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Door Maneuvering Clearances and the FHA

Noob

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Mar 8, 2019
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35
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Texas
I'm about waist deep into the infuriating FHA Design Manual.

Can anyone explain to me why, within an accessible unit, the requirements for maneuvering clearances is split between "Accessible Doors" and "Usable Doors"? If I were an architect renting an apartment and a wheelchair user and found this out, I would be angry!

For one, you are denying accessibility within the dwelling unit. We KNOW these clearances in the ADA have been tested / verified to provide accessibility. Feels alot like legalized discrimination to me.

Two, you are adding more layers of complexity to the requirements, which just creates more potential for a "gotcha" moment with the ADA lawyers.

But, I think I've answered my own question here, I'm going to design all doors to ADA maneuvering clearances - because it's the right thing to do, both legally and ethically. I'm not widdling down square footage for some developer "just because" he's counting his pennies, someone in a wheelchair deserves the same usability as someone without one, if it's 20 more square feet in the unit, so be it.
 
I'm about waist deep into the infuriating FHA Design Manual.

Can anyone explain to me why, within an accessible unit, the requirements for maneuvering clearances is split between "Accessible Doors" and "Usable Doors"? If I were an architect renting an apartment and a wheelchair user and found this out, I would be angry!

For one, you are denying accessibility within the dwelling unit. We KNOW these clearances in the ADA have been tested / verified to provide accessibility. Feels alot like legalized discrimination to me.

Two, you are adding more layers of complexity to the requirements, which just creates more potential for a "gotcha" moment with the ADA lawyers.

But, I think I've answered my own question here, I'm going to design all doors to ADA maneuvering clearances - because it's the right thing to do, both legally and ethically. I'm not widdling down square footage for some developer "just because" he's counting his pennies, someone in a wheelchair deserves the same usability as someone without one, if it's 20 more square feet in the unit, so be it.
Enjoy unemployment.
 
A door must have a 32-inch clear width to make it "usable." However, not all doors within a dwelling unit are required to be accessible. In most cases, only the primary entrance door is required to be accessible (i.e., it provides the minimum clear width plus maneuvering clearances, hardware, and opening force). I believe Chapter 3 clearly explains this. Only "covered" units are required to comply with the FHA Guidelines; however, the IBC (with ICC A117.1) requires a certain number of units to be Type A units, which require a higher level of compliance and doors "intended for user passage" must comply with the accessible door requirements.
 
Not all people with disabilities have the same needs for maneuvering space. Many people have compact wheelchairs that can spin around in a 36" or 42" space. Some people don't need a chair inside their homes. They use a cane or crutches, or they lean on walls.

The FHA Design Manual was scoped for to help make the vast majority of covered multifamily housing increase accessibility without significantly enlarging the overall unit area or significantly impacting project cost. It is a utilitarian "greatest good for the greatest number" calculation.
Within that set of FHA units, the ADA Standards provide for much greater accessibility, but it is only required for 5% of the units.

Several years ago I did an exercise comparing FHA vs. ADA for a one-bedroom apartment. The ADA unit with its large kitchen and bathroom required about 10% more area, accounting for furnishings, etc. That means you could build 10 ADA units, or for the same area you could build 11 FHA units. Now picture that applied to an area like LA County, where (pre-fire) we had 50,000+ homeless. What would it mean to get 10% more units online to get people off the streets? Yes, that is "counting the pennies", but it's to maximize housing solutions, not merely to line the developer's pockets.

A one bedroom unit has essentially no hallway. An interesting thing happens when you go to 2-, 3-, and 4- bedroom ADA units: the hallway gets massive in width in order to achieve door clearances, taking away valuable living space for the sake of circulation.

I've done a lot of rehabs and adaptive reuse projects for public housing where the units had to be upgraded for ADA compliance. Most of the residents, even those in wheelchairs, HATE the "upgrades". The lose under-sink storage space in kitchens and baths. They lose their range hood/ microwave combo. They lose furniture layout space. Their bathtubs are too tall to step over.
Etc.

All I'm saying is, don't assume ADA Standards are always the best practice for every living situation.
 
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I'm about waist deep into the infuriating FHA Design Manual.

Can anyone explain to me why, within an accessible unit, the requirements for maneuvering clearances is split between "Accessible Doors" and "Usable Doors"? If I were an architect renting an apartment and a wheelchair user and found this out, I would be angry!

For one, you are denying accessibility within the dwelling unit. We KNOW these clearances in the ADA have been tested / verified to provide accessibility. Feels alot like legalized discrimination to me.

Two, you are adding more layers of complexity to the requirements, which just creates more potential for a "gotcha" moment with the ADA lawyers.

But, I think I've answered my own question here, I'm going to design all doors to ADA maneuvering clearances - because it's the right thing to do, both legally and ethically. I'm not widdling down square footage for some developer "just because" he's counting his pennies, someone in a wheelchair deserves the same usability as someone without one, if it's 20 more square feet in the unit, so be it.
The FHA Design Manual is not the enforcing document for FHA covered housing. The FHA's enforcing document is the 24 CFR Ch. 1. Final Fair Housing Accessibility Guidelines. Published on March 16th, 1991. Congress mandated that the FHA accessibility standard is the Rules and Regulations and the 1986 ANSI A117.1 accessibility standard. The FHA is an illustrated design manual with good illustrations, but it is not the final word. FHA accepts the standard 34" wide doors through-out the covered residence. For public common area doors and gates, you would apply the ANSI A117.1 1986. Hope this helps.
 
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