ADA Compliance and Your Drainage: Urban Planning for Accessibility

When planning an urban space, designers have a moral obligation to ensure that the space is as inclusively designed as possible – there are over 61 million Americans living with a disability, including over 4.5 million disabled veterans. The Americans with Disabilities Act (ADA) of 1990 set forth comprehensive standards of inclusivity to ensure equal access and opportunity for people with disabilities, and this is extended to anywhere that’s open to the public. The act has seen substantial revisions focusing on clarity and ensuring that disabilities are well-defined and inclusive, with a large revision in 2010 adding Standards for Accessible Design for public spaces, making the moral obligation to design inclusive areas a legal obligation as well. As drainage engineers, it’s our duty to ensure our compliance with these standards to prevent liability for our clients.

When is ADA compliance required?

The ADA is broken into five titles, with Title II and Title III being relevant to the design of drainage systems. Title II outlines compliance guidelines for state and local government entities, while Title III outlines compliance guidelines for public accommodations and commercial facilities; these guidelines define the instances where ADA compliance is required. Please note that either Title II and Title III apply to different entities; compliance with both Title II and Title III, while nice, is not legally required. We’ll go through each of the titles and summarize the relevant sections below, but we encourage you to visit the links to see the formal language of the regulations.

Title II – State and Local Government Entities

For state and local government entities, Title II prohibits discrimination on the basis of disability in services, programs, and activities provided by State and local governments. Title II is implemented by the Code of Federal Regulations (CFR) Title 28, Chapter 1, Part 35. We've linked to the most relevant parts of the CFR below, and provided a summary of each, but we encourage you to visit the full regulations to ensure a robust understanding.

• Section 35.133 - Maintenance of accessible features: Public state and local government entities must maintain accessible features in an operable working condition. Accessible features include pathways and entrances, as well as parking lots where drainage systems are often heavily used. Any publicly accessible hardscape is subject to the requirements of the ADA.
• Section 35.150: Existing facilities: This section requires that state and local government entities operate services, programs, and activities, when viewed in their entirety, are readily accessible to and usable by individuals with disabilities. This doesn't necessarily require an existing facility to be brought up to new construction standards, however.
• Section 35.151: New construction and alterations: This section requires that newly constructed or altered facilities be made readily accessible to and usable by individuals with disabilities. All new buildings must comply with the Standards of Accessible Design, which we'll explore in depth shortly.

These sections of the CFR are relevant to State and local government but differ from the requirements for publicly accessible spaces, which we’ll go over in the next part of our article.

Title III – Public Accommodations and Commercial Facilities

While the spirit of Title III is broadly similar to that of Title II, there are important differences in the verbiage of the requirements, which leads to subtle but important differences between publicly accessible spaces and government owned ones. Below are the most relevant parts of Title III to the design of drainage systems for publicly accessible areas:

• Section 36.211 - Maintenance of accessible features: This section is functionally identical to Title II's Section 35.133 in that publicly accessible features be in compliance with the ADA.
• Section 36.304: Removal of barriers: This section requires the removal of architectural barriers in existing facilities where it is readily achievable and reasonably affordable, and is a bit more restrictive than the Title II counterpart.
• Section 36.401 - New construction: This section is functionally identical to above, where new buildings must be built in compliance with ADA regulations.
• Section 36.402 - Alterations: When alterations are made, facilities should be made accessible. This section, however, includes exceptions for when this is not 'readily acheivable or would harm the historical significance of a building.
• Section 36.403 - Path of travel: Similar to above, this ensures that when an area is altered, the path of travel must be made accessible. Unlike above, though, costs for the alteration may not exceed 20% of the cost of the primary function area.

In general, Title II and Title III have similar sentiments about making buildings accessible, and both enforce the same Standards for Accessible Design, but they have small differences as we talked about above.

ADA Standards for Accessible Design

Thus far we’ve talked only about the different scenarios in which accessibility is legally required, but we haven’t spoken about what being accessible means. Luckily for us, the ADA was updated in 2010 with Standards for Accessible Design which outline the requirements for a space to be considered accessible to those with disabilities. As with the CFRs we’ve gone through already, most of the content isn’t directly applicable to the design of hardscapes, and while we encourage you to read the standards in whole, we will only be covering sections applicable to drainage solutions. While the ADA itself is divided into titles, the Standards for Accessible design are instead divided into chapters, which are subdivided into sections.

Chapter 2: Scoping Requirements

This chapter creates a scope for which the ADA requirements apply, as well as defines some of the key terms that the ADA uses to ensure accessibility. These sections introduce important concepts for drainage system design and placement.

• Section 201 - Application: This section establishes the overall scope of the ADA Standards.
  • Subsection 201.1 specifies that all areas of newly designed and constructed buildings and facilities, as well as altered portions of existing buildings and facilities, must comply with these requirements.
• Section 206 - Accessible Routes:This section outlines where accessible routes are required, which is crucial for determining where drainage systems must meet ADA standards.
  • Subsection 206.1 states that accessible routes shall be provided in accordance with Section 206 and shall comply with Chapter 4.
  • Subsection 206.2 specifies where accessible routes are required, including:
    • 206.2.1 Site Arrival Points: Requires an accessible route from parking spaces, loading zones, public streets, sidewalks, and public transportation stops to accessible building entrances.
    • 206.2.2 Within a Site: Requires at least one accessible route connecting all accessible buildings, facilities, elements, and spaces on the same site.

Chapter 3: Building Blocks

This chapter provides technical requirements for accessibility in buildings as well as where required above in Chapter 2, providing guidance on grates and openings, as well as the transition back to the natural floor.

• Section 302 - Floor or Ground Surfaces:This section is perhaps the most critical for the drainage engineer, providing standards for grate openings and orientation to provide compatiblity.
  • Subsection 302.3 specifies that openings in floor or ground surfaces shall not allow passage of a sphere more than 1/2 inch (13 mm) in diameter, with some exceptions.
  • It also requires that elongated openings be placed so that the long dimension is perpendicular to the dominant direction of travel, as shown below in the illustration from the standards:
    
• Section 303 - Changes in Level:This section creates standards for changes in level, effecting common drainage items like catch basins and trench drains as they transition back to the typical floor.
  • Subsection 303.2 allows vertical changes in level of up to 1/4 inch (6.4 mm).
  • Subsection 303.3 requires changes in level between 1/4 inch and 1/2 inch to be beveled with a slope not steeper than 1:2.

Chapter 4: Accessible Routes

This chapter provides detailed requirements for accessible routes, which impact the placement and design of drainage systems along these paths.

• Section 403 - Walking Surfaces:This section ensures that areas around drainage systems maintain appropriate accessibility.
  • Subsection 403.2 requires floor or ground surfaces to comply with Section 302.
  • Subsection 403.3 specifies that the running slope of walking surfaces shall not be steeper than 1:20, and the cross slope shall not be steeper than 1:48.

Testing for ADA Compatibility

To ensure compliance with ADA standards, particularly for drainage grates and ground surfaces, simple yet effective tests can be performed:

1. The ½" Ball Bearing Test:

• Purpose: This test verifies compliance with Section 302.3 of the ADA Standards.
• Method: Roll a ½" (12.7 mm) ball bearing across the surface of the grate or ground opening. If the ball doesn't fall through, the grate is compliant. We like to use ball bearings because they're cheap and almost perfectly uniform, allowing for easy testing.

2. Flushness Test:

• Purpose: This test verifies compliance with Section 303 regarding changes in level.
• Method:
  1. Use a straightedge (like a level) placed across the grate or transition area.
  2. Measure any gap between the straightedge and the surface using a tape measure or feeler gauge.
• Compliance Standards:
  • Gaps up to ¼" (6.4 mm) are compliant without modification.
  • Gaps between ¼" and ½" (6.4 mm to 12.7 mm) must be beveled with a slope no steeper than 1:2.
  • Gaps exceeding ½" (12.7 mm) are non-compliant and require modification.

3. Slope Test:

• Purpose: This test verifies compliance with Section 403.3 on walking surfaces.
• Method: Use a digital level or inclinometer to measure both running and cross slopes.
• Compliance Standards:
  • Running slope: Should not exceed 1:20 (5%).
  • Cross slope: Should not exceed 1:48 (approximately 2%).

Regularly conducting these tests can help ensure ongoing compliance and identify areas needing adjustment or maintenance.

Accessibility Beyond ADA Requirements

While ADA compliance is crucial, it's important to recognize that these standards represent the minimum requirements for accessibility. To create truly inclusive spaces, designers and engineers should consider going beyond ADA requirements and incorporating additional standards and best practices. At Drainage Connect, we advocate for going above the bare minimum - 37 pieces of flair - so we carry a variety of grating options that go beyond ADA rating. We find the ASTM heel-proof ratings make for the most inclusive spaces.

ASTM Standards for Heel Safety

The American Society for Testing and Materials (ASTM) provides additional standards that can enhance accessibility and safety, particularly for individuals wearing high heels or other types of footwear:

• ASTM F1637: This standard provides guidelines for safe walking surfaces, including recommendations for slip resistance and the design of walkways to prevent tripping hazards.
• ASTM F2048: Specifically addresses the safety of pedestrians wearing high-heeled footwear, providing guidelines for the design of walking surfaces to minimize the risk of heel entrapment.

Incorporating these standards into drainage system design can significantly improve safety for all users, going beyond the basic ADA requirements and making a space truly inclusive. You can view our selection here, and see a full line of products that are aimed to create inclusive spaces and reduce business liability.