36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)
505 Handrails
Specifications for handrails in section 505 apply to those provided at ramps, stairs, and along walking surfaces. Revisions made to this section concern:
Handrails are required along both sides of ramps and stairs. The Board has included a requirement (403.6) that handrails, where provided along walking surfaces, comply with section 505, as discussed above. The term "walking surfaces" applies to portions of accessible routes that are not treated as ramps because the running slope is less than 1:20. Consistent with this change, provisions in section 505 have been modified to specifically reference walking surfaces, including the general charging statement at 505.1. Walking surfaces are not subject to requirements for handrails on both sides (505.2) or handrail extensions (505.10).
In the final rule, an exemption from the requirements for stairways, including handrails, has been included for aisle stairs in assembly areas (210.1, Exception 3). An exception from the requirement for handrails on both sides for aisle ramps and aisle stairs has been revised for consistency. Specifically, the reference to aisle stairs in this exception has been removed as redundant.
Specifications for ramps require handrails only at ramps with a rise greater than 6 inches (405.8). Curb ramps are not subject to handrail requirements. The Board has removed as redundant an exception in the handrail section for ramps with a rise of 6 inches maximum (505.2, Exception 2).
The guidelines require handrails to be continuous within the full length of stair flights and ramp runs (505.3). The Board has added clarification, consistent with the original ADAAG, that the inside handrail at switchback or dogleg stairs and ramps be continuous. This change was made for consistency with the ANSI A117.1 standard.
Comment. The proposed rule specified that gripping surfaces be continuous and unobstructed by elements, including newel posts (505.6). An exception permitted brackets and balusters attached to the bottom of a handrail provided they did not obstruct more than 20% of the handrail length, their horizontal projection was at least 2 ½ inches from the bottom of the handrail, and their edges had a radius of at least c inch. Comments from the handrail industry, including manufacturers, trade associations, and others, indicated that these stipulations would effectively prohibit many common fabrication methods and would be unduly costly and burdensome on the industry while promising limited access benefits. Specifically, these comments indicated that many materials currently used will not meet the minimum c inch radius specifications. In addition, commenters claimed many current mounting brackets do not meet the 2 ½ inch minimum requirement for horizontal projections below the handrail, which is inconsistent with the 1 ½ inch minimum specified by model building codes. They also would preclude use of panels below handrails, which have become popular in meeting code requirements that prohibit openings in railings through which a 4 inch sphere can pass. Manufacturers stated that they have not received complaints about sharp edges and that some railing cross sections have been used for many years without injury. Opposing comments referred to ergonomic studies which support a 2 ¼ inch clearance below the handrail.
Response. The Board has revised some of the specifications for gripping surfaces in section 505.6 in order to accommodate a wider range of handrail materials and designs. The revised provisions prohibit obstructions on the top and sides of handrails, while the bottom may be obstructed up to 20% of the handrail length. This is generally consistent with the proposed rule. The Board believes that such a requirement will still permit popular designs such as panels under handrails so long as they are not directly connected to the entire length of the bottom of the handrail gripping surface. The requirement that horizontal projections occur 2 ½ inches minimum below the bottom of gripping surfaces has been changed to 1 ½ inches, consistent with model building codes and industry practice. In addition, the Board has added an exception for handrails along walking surfaces that permits obstructions along the entire bottom length that are integral to crash rails and bumper guards (505.6, Exception 1). Another exception, consistent with the ANSI A117.1‒2003 standard and recommended by a comment to the draft of the final guidelines, allows the distance between horizontal projections and the gripping surface bottom to be reduced by c inch for each ½ inch of additional handrail perimeter dimension exceeding 4 inches (505.6, Exception 2). A requirement that bracket or baluster edges have a radius of c inch minimum has been removed. A similar specification for handrail surface edges in section 505.8 has been replaced with a requirement for "rounded edges."
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