughtful, successful project for all stakeholders. GSA’s Regional Accessibility Officers support this collaboration by conducting accessible-facility design reviews at regular intervals in a project’s evolution.

Minimizing a building or facility’s accessible-design concerns, for the Regional Accessibility Officer, begins in early design phases. The following points clarify

25GSA National Accessibility Program Ed. 14. 1 when an officer should conduct reviews with a project team, and their associated activities:

· Design narrative:

The Regional Accessibility Officer verifies that design narrative documents reference the current edition of the PBS-P100 (Facilities Standards for the Public Buildings Service) and ABAAS, instead of obsolete standards like ANSI A117.1, and removes references to ADAAG and the ADA.

· Concept development:

Because these rudimentary plans often lack sufficient detail to make specific comments on accessibility features, the Regional Accessibility Officer provides general comments concerning the facility’s design. This feedback may cover accessible route and accessible parking, building elements and spaces including entrances, horizontal and vertical circulation, and toilet rooms.

· Design development:

Drawings at this phase provide enough detail for accessible design review to guide a project team’s design toward conformance with ABAAS and the PBS-P100. The Regional Accessibility Officer references specific sections of both documents as technical validation for comments.

Comments may cover design elements including: surface parking lot layouts, exterior accessible routes, parking garage layouts, entrance/security details, interior door

26GSA National Accessibility Program Ed. 14. 1 widths and maneuvering clearances, toilet rooms, locker/shower rooms, break rooms, service counters and work surfaces, courtrooms, holding cells, and laboratory layouts.

The Regional Accessibility Officer continues conducting accessible design reviews of contract documents to verify that the pending building or facility embodies the accessible design requirements mandated by ABAAS and the PBS-P100. Review intervals include:

· 60 percent:

At this level of design, primary accessibility features like parking, accessible route to the building, entrances, elevators and toilet rooms, locker/shower rooms, kitchenettes, accessible seating and assistive listening in places of assembly, and courtroom stations and spectator seating should be sufficiently detailed. The Regional Accessibility Officer conducts an in-depth review of these features in turn.

· 90 percent:

The Regional Accessibility Officer performs a final check, to make sure changes have not affected accessibility since the 60 percent review. If such design changes have occurred, the officer will review specific elements for conformance with ABAAS.

Integrated Design Reviews at GSA Central Office GSA Central Office also participates in ensuring that an evolving building or facility design minimizes accessible-

27GSA National Accessibility Program Ed. 14. 1 design issues and synergizes program goals. It does so through Integrated Design Reviews, which are conducted by GSA’s Office of Design and Construction. Accessible design is an essential part of the Integrated Design Review.

Currently, this process focuses on a project’s concept documents prior to their final presentation to the Commissioner of the Public Buildings Service. It is under further development, both at GSA Central Office and the agency’s regional offices; ultimately reviews will take place at intervals from the concept phase through contract documents.

THE DESIGN PROCESS IN CONTEXT

GSA advocates accessibility awareness from the earliest phases of design. To this end, the agency empowers its Regional

Accessibility Officers to conduct accessi-bility design reviews over a project’s evolu-tion. Moreover, it has introduced Integrat-ed Design Reviews to ensure, among other policies, that a project accommodates persons with disabilities and all stakeholders holistically.

GSA’s actions evidence an indus-try-wide move toward integrated project delivery (IPD). As the American Institute of Architects describes it, IPD “leverages early contributions of knowledge and expertise through the utilization of new technologies, allowing all team members to better realize their highest potentials while expanding the value they provide throughout the project lifecycle.”

This definition of IPD relies partly on software platforms, like BIM, by which many skilled practitioners can communi-cate and reconcile individual design and construction decisions. Yet IPD is valid even without a specific technology at a team’s disposal. At its core IPD is collabo-ration in which team members contribute their individual expertise to a problem from the outset of design; exchange ideas in an ongoing manner; and make decisions collectively.

IPD begins in properly defining a prob-lem and identifying limiting conditions and potential outcomes. Once actual design has started, integrated delivery is distinguished by regular feedback that allows the specific expertise of each member to come to the fore, to ensure that the team is addressing as many con-cerns as possible. Although design has always been a non-linear undertaking— new data can send a team “back to the drawing board,” after all—IPD depends on open communication and eschews hierarchy. The process, and its culture of trust and sharing, precludes waste and maximizes solutions.

IPD officially describes the collaboration of a design-and-construction team, and can also refer to a contractual agreement.

As described here, GSA stewards its design and construction teams in the spirit of

IPD. Readers should consult RFPs and standards publications for the latest agency directives about IPD in project delivery.

28GSA National Accessibility Program Ed. 14. 1

Entrance Ramp - United States Courthouse Annex, San Diego, California

29GSA National Accessibility Program Ed. 14. 1

ABA MODIFICATION

AND WAIVER REQUESTS

Section 6 of the Architectural Barriers Act authorizes GSA’s Administrator “to modify or waive on a case-by-case basis, upon application made by the head of department, agency, or instrumentality of the United States concerned,” any ABA standard for the design, construction, and alteration of GSA’s owned and leased buildings and facilities when “clearly necessary.” This authority has been delegated by the Administrator to the Commissioner of GSA’s Public Buildings Service.

In addition, Section 502(b)(1) of the Rehabilitation Act of 1973 authorizes the United States Access Board, as enforcer of the ABA, to review all of GSA’s approved modifications and waivers to make sure they are based on fact and consistent with the ABA.

Modifications and waivers ostensibly do not apply to new construction. More generally, they are approved

6A. EXCEPTIONAL CONDITIONS

30GSA National Accessibility Program Ed. 14. 1 only in rare circumstances, and only after GSA and its tenant agencies have made extensive efforts to comply with the ABA. GSA does not condone circumventing the accessibility mandate.

6B. MODIFICATION

A modification is an authorized written change to a specific requirement in an ABA standard.

Modifications may be utilized when applying the standard as written is technically infeasible, but basic accessibility can be provided if a less stringent standard is applied.

For example, a GSA building that is on the National Register of Historic Places and is being altered has an existing door opening with a swinging door and a clear width of 31.20 inches located on the accessible route, and the doorway is classified as part of the historic fabric of the building. ABAAS Section 404.2.3 (Manual Doors, Doorways, and Manual Gates, Clear Width) requires that “Doorways shall provide a clear opening width of 32 inches (815 mm) minimum. Clear openings of doorways with swinging doors shall be measured between the face of the door and the stop, with the door open 90 degrees.” In alterations, a projection of 5/8 inch (0.62 inches) into the required clear opening width is permitted by the standard for the latch side stop (see Exception 1). However, modifying the standard http://www.nps.gov/nr/ http://www.nps.gov/nr/

31GSA National Accessibility Program Ed. 14. 1 to allow the existing clear opening width may be the only option in this case because alteration of the historic fabric is not acceptable under the Historic Preservation Act.

6C. WAIVER

A waiver grants temporary authority to not comply with a specific requirement in the ABA standard.

These written determinations are only granted after every effort has been made to comply with the standard.

A waiver may be issued to recognize an existing condition that cannot provide basic accessibility, such as a site whose gradient prevents access to one of two public entrances. In this example, one public entrance of a new federal building is accessible, while the other requires the use of a series of stairs and landings to traverse a 45 degree slope, and an accessible design evaluation has determined that a series of switch back ramps and three wheelchair lifts would be needed to make it accessible because the site does not have adequate space for the use of ramps alone. The necessity for three wheelchair lifts makes it highly probable that at least one will be out of service at any given time, eliminating the accessible route. For GSA buildings, ABAAS Section F206.4.1 (Public Entrances) states that at least 60 percent

32GSA National Accessibility Program Ed. 14. 1 of all public entrances must be accessible. In this example, ABAAS requires two accessible public entrances, so a waiver of Section F206.4.1 would be requested for the non-accessible entrance.

Procedures for Submitting Modification and Waiver Requests 1 Inquiries concerning modifications and waivers may be initiated through GSA’s National Accessibility Officer or a Regional Accessibility Officer. After review and discussions with the National Accessibility Officer, the requestor— as per the ABA, “the head of department, agency, or instrumentality of the United States concerned”—then drafts a letter of request for a modification or waiver and submits it to the Commissioner of GSA’s Public Buildings Service.

The request must include all of the following items:

a. Date of request

b. Purpose of request, specifying waive or modification as well as the ABAAS requirement(s) to which the request pertains

c. Description and support for request, including conditions that affect accessibility and alternative solutions that have been considered

d. Consequence if no modification or waiver is permitted

e. Conclusion, including contact details for additional information requests

33GSA National Accessibility Program Ed. 14. 1

f. Photographs and available drawings for documentation

g. Other attachments/enclosures of any supporting information (copies of codes, etc.)

h. Signature and agency of requestor 2 This letter is forwarded to the National

Accessibility Officer, who reviews it and prepares a memo recommending the PBS Commissioner’s approval/denial

3 The PBS Commissioner reviews the memo;

documentation of the Commissioner’s approval/denial is returned to the National Accessibility Officer, also via memo

4 The National Accessibility Officer drafts an outgoing letter informing the requestor of the decision, for the Commissioner’s signature

5 The draft is forwarded to the PBS Commissioner’s correspondence control group for review of formatting and other non-content issues. After review by the National Accessibility Officer, the final draft with photographs, floor plans, or other appropriate attachments is forwarded to the Commissioner for signature. The final, signed letter is then sent to the requestor and copied to the United States Access Board

34GSA National Accessibility Program Ed. 14. 1

District Courtroom - United States Courthouse, Salt Lake City, Utah

35GSA National Accessibility Program Ed. 14. 1

ACCESS BOARD

COMPLAINTS

Ensuring access for persons with disabilities is financially manageable when it is included from the earliest phases of new construction, modernizations, and alterations. The opposite may be true when accessibility is ignored, and ABA complaints are filed with the U.S. Access Board after construction completion.

The most common accessibility complaints concern accessible routes, parking, entrances, interior doors, and toilet rooms. A user of a federally owned or leased property or a federal employee or contractor submits an accessibility complaint to the U.S. Access Board via the online complaint form or by email, standard mail, or fax. The complaint must contain the name and address of the building or facility and a brief description of the access problems.

7A. INTRODUCTION

http://www.access-board.gov/enforcement/complaint.html

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Additional information such as the property’s age, known sources of funding, and photographs may be included, but is not necessary. Complaints can be made anonymously, although in all cases a complainant’s name and contact information is kept confidential.

The Access Board makes a preliminary analysis of the complaint to determine whether the complaint could be covered by the ABA. If so, the board opens a complaint investigation and sends the complainant an acknowledgment letter. If the Access Board determines that the ABA does not apply to the given case, it does not open a complaint and sends the complainant a letter presenting its findings and referral information.

7B. GSA RESPONSE PROCEDURES

If a complaint is submitted against a GSA-owned or -leased property and preliminary analysis determines the complaint could be covered by the ABA, then the Access Board mails a copy of the complaint documentation to GSA’s Deputy Administrator. Hereafter, the GSA Deputy Administrator will be known as the addressee.

Historically, the addressee’s correspondence control group has delegated official responsibility for Access Board complaints to the Commissioner of GSA’s Public Buildings Service.

37GSA National Accessibility Program Ed. 14. 1

Because accessibility expertise at GSA is housed within the Office of the Chief Architect, the Access Board also emails a copy of this documentation to the National Accessibility Officer. The National Accessibility Officer is entrusted with expediting a response from the PBS Commissioner, the signed final draft of which is copied to the addressee.

1 Complaint documents comprise a letter of inquiry, the complaint allegations, and a questionnaire that contains a three-part test:

a. Was the building or facility designed, built, or altered by or on behalf of the United States after August 12, 1968?

b. Is the building or facility leased, in whole or in part, by the United States?

c. Was the building or facility constructed in whole or in part with funds from a grant or loan made by the United States after August 12, 1968?

If the answer to any question is yes, then the building or facility is covered by the ABA.

In the complaint letter, the addressee is required to provide the completed questionnaire to the Access Board’s Office of the General Counsel within 30 days, in order to help the Access Board make a determination as to whether the facility named in the complaint is subject to the ABA. In reality, GSA’s

38GSA National Accessibility Program Ed. 14. 1 standard operating procedure is for the National Accessibility Officer to check the Asset Business Plan database to determine whether the cited property is in GSA’s inventory, as well as its age. If further information is required before a determination can be made, the National Accessibility Officer will ask Regional Accessibility Officers for assistance.

The National Accessibility Officer then discusses these findings with the Access Board’s Office of the General Counsel and proceeds to investigate the complaint allegations in cases of ABA applicability.

The questionnaire is just one component of GSA’s response to the Access Board, the preparation of which is outlined in steps 2 through 5 below

2 The National Accessibility Officer prepares a file that includes a printed copy of the complaint and survey form, and forwards the electronic copies of the Access Board’s complaint documents with a cover email to the Regional Accessibility Officer

3 The National Accessibility Officer and Regional Accessibility Officer collaborate to resolve the following preliminary questions:

a. Is the subject of the complaint under GSA’s jurisdiction? Sometimes the building that is the subject of the complaint is actually owned or leased by one of the other standard-setting agencies (USPS, DoD, or HUD). Complaints can also involve facilities that are not federal, 39GSA National Accessibility Program Ed. 14. 1 such as: a state courthouse the complainant had assumed was built with federal funds;

on-street parking spaces and sidewalks under the control of a local jurisdiction; and inaccessible restrooms in the public lobby area of a building that are not included in a federal lease

b. Is the building subject to the ABA? This is based on factors that include: owned or leased status; construction start date; whether the subject property is non-federal and was constructed with funds from a federal grant or loan; history of alterations

c. Is there a valid ABA complaint? The facility may be compliant, but the complainant may not be aware of the applicable accessibility standards

4 If the complaint is valid, then it must be resolved at the earliest possible date. The resolution process begins with an email report, sent by the Regional Accessibility Officer to the National Accessibility Officer. This report investigates the complaint allegations, verifies them as fact, and can include digital photos, floor plans,and field measurements if required. After reviewing the report and discussing it with the Regional Accessibility Officer, the National Accessibility Officer may request additional information. Once all the necessary information is provided, the

40GSA National Accessibility Program Ed. 14. 1

National Accessibility Officer drafts a response to the complaint for the signature of the Commissioner of GSA’s Public Buildings Service and reviews it with the Regional Accessibility Officer. This response must include:

a. Description of the complaint

b. Summary of the investigation findings, which includes site and floor plans, field measurements, and digital photos if applicable

c. Determination whether the subject of the complaint complies with the ABA standard, with references to specific sections of ABAAS

d. A corrective action plan for addressing the ABA violations, preferably with milestones included, that has been coordinated with the GSA regional office

e. The completed questionnaire intended for the

Access Board’s Office of the General Counsel 5 The draft is forwarded to the PBS Commissioner’s correspondence control group for review of formatting and other non-content issues, and for review by the Office of the General Counsel.

After any required revisions are made, the draft is reviewed by the National Accessibility Officer, and the final draft with completed questionnaire and appropriate attachments is forwarded to the Commissioner for signature. The final, signed letter is then sent to the Access Board and copied to the addressee

41GSA National Accessibility Program Ed. 14. 1

6 The Access Board reviews the response. If issues remain, the Access Board sends a letter to GSA requesting additional information

7 Once all issues are resolved, including any corrective action, the Access Board submits written notification to the complainant that complaint issues have been addressed and that the complainant has 15 days to notify the Access Board of any outstanding issues

8 If there is no response from the complainant,the Access Board sends a letter to GSA’s National Accessibility Officer, which states that the complaint is closed.