36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

210 Stairways

Stairs that are part of a means of egress are required to comply with the guidelines (210.1). Exceptions are provided for certain stairs in detention and correctional facilities and altered stairs. The final rule modifies the exception for altered stairs (Exception 2), adds a new exception for aisle stairs in assembly areas (Exception 3), and incorporates an exception for play components developed in previous rulemaking on play areas (Exception 4).

Comment. In altered facilities, stairs serving levels that are connected by an accessible route do not have to comply, but must be equipped with complying handrails. Comments indicated that this requirement should apply only where an alteration affects stairs. Otherwise, the requirement for complying handrails should not apply.

Response. The requirement for complying handrails was intended to apply only where stairs are modified or replaced as part of an alteration. Clarification has been added in the final rule that the requirement for complying handrails applies "when the stairs are altered."

Comment. The International Building Code and other model building codes provide various exceptions for stairs in assembly areas to permit design features used to accommodate sight lines. Such features include unique riser and tread dimensions and handrail configurations. Comments indicated that an exception should similarly be provided in the guidelines to avoid conflict with model building codes.

Response. The final rule exempts aisle stairs in assembly areas from the requirements for stairs.