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

In the proposed rule, section 404 referenced doors and doorways. The original ADAAG included a provision for gates which were subject to all relevant specifications for doors and doorways. The final rule includes references to gates throughout section 404 so that they are equally covered, consistent with the intent of this section and with scoping provisions for doors, doorways, and gates in section 206.5. In addition, clarification has been added that the requirements for manual doors, doorways, and gates in section 404.2 apply to those "intended for user passage."

Comment. Commenters requested that the Board specifically address doors which do not provide user passage.

Response. Section 404, as all of Chapter 4, addresses accessible routes and components of such routes. Doors which do not provide user passage would not be considered part of an accessible route. However, doors not providing user passage, such as those at many types of closets and wall mounted cabinets, are subject to requirements for storage (811) and for operable parts (309) where they are required to be accessible.