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

Comment. Escalators must have a clear width of 32 inches minimum (810.9). The original ADAAG contained a requirement that at least two contiguous treads be level beyond the comb plate at the top and bottom before risers begin to form (ADAAG 10.3.1(16)). It also required color contrast on treads. Both provisions were removed in the proposed rule as recommended by the advisory committee, which questioned the need for such criteria in guidelines for accessibility. Comments requested that these specifications be restored for greater access. Commenters noted that the required color contrast benefits persons with low vision.

Response. In the final rule, the Board has added a reference to relevant provisions in the ASME A17.1 Safety Code for Elevators and Escalators instead of providing its own specification (810.9). This will ensure consistency with the safety code. The ASME code requires steps to be demarcated by yellow lines 2 inches wide maximum along the back and sides of steps (ASME A17.1, section 6.1.3.5.6). It also requires at least two flat steps and no more than four flat steps at the entrance and exit of every escalator (ASME A17.1, section 6.1.3.6.5). Consistent with the original ADAAG, an exception from these requirements is provided for existing escalators in key stations (810.9, Exception).