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

Comment. Comments recommended that the height of elevator car controls be harmonized with the ANSI A117.1 standard. Specifically, the ANSI standard specifies a maximum reach height of 48 inches for forward or side reaches. It also provides an exception that allows a maximum height of 54 inches for elevators with more than 16 openings where a parallel approach to the car controls is provided. The advisory committee also recommended lowering the maximum height for control buttons from 54 to 48 inches, consistent with its recommendations for reach ranges generally. The advisory committee recognized a potential adverse impact of a lower maximum height on elevators with panels that must have a large number of buttons in a limited amount of space and recommended an exception that would allow the 54 inch maximum height for elevators with more than 16 stops.

Response. As discussed above in section 308, the Board lowered the maximum side reach height from 54 to 48 inches. This height is the same as that specified for forward reaches. Elevator car controls are required to be within these reach ranges (407.4.6.1). Consequently, the Board has included an exception, consistent with the ANSI A117.1 standard and the advisory committee’s recommendation, that allows a maximum height of 54 inches where the elevator serves more than 16 openings and a parallel approach is provided (407.4.6.1, Exception 1).