Notice
This checklist has been prepared to assist individuals and entities with rights or duties under Title II, and Title III of the Americans with Disabilities Act (ADA) in applying the requirements of the Americans with Disabilities Act Accessibility Guidelines (ADAAG) to buildings and facilities subject to the law. The checklist presents information in summary form on the Department of Transportation (DOT) and the Department of Justice (DOJ) regulations implementing the ADA. The checklist must be used with the DOT and DOJ regulations and ADAAG to ensure accuracy.
This checklist is intended for technical assistance purposes only. Individuals who use this checklist should be aware that the Department of Justice and the Department of Transportation, not the U.S. Architectural and Transportation Barriers Compliance Board (Access Board, are responsible for the enforcement of Titles II and III of the ADA. Use of this checklist does not constitute a determination of your legal rights or responsibilities under the ADA, and it is not binding on the Department of Justice, Department of Transportation, or the Access Board.
Use of this checklist is voluntary. Individuals who use this checklist are not required to send the survey forms to DOJ, DOT, or the Access Board.
While ADAAG may be amended in the future, this checklist is based on ADAAG as published on July 26, 1991 (sections 1 through 4.35 and special application sections 5 through 9) and September 6, 1991 (section 10). See 56 FR 35408 (July 26, 1991) and 56 FR 45500 (September 6, 1991) as corrected at 57 FR 1393 (January 14, 1992).
INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Page 1
Purpose
New Construction
Alterations
Historic Preservation
Barrier Removal in Existing Facilities
Key Stations
What Are "Places of Public Accommodation" and "Commercial Facilities"
How the Checklist is Organized to Assist You
How Differences in Requirements for New Construction, Alterations, and Historic Properties are Addressed
SURVEY INSTRUCTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Page 6
Approach to Surveying
Preparing to Survey
Step 1: Identify the Type of Facility or Building Use
Step 2: Determine Minimum Requirements
Step 3: Copy and Assemble the Survey Forms
Step 4: Survey
BUILDING IDENTIFICATION AND DATA SHEET
MINIMUM REQUIREMENTS AND SUMMARY SHEETS
A: Parking and Passenger Loading Zones
B: Site Accessible Routes and Elements
C: Entrances
D: Building Accessible Route
E: Rooms and Spaces (Including Assembly Areas and Dressing and Fitting Rooms)
F: Toilet Rooms and Bathrooms
G: Special Features -- Signage, Alarms, Detectable Warnings, and Automated Teller Machines (ATMs)
H: Special Types of Facilities
I: Accessible Buildings -- Additions and Alterations
J: Accessible Buildings -- Historic Preservation
TECHNICAL REQUIREMENTS SURVEY FORMS
General Requirements --
Survey Form 1: Parking
Survey Form 2: Passenger Loading Zone
Survey Form 3: Exterior Accessible Routes
Survey Form 4: Curb Ramps
Survey Form 5: Drinking Fountains
Survey Form 6: Telephones
Survey Form 7: Ramps
Survey Form 8: Stairs
Survey Form 9: Platform Lifts
Survey Form 10: Entrances and Exits (Areas of Rescue Assistance)
Survey Form 11: Doors and Gates
Survey Form 12: Building Lobbies and Corridors (Interior Accessible Route)
Survey Form 13: Elevators
Survey Form 14: Rooms and Spaces
Survey Form 15: Assembly Areas
Survey Form 16: Toilet Rooms and Bathrooms
Survey Form 17: Bathtubs and Showers
Survey Form 18: Dressing and Fitting Rooms
Survey Form 19: Signage
Survey Form 20: Alarms
Survey Form 21: Detectable Warnings
Survey Form 22: Automated Teller Machines (ATMs)
Special Facility Types --
Survey Form 23: Restaurants and Cafeterias
Survey Form 24: Medical Care Facilities
Survey Form 25: Mercantile Facilities
Survey Form 26: Libraries
Survey Form 27: Transient Lodging -- Hotels, Motels, Inns, Boarding Houses,Dormitories, and Similar Places
Survey Form 28: Transient Lodging in Homeless Shelters, Halfway Houses, Transient Group Homes,and Other Social Services Establishments
Survey Form 29a: Transportation Facilities -- Bus Stops
Survey Form 29b: Transportation Facilities -- Fixed Facilities,Terminals and Stations
Survey Form 29c: Transportation Facilities -- Airports
The Americans with Disabilities Act (ADA), signed by President Bush on July 26, 1990, is landmark legislation to extend civil rights protection to people with disabilities. The ADA prohibits discrimination on the basis of disability in employment, State and local government services, public transportation, public accommodations, commercial facilities, and telecommunications. The ADA required the U.S. Architectural and Transportation Barriers Compliance Board (Access Board) to supplement its Minimum Guidelines and Requirements for Accessible Design to serve as the basis for regulations to be issued by the Department of Justice and the Department of Transportation under Title II and Title III of the Act. On July 26, 1991, the Access Board published its ADA Accessibility Guidelines for Buildings and Facilities (ADAAG). These guidelines were amended and supplemented with provisions for transportation facilities on September 6, 1991. ADAAG is applicable to buildings and facilities covered by Title II and Title III of the ADA to the extent required by regulations issued by the Department of Justice and the Department of Transportation under the ADA.
The purpose of this checklist is to enable people to survey places of public accommodation, commercial facilities, and transportation facilities for compliance with the new construction and alterations requirements of Title II, Subtitle B (Public Transportation) and Title III of the ADA. It can also be used to identify barriers in existing buildings. No special training is needed to use this checklist. It can be used by businesses, building owners and managers, State and local governments, design professionals, or concerned citizens.
The checklist must be used in conjunction with the Department of Justice's regulations in 28 CFR Part 36, the Department of Transportation's regulations in 49 CFR Part 37, and the Americans with Disabilities Act Accessibility Guidelines which are reprinted in the appendices to those regulations. Appendix A of the Department of Transportation's regulations includes section 10 of ADAAG, which specifies additional provisions for transportation facilities.
Buildings and facilities constructed or altered by, on behalf of, or for the use of State and local governments covered by Title II, Subtitle A of the ADA, (other than transportation facilities covered by the Department of Transportation's regulation), are allowed by 28 CFR 35.151 to follow either ADAAG without the elevator exception or the Uniform Federal Accessibility Standards (UFAS). A similar checklist, the UFAS Accessibility Checklist, is available from the Access Board.
Places of public accommodation and commercial facilities covered by Title III of the ADA are required by 28 CFR 36.401 and 36.406 to comply with ADAAG if the facilities are designed and constructed for first occupancy after January 26, 1993. This requirement applies only if: (1) the last application for a building permit or permit extension for the facility is certified to be completed by a State, county, or local government after January 26, 1992 and (2) the first certificate of occupancy for the facility is issued after January 26, 1993. Full compliance with the new construction requirements is not required where an entity can demonstrate that it is structurally impracticable. The exception for structural impracticability, a very narrow one, is discussed in 28 CFR 36.401(c) and ADAAG 4.1.1(5)(a). Other exceptions for certain temporary structures, specific building areas and features (including elevators) are discussed in ADAAG 4.1.1(4), 4.1.1(5)(b) and 4.1.3(5) and, where applicable, on the Minimum Requirements Summary Sheets or the Technical Requirements Survey Forms.
Transportation facilities covered by Title II, Subtitle B of the ADA are required by 49 CFR 37.9 and 37.41 to comply with ADAAG, including section 10, if a notice to proceed is issued after January 25, 1992, for bus, light rail or rapid rail facilities; or after October 7, 1991, for intercity or commuter rail stations.
Areas that are used only by employees as work areas must be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas as required in ADAAG 4.1.1(3). The guidelines do not require that any areas used only by employees as work areas be constructed to permit maneuvering within the work area or be constructed or equipped (i.e., with racks or shelves) to be accessible.
Departures from the ADAAG technical and scoping provisions are permitted where the alternative designs and technologies used will provide substantially equivalent or greater access to and usability of the facility. See ADAAG 2.2 and other sections referenced in Appendix A2.2 of ADAAG for specific examples of equivalent facilitation.
For transportation facilities covered by Title II, Subtitle B of the ADA, a determination of equivalent facilitation must be made by the Administrator of the Federal Transit Administration or the Federal Railroad Administration, as applicable. The specific procedure for applying for such a determination is included in 49 CFR 37.9(d).
Alterations to a place of public accommodation or commercial facility covered by Title III of the ADA that are undertaken after January 26, 1992 are required by 28 CFR 36.402 and 36.406 to be done in a manner so as to ensure that, to the maximum extent feasible, the altered portions of the facility comply with ADAAG. For transportation facilities covered by Title II, Subtitle B of the ADA, 49 CFR 37.9 and 37.4 require that alterations must follow ADAAG if a notice to proceed or work order is issued after January 25, 1992, for bus, light or rapid rail facilities; or after October 7, 1991, for intercity or commuter rail stations.
In general, alterations of specific elements or portions of a facility must be completed in compliance with the requirements for new construction. However, full compliance with the alterations requirements is not required where it is technically infeasible. The exception for technical infeasibility is discussed in ADAAG 4.1.6(1)(j). This and other special provisions and exceptions for alterations contained in ADAAG 4.1.6 are discussed on the Minimum Requirements Summary Sheet I: Accessible Buildings - Additions and Alterations. Additional special provisions and exceptions for alterations for special facility types are found in ADAAG 5, 6, 7, 9 and 10 and on the Technical Requirements Survey Forms for the special facility types.
If an alteration affects or could affect the usability of or access to an area of a facility that contains a "primary function," an accessible path of travel must be provided to the altered area. In addition, restrooms, telephones, and drinking fountains serving the altered area must also be made accessible to the extent that the cost is not "disproportionate" to the cost of the overall alteration. Disproportionality is defined in 28 CFR 36.403 (f) and 49 CFR 37.43(e) as a sum not to exceed 20% of the cost of the alteration to the primary function area.
Alterations to a qualified historic building or facility must comply with ADAAG unless it is determined in accordance with procedures described in ADAAG 4.1.7(2) that compliance with certain requirements would threaten or destroy the historic significance of the building or facility. In such a case, alternative requirements may be used. The alternative requirements are discussed in 28 CFR 36.405 and ADAAG 4.1.7(3) and on the Minimum Requirements Summary Sheet J: Accessible Buildings - Historic Preservation.
Barrier Removal in Existing Facilities
Public accommodations covered by Title III of the ADA must remove architectural barriers in existing facilities, including communication barriers that are structural in nature, where such removal is readily achievable. The ADA generally defines readily achievable as "easily accomplishable and able to be carried out without much difficulty or expense." The requirement to remove architectural barriers where readily achievable is discussed in 28 CFR 36.304. Measures taken to comply with readily achievable barrier removal must comply with ADAAG unless it would not be readily achievable. Then, other readily achievable measures that do not fully comply with ADAAG may be taken. However, no measure shall be taken that poses a significant risk to the health or safety of individuals with disabilities or others.
Existing rapid rail, light rail, and commuter rail transportation systems covered by Title II, Subtitle B of the ADA must identify "key stations", in accordance with requirements of 49 CFR 37.47 and 37.51. Generally, "key stations" must comply with ADAAG 10.3.2. Under some conditions, previously altered elements which conform to UFAS (when done by a public entity) or ANSI A117.1-1980 (when done by a private entity without Federal funds) may meet the key station requirements. This "grandfather" provision applies only to "key stations" and is discussed in 49 CFR 37.9(b) and the corresponding explanatory material in Appendix D to the Department of Transportation's regulations. All existing intercity rail stations must comply with ADAAG 10.3.2. The timeframes for making "key stations" and existing intercity rail stations accessible are specified in the Department of Transportation's regulations at 49 CFR 37.47, 37.51, and 37.55.
What Are "Places of Public Accommodation" and "Commercial Facilities"?
ADAAG applies to new construction and alterations of "places of public accommodation and commercial facilities." A "place of public accommodation" is a facility, operated by a private entity, whose operations affect commerce and which falls within at least one of the twelve categories listed below:
"Commercial facilities" are facilities whose operations will affect commerce and that are intended for nonresidential use by a private entity (e.g., factories and warehouses). "Commercial facilities" do not include facilities that are covered or expressly exempted from coverage under the Fair Housing Act of 1968, as amended; aircraft; and certain railroad equipment listed in 28 CFR 36.104.
How the Checklist is Organized to Assist You
This checklist presents the minimum scoping and technical requirements contained in ADAAG for newly constructed facilities in the logical progression of traveling to and through a building. The Minimum Requirements Summary Sheets tell you what to survey, such as an accessible route, an entry, or a bathroom. The Technical Requirements Survey Forms give you the specific features those elements must have. There are 29 survey forms to represent elements on the site and in the building. Many of ADAAG's general requirements are repeated on different forms because they apply to more than one element. Some survey forms may refer you to others for detailed provisions.
In general, the Minimum Requirements Summary Sheets and the Technical Requirements Survey Forms contain the ADAAG requirements for new construction. In alterations one must first attempt to meet the requirements for new construction unless it is technically infeasible or special provisions apply.
The survey process moves through a parallel structure in three steps using the following sheets and forms:
Step 1: Building/Facility Identification and Data Sheet
Step 2: Minimum Requirements Summary Sheets
Sheet A: Parking and Passenger Loading Zones
Sheet B: Site Accessible Routes and Elements
Sheet C: Entrances
Sheet D: Building Accessible Route
Sheet E: Rooms and Spaces (Including Assembly Areas and Dressing and Fitting Rooms)
Sheet F: Toilet Rooms and Bathrooms
Sheet G: Special Features - Signage, Alarms, Detectable Warnings,
and Automated Teller Machines (ATMs)
Sheet H: Special Types of Facilities
Sheet I: Accessible Buildings - Additions and Alterations
Sheet J: Accessible Buildings - Historic Preservation
Step 3: Technical Requirements Survey Forms
Form 1:Parking
Form 2:Passenger Loading Zones
Form 3:Exterior Accessible Routes
Form 4:Curb Ramps
Form 5:Drinking Fountains
Form 6:Telephones
Form 7:Ramps
Form 8:Stairs
Form 9:Platform Lifts
Form 10:Entrances and Exits (Areas of Rescue Assistance)
Form 11:Doors and Gates
Form 12:Building Lobbies and Corridors (Interior Accessible Route)
Form 13:Elevators
Form 14:Rooms and Spaces
Form 15:Assembly Areas
Form 16:Toilet Rooms and Bathrooms
Form 17:Bathtubs and Showers
Form 18:Dressing and Fitting Rooms
Form 19: Signage
Form 20: Alarms
Form 21: Detectable Warnings
Form 22: Automated Teller Machines (ATMs)
Special Facility Types --
Form 23:Restaurants and Cafeterias
Form 24:Medical Care Facilities
Form 25:Mercantile Facilities
Form 26:Libraries
Form 27: Transient Lodging (Hotels, Motels, Inns,
Boarding Houses, Dormitories, and Other Similar Places)
Form 28: Transient Lodging in Homeless Shelters,
Halfway Houses, Transient Group Homes, and Other Social Service Establishments
Form 29:Transportation Facilities
Special provisions and exceptions allowed in alterations of buildings, including
historic properties, are addressed in Minimum Requirements Summary
Sheet I: Accessible Buildings - Additions and Alterations, and
Sheet J: Accessible Buildings - Historic Preservation.
Special provisions and exceptions allowed in special facility types such as hotels, motels, hospitals, mercantile facilities, libraries, restaurants and cafeterias are addressed in Survey Forms 23 through 29.
This checklist is designed to be used in full or in part, depending on the facility and your available time. If you are surveying a facility with which you are familiar, you may already know what the general access problems are and will want to use specific survey forms to check the details. If you are unfamiliar with the facility, it is helpful to make an initial tour through the building to orient yourself and to obtain information to help you compile your survey document.
Although this checklist is structured for use on site, it can also be used by architects, facility managers or others to review architectural plans.
Make contact with the building management and advise them that you will be surveying the building and that you will be glad to share your information with them. If you do not have a building plan, ask the management if they can provide you with one. A plan can be very helpful, particularly if you are surveying a large facility. You can assign numbers to areas or elements on the plan and use the same numbers to correlate the Survey Forms.
Take a copy of ADAAG with you when you do the survey. Since the questions in this checklist are fairly brief, it is helpful to have ADAAG with you to gain a thorough understanding of the full requirements of the Guidelines. Also, not every illustration in the ADAAG has been included in this survey. Illustrations are provided in the checklist only for those survey questions which cannot easily be stated or understood using words alone.
Step 1: Identify the Type of Facility or Building Use
Complete the Building Identification and Data Sheet to document the name and address of the facility, dates of construction and alteration, type of facility or building use, number of stories and size of each, name of surveyor and date of survey.
Before surveying the facility it is essential to determine whether the provisions of ADAAG apply to the facility or portion of the facility and to identify certain attributes about the facility which might trigger or disallow certain exceptions contained in ADAAG. To determine which provisions of ADAAG apply, you must consult the Department of Justice regulations or Department of Transportation regulations as explained in the introduction. To determine the exceptions that apply you must also consult the DOJ or DOT regulations. Exceptions within ADAAG are noted on the Technical Requirements Survey Forms. An example of an exception is the elevator exemption contained in ADAAG 4.1.3(5) Exception 1. Elevators are not required in places of public accommodation and commercial facilities that are less than three stories or that have less than 3,000 square feet per story unless the building is a shopping center or mall, the professional office of a health care provider, or a transportation facility.
Step 2: Determine Minimum Requirements
The Minimum Requirements Summary Sheets tell you which elements are required to be accessible, such as a toilet room or an accessible route between the entrance and parking. Use the Summary Sheets to identify the specific elements of your facility which must be accessible.
With the Summary Sheets in hand, take a quick tour of the facility and/or look at the building plans. As you go through the facility, complete each Summary Sheet in the order in which it is presented. The Summary Sheets will ask you to inventory the elements of your facility which must be accessible.
The principle of an "accessible route" is key to the Summary Sheets. An "accessible route" is simply a path of travel which a person in a wheelchair, an elderly person, or someone with another mobility limitation would find safe and easy to use. (See ADAAG 3.5 Definitions.) The Summary Sheets define where these accessible routes must be.
Step 3: Copy and Assemble the Survey Forms
Return to your workplace with the completed Summary Sheets. Using the completed Summary Sheets you can determine how many copies to make of each Technical Requirements Survey Form. Some forms will be needed more than once, others will not be needed at all. Some forms will reference other forms. Two forms that are referenced quite often are Form 11: Doors and Gates and Form 12: Building Lobbies and Corridors. Where forms are cross referenced you will always need to have a copy of the form for reference.
In some multi-story buildings, you will find that certain elements required to be accessible are duplicated in the details of installation and you may be able to develop a "shorthand" method of surveying these elements. For instance, you might find that accessible drinking fountains are installed in the same location in a corridor and in the same way on the first through the tenth floor of a ten story building. It may be sufficient to use only one form (Form 5: Drinking Fountains) to assess compliance in detail for a typical fountain on the first floor, and then note that each fountain on the second through the tenth floor is the same. All elevators are required to be accessible but where there are three elevators in a bank, you will often find that the three elevators are the same. If this is true, you may be able to use a single form (Form 13: Elevators) to survey three elevators in the same bank.
Copy the necessary Survey Forms and attach them to the Summary Sheet which called for them. When you are finished, you will have a series of Survey Forms which progress logically through the facility and are divided by the Minimum Requirements Summary Sheets. If you are working with a team, you can give team members a complete section covered by a Summary Sheet. Cover the entire package with the Building Identification and Data Sheet. If you are surveying an alteration to a facility or an alteration which falls under historic preservation provisions, you will also need those Summary Sheets.
Bring a copy of ADAAG, a clipboard, a pencil or a pen, a flexible measuring tape, and a stick of chalk for marking distances on surfaces. You may also want a line level or other device to measure ramp slopes, and a fish scale for determining door pull force.
Each Survey Form has a title block which allows you to identify the specific element you are inspecting. Be sure to fill in the location of the element and the facility name on each Survey Form.
Each survey question or series of questions has an ADAAG section number. Some questions have more than one ADAAG section number. If you do not understand the question, look up the section(s) in ADAAG. Illustrations referenced in the survey forms are printed on subsequent pages. If you have a question about a term, refer to ADAAG 3.5 (Definitions).
Check off whether the element complies or not. If you cannot determine whether or not it complies, put a question mark in the box. Do not leave blank boxes because it will confuse someone who later reviews the forms. If the element does not exist, write "N/A" (Not Applicable).
Each Survey Form has boxes for you to check for each question, either "yes" or "no." Please also notice that extra space is provided for you to elaborate where a simple "yes" or "no" is insufficient. You should note as precisely as possible what the problem is; for example, "clear opening width only 29 inches," "hand rail diameter 4 inches," or "ramp slope 1:10." This information will assist those using the survey at a later date to make modifications to evaluate which changes might be more critical in providing access.
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