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Additions 4.1.5:

Additions must meet the applicable minimum requirements for new construction in 4.1.1 to 4.1.3 and the applicable technical provisions in 4.2 through 4.35 and 5.0 through 10.0 for each space or element added to the existing building or facility. Use the applicable survey forms for new construction for each altered element or space.

Additions to an existing building or facility also are regarded as alterations. An addition that affects an area of primary function must also comply with 4.1.6(2) and 28 CFR _36.403.

Alterations 4.1.6(1):

No alteration may decrease accessibility below the requirements for new construction. Alterations are not required to provide greater accessibility than that in new construction. In existing buildings or facilities, alterations must comply with the following:

  • Each element, space, feature, or area that is altered must comply with the applicable minimum requirements for new construction in 4.1.1 through 4.1.3 and the applicable technical provisions in 4.2 through 4.35 and 5.0 through 10.0. (Use Forms 1-29.) If the applicable requirements for new construction require that an element, space, feature, or area be on an accessible route, an accessible route is not required except as provided in 4.1.6(2) (Alterations to an Area Containing Primary Function).
  • When alterations of single elements amount to an alteration of a room or space, the entire space must be made accessible.
  • If full compliance with the technical provisions (4.2 through 4.35 and 5.0 through 10.0) of an altered element, space, feature, or area is technically infeasible, the special technical provisions in 4.1.6(3) may be utilized. If there is no special technical provision in 4.1.6(3) for an altered element, space, feature, or area, or if full compliance with the special technical provision is technically infeasible, the alteration must provide accessibility to the maximum extent feasible. Any elements or features of the building or facility that are being altered and can be made accessible, must be made accessible within the scope of the alteration.

Special Technical Provisions 4.1.6(3): The following elements may be modified only as described below.

  • Curb Ramps and Ramps - Slope and Rise: Where space limitations prohibit the use of a 1:12 slope, a slope between 1:10 and 1:12 is allowed for a maximum rise of 6 inches; and a slope between 1:8 and 1:10 is allowed for a maximum rise of 3 inches.
  • Stairs - Handrail Extensions: Where handrail extensions would be hazardous (e.g., protruding into pedestrian traffic perpendicular to the stair) or impossible due to plan configuration, full extension of handrails is not required.
  • Elevators - Safety Edges and Car Dimensions: If safety edges are provided in an existing automatic elevator, automatic door opening devices may be omitted. Where existing shaft configuration or technical infeasibility prohibits full compliance with 4.10.9, the car plan dimensions may be reduced by the minimum amount necessary, but in no case shall the inside car area be less than 48 inches by 48 inches. Equivalent facilitation may be provided with an elevator car of different dimensions when usability can be demonstrated and when all other accessible elements comply with 4.10.
  • Doors - Clear Opening and Thresholds: Where it is technically infeasible to comply with the 32 inch clear opening width requirement, a maximum projection of 5/8 inch will be permitted for the latch side stop. If existing thresholds are no more than 3/4 inch high, and have (or are modified to have) a beveled edge on each side, they may remain.
  • Toilet/Bath Rooms - Unisex, Alternate Stall, Directional Signage: Where it is technically infeasible to modify both men's and women's toilets/bath rooms in compliance with 4.22 or 4.23, a unisex toilet/bath room is permitted. Each unisex toilet room must contain one water closet complying with 4.16 and one lavatory complying with 4.19, and the door must have a privacy latch. Where it is technically infeasible to install a required standard stall (Fig. 30(a)), or where other codes prohibit reduction of the fixture count, either alternate stall (Fig. 30(b)) may be provided. Where existing toilet/bath rooms are not altered to be accessible, signage must be provided indicating the location of the nearest accessible toilet/bath room within the facility.
  • Assembly Areas - Dispersal of Seating and Performing Areas: Where it is technically infeasible to meet dispersal requirements, accessible seating may be clustered. Each accessible seating area must have provisions for companion seating and must be located on an accessible route usable as a means of emergency egress. Where it is technically infeasible to alter all performing areas to be on an accessible route, at least one of each type of performing area must be made accessible.
  • Lifts - Conditions for Use: In alterations, the use of lifts is not limited to the four conditions in 4.1.3(5) Exception 4. Lifts must comply with 4.11 and applicable State and local codes.
  • Dressing/Fitting Rooms - Minimum Number: Where technically infeasible to provide the minimum number of dressing/fitting rooms required in 4.1.3(21), one dressing room for each sex (or one unisex room if typical) on each level must be made accessible.

Additional Requirements and Exceptions (4.1.6(1)):

  • Text Telephones - At least one interior public text telephone complying with 4.31.9 must be provided where:
    1. Alterations to existing buildings or facilities with fewer than four exterior of interior public pay telephones would increase the total number to four or more telephones with at least one in an interior location; or
    2. Alterations to one or more exterior or interior public pay telephones occur in an existing building or facility with four or more public telephones with at least one in an interior location.
  • Accessible Vertical Access - If an escalator or stair is planned or installed where none existed previously and major structural modifications are necessary for such installation, then a means of accessible vertical access must be provided that complies with the applicable provisions of 4.7 Curb Ramps, 4.8 Ramps, 4.10 Elevators, or 4.11 Lifts.
  • Areas of Rescue Assistance - In alterations, areas of rescue assistance are not required because the new construction requirements of 4.1.3(9), 4.3.10 and 4.3.11 do not apply.
  • Entrances - If a planned alteration entails alterations to an entrance, and the building has an accessible entrance, the entrance being altered is not required to comply with 4.1.3(8), except to the extent required by 4.1.6(2). If a particular entrance is not made accessible, appropriate accessible signage indicating the location of the nearest accessible entrance(s) must be installed at or near the inaccessible entrance, such that a person with a disability will not be required to retrace the approach route from the inaccessible entrance.
  • Alterations Not Affecting Accessibility - If the alteration work is limited solely to the electrical, mechanical, or plumbing system, or to hazardous material abatement, or automatic sprinkler retrofitting, and does not involve the alteration of any elements or spaces required to be accessible under ADAAG then 4.1.6(2) does not apply.
  • Elevator Exception - If a building is less than three stories or has less than 3,000 square feet per story, an elevator is not required unless the building is a shopping center or shopping mall, the professional office of a health care provider, or a transportation facility. These terms are defined in 28 CFR _36.404(a).

Alterations to an Area Containing a Primary Function (4.1.6(2)):

In addition to the requirements of 4.1.6(1), an alteration that affects or could affect the usability of or access to an area containing a primary function must be made so as to ensure that, to the maximum extent feasible, the path of travel to the altered area and the restrooms, telephones, and drinking fountains serving the altered area, are readily accessible to and usable by individuals with disabilities, unless such alterations are disproportionate to the overall alterations in terms of cost and scope (as determined under criteria established by the Attorney General). These terms are further defined in 28 CFR _36.403.


Americans with Disabilities Act Accessibility Guidelines (ADAAG)
Checklist for Buildings and Facilities


October 1992


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).

Table of Contents

INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Page 1

New Construction
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



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


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)


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