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ADA 2010 Standards

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225 and 811 Storage

Section 225 of the 2010 Standards provides that where storage is provided in accessible spaces, at least one of each type shall comply with the 2010 Standards. Self-service shelving is required to be on an accessible route, but is not required to comply with the reach range requirements. These requirements are consistent with the 1991 Standards.

Section 225.3 adds a new scoping requirement for self-storage facilities. Facilities with 200 or fewer storage spaces will be required to make at least five percent (5%) of the storage spaces accessible. Facilities with more than 200 storage spaces will be required to provide ten accessible storage spaces, plus two percent (2%) of the total storage spaces over 200.

Sections 225.2.1 and 811 of the 2010 Standards require lockers to meet accessibility requirements. Where lockers are provided in clusters, five percent (5%) but at least one locker in each cluster will have to comply. Under the 1991 Standards, only one locker of each type provided must be accessible.

Commenters recommended that the Department adopt language requiring public accommodations to provide access to all self-service shelves and display areas available to customers. Other commenters opposed this requirement as too burdensome to retail and other entities and claimed that significant revenue would be lost if this requirement were to be implemented.

Other commenters raised concerns that section 225.2.2 of the 2010 Standards scopes only self-service shelving whereas section 4.1.3(12)(b) of the 1991 Standards applies to both "shelves or display units."

Although "display units" were not included in the 2010 Standards under the belief that displays are not to be touched and therefore by definition cannot be "self-service," both the 2010 Standards and the 1991 Standards should be read broadly to apply to all types of shelves, racks, hooks, and similar self-service merchandising fittings, including self-service display units. Such fixtures are permitted to be installed above or below the reach ranges possible for many persons with disabilities so that space available for merchandising is used as efficiently as possible.

225 Storage

225.1 General. Storage facilities shall comply with 225.

225.2 Storage. Where storage is provided in accessible spaces, at least one of each type shall comply with 811.

Advisory 225.2 Storage. Types of storage include, but are not limited to, closets, cabinets, shelves, clothes rods, hooks, and drawers. Where provided, at least one of each type of storage must be within the reach ranges specified in 308; however, it is permissible to install additional storage outside the reach ranges.

225.2.1 Lockers. Where lockers are provided, at least 5 percent, but no fewer than one of each type, shall comply with 811.

Advisory 225.2.1 Lockers. Different types of lockers may include full-size and half-size lockers, as well as those specifically designed for storage of various sports equipment.

225.2.2 Self-Service Shelving. Self-service shelves shall be located on an accessible route complying with 402. Self-service shelving shall not be required to comply with 308.

Advisory 225.2.2 Self-Service Shelving. Self-service shelves include, but are not limited to, library, store, or post office shelves.

225.3 Self-Service Storage Facilities. Self-service storage facilities shall provide individual self-service storage spaces complying with these requirements in accordance with Table 225.3.

Table 225.3 Self-Service Storage Facilities

Total Spaces in Facility

Minimum Number of Spaces Required to be Accessible

1 to 200

5 percent, but no fewer than 1

201 and over

10, plus 2 percent of total number of units over 200

Advisory 225.3 Self-Service Storage Facilities. Although there are no technical requirements that are unique to self-service storage facilities, elements and spaces provided in facilities containing self-service storage spaces required to comply with these requirements must comply with this document where applicable. For example: the number of storage spaces required to comply with these requirements must provide Accessible Routes complying with Section 206; Accessible Means of Egress complying with Section 207; Parking Spaces complying with Section 208; and, where provided, other public use or common use elements and facilities such as toilet rooms, drinking fountains, and telephones must comply with the applicable requirements of this document.

225.3.1 Dispersion. Individual self-service storage spaces shall be dispersed throughout the various classes of spaces provided. Where more classes of spaces are provided than the number required to be accessible, the number of spaces shall not be required to exceed that required by Table 225.3. Self-service storage spaces complying with Table 225.3 shall not be required to be dispersed among buildings in a multi-building facility.