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

405 Ramps

Section 405 provides technical criteria for ramps. Revisions made to this section include:

• a new exception for ramps in assembly areas (405.1)

• removal of an exception for ramp slopes in historic facilities (405.2)

• addition of exceptions for ramps in employee work areas (405.5 and 405.8)

• clarification of specifications for ramp landings (405.7)

Comment. Requirements for ramps apply to portions of accessible routes that slope more than 1:20. Technical provisions address running slope, cross slope, handrails, landings, edge protection, and other elements. Comments from designers of assembly areas requested that the guidelines make clear that ramps adjacent to seating in assembly areas that are not part of a required accessible route do not have to comply with the guidelines. Often, it is not practicable that such ramps meet requirements for handrails, edge protection, running slope, and other specifications.

Response. An exception has been added in the final rule (405.1) for ramps adjacent to seating in assembly areas, which are not required to comply with the guidelines provided that they do not serve elements required to be on an accessible route

Section 405.2 specifies a maximum running slope of 1:12 for ramps. Alternate slope requirements are permitted for short ramps in existing facilities where space constraints effectively prohibit a 1:12 running slope. A 1:10 maximum slope is permitted for ramps with a rise of up to 6 inches, and a maximum 1:8 slope is allowed for ramps with a rise of up to 3 inches.

Comment. Commenters recommended that language in the original ADAAG be restored calling for the "least possible slope" to be used, with 1:12 being the maximum allowed.

Response. While the least possible slope is generally desired for easier access, this language had been removed because it is considered too vague from a compliance standpoint and thus difficult to enforce. The final rule, consistent with the proposed rule, specifies only that the maximum slope shall be 1:12.

Comment. The proposed rule included an exception for qualified historic structures (405.2, Exception 2) that would have permitted a running slope of 1:6 maximum for ramps no longer than 24 inches. Commenters urged that this exception be removed for consistency with the ANSI A117.1‒1998 standard and the International Building Code (IBC).

Response. This exception for qualified historic facilities has been removed in the final rule. Such facilities, however, may qualify for the exceptions generally permitted for existing facilities that have been retained in the final rule.

The final rule includes exceptions for ramps located in employee work areas. Common use circulation paths within such areas are subject to requirements for accessible routes (203.9). These circulation paths must be accessible according to requirements for accessible routes, including ramps. Exceptions included in the final rule for the clear width (405.5) and handrails (405.8) of ramps located in employee work areas recognize constraints posed by various types of equipment. Employee work area ramps do not have to meet the specified 36 inch minimum clear width where a decrease is necessary due to equipment within the work area so long as the decrease is essential to the work being performed. Ramps within employee work areas are not required to have handrails if they are designed to permit the later installation of complying handrails. A clearance of 36 inches between handrails is required, except at those ramps that qualify for the clear width exception in 405.5.

Comment. Section 405.7 addresses ramp landings, including the minimum width and length (405.7.2 through 405.7.4). A commenter suggested that these provisions be revised to the "clear" dimension for clarity and consistency.

Response. Specifications for ramp landings have been revised in the final rule, as suggested, to refer to the "clear" dimension.