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Indoor play equipment accessibility

cburgess

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Sep 4, 2013
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18
Location
Indianapolis
In my role as a state building official, a dispute has come to our attention over an accessibility issue. I'd like others' thoughts on it.

A new two-story school building for small children is under construction. A portion of the building's first floor is open through the second floor to the roof. On the second floor, that open-to-below area is bound by a compliant guard railing. The designer has placed a tubular spiral playground slide in that open area, from the second floor down to the first. It is accessed by a hole in the second floor guard rail system. There is an elevator to the second floor located immediately adjacent to the slide.

The local official has cited this slide as not complying with the building code's Section 1103.1 for general accessibility (our current code is based on the 2012 model). He has provided no information as to how he believes it falls short of the mark.

So the questions before me are these:
  • Is the device really noncompliant with 1103.1? There's an elevator to the top.
  • If it really is noncompliant, does that presuppose that an accessible version exists, or that one can be created? And how would it be different? What does an accessible tubular spiral slide look like? Or would it simply need to be removed completely?
  • The building code doesn't regulate outdoor playgrounds. Does it regulate indoor ones?
  • How is this device any different from a piece of furniture that's ungoverned by the code? It's not a part of the building in the same way a doorway or set of stairs are.
Keep in mind this has nothing at all to do with ADA. There may well be ADA implications, but they're not for me to consider. Our rules and enforcement authority are limited strictly to state regulations, and those are the building codes. All I can consider is the code and, by reference, the ICC/ANSI A117.1-2009 regulations.

Thanks in advance for any thoughts you might have.
 

classicT

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Aug 2, 2017
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Washington State
My take on the A117.1 regulation is that it requires an accessible route to the components. It does not require that the components be fully accessible. I would further say that a slide is an elevated play component, and therefore the only real code section from the A117.1 is 1108.3.2.2.

As an elevator is provided, the slide is on an accessible route.

1108.3.2.2 Elevated Play Components
Where elevated play components are provided, at least 50 percent shall be on an accessible route and shall comply with Section 1108.4.3.
 

ADAguy

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Sep 11, 2013
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Here we have an insensitivity issue. It may not be in code/ANSI but the experience cannot be denied to those with disabilities.
Swings have been adapted for WC users, this must be too or face the consequences of a parent.
 

classicT

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Here we have an insensitivity issue. It may not be in code/ANSI but the experience cannot be denied to those with disabilities.
Swings have been adapted for WC users, this must be too or face the consequences of a parent.
Sensitivity issues are not up to a local code official. Code officials should stick to the code; that's the job.

Aside from the "insensitivity" and the "consequences of a parent", what would you suggest? Every slide in the world be made accessible? Not even remotely possible. The nature of a slide requires that it be confined to a limited space for the safety of the slider. I can't imagine what would be necessary to make a slide fully accessible.

Accessibility is about providing as many accommodations as possible, within reason. Accessibility is not intend to fix the world, but to show grace and understanding to those with mobility limitations.

Sorry for the rant... but saying "the experience cannot be denied to those with disabilities" is wrong. We (the world, code officials, etc.) are attempting to show the grace and understanding I mentioned, but it needs to be reasonable and should not remove the ability for those without a disability to enjoy a fixture or feature.

The answer should never be, it is not accessible and therefore it is not allowed. Almost becomes a reverse form of discrimination at that point. Instead we should aim for, it is not accessible, therefore what is the maximum extent I can provide for accessible use.
 

Yikes

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Here we have an insensitivity issue. It may not be in code/ANSI but the experience cannot be denied to those with disabilities.
Swings have been adapted for WC users, this must be too or face the consequences of a parent.
I've seen slides for wheelchairs all over the place. They're called "ramps".

With 8.33% slope and ANSI-compliant slip resistance, they're not much of a "slide" experience.
 

ICE

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Jun 23, 2011
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California concrete jungle
A new two-story school building for small children is under construction. A portion of the building's first floor is open through the second floor to the roof. On the second floor, that open-to-below area is bound by a compliant guard railing. .
The guard is compliant until it gets to the opening for the slide. At that point it is not a compliant guard.
 

MtnArch

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Dec 25, 2009
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324
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San Juan Bautista, California
Although I appreciate ADAguy's comments, I have to agree with classicT and Yikes on this - unfortunately (as hard as we may (or may not) try) there is no way to accommodate both able and disabled with everything. It may seem like a callous comment, but as I've reminded my kids over the years - "If someone told you that life is fair .. they lied to you." There simply will be areas that the disabled will not be able to experience in the same way as others - but if all we ever do is focus on the negative, we will miss so much of what IS available to be enjoyed and experienced by all.
 

classicT

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The guard is compliant until it gets to the opening for the slide. At that point it is not a compliant guard.
Technically, with an enclosed slide, there is not a 30" drop within 36" of the opening. I'm not sure if there is an official standard for slides, but most that are more than 5-6-ft off the ground are the fully enclosed tube type. I would argue that a tube, being fully enclosed is not an issue for a guard. Now install a traditional non-tube, U-shaped slide, and I think that there is a fall hazard if the slide transitions between stories.
 

classicT

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To go with ICE....If the tube isn't 42" tall...It would not qualify as a guard....Shirley I wouldn't call it a drop though...
images


I'd imagine that it should look something like this. The guard is continuous around and above the slide opening.
 

bill1952

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Aug 12, 2021
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Clayton NY
My mom taught in a small school that had a slide like that - straight - from second floor to first - on exterior. Fire escape of course. Don't know if they used if for fun or just fire drills.

Kind of beyond maximum ramp slope.....
 

fatboy

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Oct 17, 2009
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Northern CO
I ran into this with a rec pool we built years ago, and I got over agonizing on it. Accessible route ended at the slide base. That's been about 16 years now, never had heard a word about it, still in the same jurisdiction, heck, they made me the CBO right after that!
 
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