ADAAG Manual

Alterations [4.1.6(1)(f) & (k)]

In alterations, ADAAG does not require a level of access greater than that required in new construction. Thus, the exception from the requirement for an elevator in buildings with less than 3 stories or with less than 3,000 square feet per floor applies to altered facilities as well, including those where an area containing a "primary function" is altered. For those not exempt, ADAAG provides guidance on the type of alterations that may require vertical access between floors: major structural modifications resulting from replacement or addition of stairs or escalators. This guidance is key in determining whether an elevator is required in buildings where an alteration increases the number of stories or square footage per floor above the number recognized by the exception. In a building not exempt from the elevator requirement, vertical access may be required as part of the path of travel to altered primary function areas when the cost is not "disproportionate."

The intended scope of work and technical feasibility are key factors in determining compliance in alterations to existing elevators. For example, if the planned scope of work is limited to replacement of an elevator cab's control panel, then at a minimum the new control panel must comply to the maximum extent feasible. Or, if an alteration involves replacing the cab but not the existing shaft, ADAAG recognizes that meeting the minimum car plan dimensions may not be technically feasible due to the existing shaft configuration; in this case, smaller cab sizes are permitted. Special provisions based on technical infeasibility for car dimensions and automatic door reopening devices in 4.1.6(3)(c) are further discussed below.