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Walk-off mats & ADA

e hilton

e hilton

Bronze Member
Joined
Jul 2, 2014
Messages
3,148
Location
Virginia
I’m getting caught between our maintenance managers and our ada consultants. The ada folks are saying the rubberized walk-off mats at the entrances are not compliant, because 302.2 says carpet or carpet tile shall be securely attached, and exposed edges shall be fastened to the floor and have trim on all edges. So we pulled out all the black mats. Naturally the maintenance manager is in a snit because there is nothing for customers to wipe their feet.

The mat supplier has of course weighed in on the side of the maintenance manager, and has provided a slick data sheet that says “their” mats are fully compliant, and quotes Assistant attorney general w lee rawls as saying that floor mats are not considered carpeting so they are exempt from 302.2.

Does anyone have a source that shows interpretations for ADA requirements? If it matters, the locations are in washington dc and philly.
 
Not sure how you get caught between 2 non thinking targets, but I will take a shot and guess neither will bend.

Being in the NJ/PA boarder area for decades, the company I tend to follow on this is the link below.


I would venture an interpretation from the us access board would help or you could go directly to the DOJ and ask for another updated interpretation, don't hold your breath getting a timely response from the second source.

However, do they have these types of entry mat rentals in California? If so I would venture a guess, and this is only a guess, with all the crazy and over zealous "ADA" law suits out there, I would venture either they put that industry out of business or they are an acceptable form of product use in an ADA entry.

Again this is only a W.A.G. who could survive valid law suits from that group....

As to the ADA consultant, just citing a section as non-compliant without citing how the DOJ and Access-Board have any published interpretations on this widely used product I find ODD, as to the MAT supplier, as noted in post #3, what else would you expect, but I would not just quote the past Attorney General, I would have a hard copy and electronic copy of that actually letter or notice of interpretation that I could provide when questioned at anytime.

Then again I just find this odd and interesting at the same time... Good luck
 
2010 ADAS Section 302.2 - Carpet or carpet tile shall be securely attached and shall have a firm cushion, pad, or backing or no cushion or pad. Carpet or carpet tile shall have a level loop, textured loop, level cut pile, or level cut/uncut pile texture. Pile height shall be 1/2 inch (13 mm) maximum. Exposed edges of carpet shall be fastened to floor surfaces and shall have trim on the entire length of the exposed edge. Carpet edge trim shall comply with 303.

We had to replace our mats with rounded corner type mats, we still do not meet this requirement, so the alternative is to eliminate the mat and put a camera in to catch the slip show... I guess...

e hilton I feel your pain.. as well as your future slippers!
 
mtlogcabin said:
They secure to the floor
Click to expand...
Guys … i’m not talking about the ronick-type mats. We have a similar product, different brand, and it’s fine. The question is about the loose mats you get from grainger … low pile black carpet in the center, 1” flat rubber border. Our ada consultant failed them, with a picture, because you could snag the edge with your PF Flyer sneakers and cause the edge to roll up.

And yes it’s no surprise the mat vendor has a vague but slick “report” that claims “their” mat is fully compliant.
 
This has pegged my interest enough that I emailed the US Access-board this morning and got the following response back from them already, I think you will find this interesting. It does come with all the disclaimers, but I found this to be quite interesting.

My email to the Access Board Tech line first:

Quote:
Sent: Wednesday, October 6, 2021 6:04 AM
To: Technical Assistance: U.S. Access Board <ta@Access-Board.gov>
Subject: Walk off matts are they compliant

Good morning,

A question came up on one of the message boards and I am trying to get an idea, as many of my clients use the mat service companies for their businesses.
Here is the question”
Quote:
I’m getting caught between our maintenance managers and our ada consultants. The ada folks are saying the rubberized walk-off mats at the entrances are not compliant, because 302.2 says carpet or carpet tile shall be securely attached, and exposed edges shall be fastened to the floor and have trim on all edges. So we pulled out all the black mats. Naturally the maintenance manager is in a snit because there is nothing for customers to wipe their feet.
The mat supplier has of course weighed in on the side of the maintenance manager, and has provided a slick data sheet that says “their” mats are fully compliant, and quotes Assistant attorney general w lee rawls as saying that floor mats are not considered carpeting so they are exempt from 302.2.
Does anyone have a source that shows interpretations for ADA requirements? If it matters, the locations are in washington dc and philly.
End Quote:
Any information on this interpretation or another will be helpful, thank you

End Quote: email sent to Access Board tech line

Responding QUOTE from Access Board Tech Line:

Good morning:

Rollout carpets and door mats, such as the walk-off mats you mention, are movable elements, like furniture, that are not covered by the ADA standards.
It is recommended that the requirements for carpeting be followed as much as possible so that a wheelchair could roll over the carpet or mat without it buckling or getting stuck if the trim does not meet the requirements for change in level. But these are not covered by the standards, and ultimately are not required to comply.

Hope this helps.

Sarah Presley
Accessibility Specialist
U.S. Access Board
(202)272-0046
presley@access-board.gov
www.access-board.gov

For technical assistance:
(800)872-2253 (V) (800)993-2822 (TTY)
ta@access-board.gov

Disclaimer: Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.

End Quote: from tech line at access board
 
Sure it is movable in the sense of easily relocatable (away from the accessible path), but if you move it anywhere else than in front of the door, what is the point in having a mat at all?
It is locationally fixed.
"Dear owner: Which risk is greater, slip & fall or trip & fall?"
e. hilton - Is it a walk-off mat (dust & pebbles) or a slip & fall mat (rain)?
 
E-H

I spoke to the tech from the access board this afternoon they called me, if this is in a building that is under the ABA, then the enforcing agency would be the access board and they look at the mats for are they close to meeting all the requirements of 302.2 except being fixed in place, being the gist.

It is not that the mats are compliant with ADA or ABA, it is they are not regulated by either and as thus ok to be in the pathway,

So the read I am getting is the ADA consultant needs to check with the Access board and change they can then see their position is not inline with with the Access board and DOJ. Again this is based on the mat said to be being used.

Good luck
 
Thanks for all your help. I am the proj mgr in the middle … the ADA consultant comes up with a list of things to be corrected. I correct them. If a question like the mats comes up, or if i find a problem making a correction, i raise it back to them. They may say its close enough. Or tell me to remove the mats anyway.
 
There is no "Goodhousekeeping" seal of approval agency for approval of ADA compliance.
It is for the vender/user to be prepared to defend themselves if using them.
e hilton said:
Guys … i’m not talking about the ronick-type mats. We have a similar product, different brand, and it’s fine. The question is about the loose mats you get from grainger … low pile black carpet in the center, 1” flat rubber border. Our ada consultant failed them, with a picture, because you could snag the edge with your PF Flyer sneakers and cause the edge to roll up.

And yes it’s no surprise the mat vendor has a vague but slick “report” that claims “their” mat is fully compliant.
Click to expand...
ere
 
Carpet may be a key definition to examine if you choose to argue. broaden the discussion with the ADA consultant.
No definition provided in Ch 2.
Rubber mats don't slip and by inference from the code, they are not only allowable, but apparently heavy enough to not require "securing to the floor" as they seem to call out for the condition of carpet only. Rubber mats no doubt, have a much higher coefficient of friction than the jute backed carpet. Your proposed product looks to be predominantly rubber with a topping of dense, absorbent fibers.
The recognized benefits are in the mat as a composite system and not on any singular part of the system. Not to get too obscure, but I am willing to bet that the weight of the rubber content in your proposed mats exceeds the weight of the fibers and that the lifespan of the rubber vs ("secured") carpet is greater as well, so your product requires less maintenance and greater reliability as well.
I can even see an argument made for the fact that the softer topping surface allows toes to more easily slide along the surface rather than stubbing your toe on a rubber surfaced mat. Some elderly and people in walkers often drag or shuffle their toes and a surface that provides for that movement and yet is still firm and stable from below at the floor surface level, is a much better option and provides the best of both worlds.
 
Here in is the rub, "it depends" on who the user is and if they are using an assist device to cross the mat. Walker, cane user, type of soles on their shoes, type of mobility device and how a trip and fall has occurred It is a "potential" that you don't want to be exposed to. Will the owners premisis liability insurance cover such an accident?
 
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