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

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."