2010 ADA -- Emergency Response Personnel

[alora]

Anyone hear of any further decisions/data on the following excerpt from "Guidance on the 2010 ADA Standards for Accessible Design"?

Have a current project involving a major renovation (removing all interior elements/FFE) of an existing fire station. Just notified that new interior concrete slab at HC shower stalls was poured level with existing finish floor instead of sloped toward the drain as called out on the CDs.

I'm curious if there's any information (based on the 'guidance' verbiage) that might allow a raised curb at shower stall entry for this type of facility in lieu of the 1/2" maximum.

This project falls under UFC and its referenced ABA for DOD facilities. From the looks of it, ABA is similar in its requirements to the ADA, particularly in the shower thresholds section.

Ultimately, the GC can be required to re-do the work to comply with the CDs.

Thank you for any information.

§ 35.151(d) Scope of coverage:

... The Department received one additional comment on this issue from an organization representing emergency response personnel seeking an exemption from the transient lodging accessibility requirements for crew quarters and common use areas serving those crew quarters (e.g., locker rooms, exercise rooms, day room) that are used exclusively by on-duty emergency response personnel and that are not used for any public purpose. The commenter argued that since emergency response personnel must meet certain physical qualifications that have the effect of exempting persons with mobility disabilities, there is no need to build crew quarters and common use areas serving those crew quarters to meet the 2004 ADAAG. In addition, the commenter argued that applying the transient lodging standards would impose significant costs and create living space that is less usable for most emergency response personnel.The ADA does not exempt spaces because of a belief or policy that excludes persons with disabilities from certain work. However, the Department believes that crew quarters that are used exclusively as a residence by emergency response personnel and the kitchens and bathrooms exclusively serving those quarters are more like residential dwelling units and are therefore covered by the residential dwelling standards in the 2010 Standards, not the transient lodging standards. The residential dwelling standards address most of the concerns of the commenter. For example, the commenter was concerned that sinks in kitchens and lavatories in bathrooms that are accessible under the transient lodging standards would be too low to be comfortably used by emergency response personnel. The residential dwelling standards allow such features to be adaptable so that they would not have to be lowered until accessibility was needed. Similarly, grab bars and shower seats would not have to be installed at the time of construction provided that reinforcement has been installed in walls and located so as to permit their installation at a later date.

 

[brudgers]

comply with the CDs.

That needs to be your position. If the Owner chooses to do otherwise, then they own any future problem. If you say it's ok, you've got liability - both contractually and based on Civil Rights.

 

[TJacobs]

It just boggles my mind that people are still trying to wiggle out of this. I can possibly see it for existing "impractical", but certainly not new construction.

 

[alora]

That needs to be your position. If the Owner chooses to do otherwise, then they own any future problem. If you say it's ok, you've got liability - both contractually and based on Civil Rights.

Understood.

Owner, User & I were made aware of problem quickly and at the same time.

Just happened to remember this point about emergency response personnel while skimming through the new ADA.

We're all inclined to require the GC to re-do the work; especially, with the potential of dealing with 3 shifts of 20 firemen/shift.

 

[alora]

It just boggles my mind that people are still trying to wiggle out of this. I can possibly see it for existing "impractical", but certainly not new construction.

You mean, "technically infeasible"?

I know. It's a daunting phrase.

 

[Coug Dad]

Under the Department of Defense / UFC process, the command is allowed to classify areas as occupied by able bodied service personel only and the accessibility provisions do not apply. Has this classification been made?

 

[alora]

Under the Department of Defense / UFC process, the command is allowed to classify areas as occupied by able bodied service personel only and the accessibility provisions do not apply. Has this classification been made?

Thought about that.

However, the UFC references I've found deal primarily with Marine facilities, Naval facilities and entry control facilities/buildings. None of these seem to apply here.

Do you have a specific UFC section in mind?

This fire station, located on DOD premises, serves the 'on-site' facilities as well as nearby 'off-site' public/private structures.

 

[Coug Dad]

UFC 1-200-01

16 August 2010

2-11 CHAPTER 11 – ACCESSIBILITY

Use the ABA Accessibility Standard for Department of Defense Facilities as adopted by the Deputy Secretary of Defense memorandum dated October 31, 2008, in lieu of IBC Chapter 11.

 

[alora]

UFC 1-200-0116 August 2010

2-11 CHAPTER 11 – ACCESSIBILITY

Use the ABA Accessibility Standard for Department of Defense Facilities as adopted by the Deputy Secretary of Defense memorandum dated October 31, 2008, in lieu of IBC Chapter 11.

Yes, made note of that in the OP.

ABA has same 1/2" threshold requirement as ADA.

 

[Coug Dad]

But, is the building required to be accessible per DOD standards?

 

[alora]

But, is the building required to be accessible per DOD standards?

Yes it is.