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					Universal Design

Universal Design is a model with a set of principles that encourage all
environments and products be designed so as to be usable by people of all ages
and abilities, to the greatest extent possible, without adaptation or specialized
design. Universal design includes seven key principles:

   1.   Equitable Use.
   2.   Flexibility in Use
   3.   Simple and Intuitive Use
   4.   Perceptible Information
   5.   Tolerance for Error
   6.   Low Physical Effort, and
   7.   Size and Space for Approach and Use

Like all models the principles of Universal Design perform best when used
together as an integrated system.

An example of a universal design feature would be to site and grade a building
so that neither stairs nor ramps are necessary at entrances and exits.

Providing universal design features in a building does not necessarily mean that
you have complied with the legal and regulatory accessibility criteria contained in
the Fair Housing Act Guidelines, the Uniform Federal Accessibility Standards
(UFAS) or even the Americans with Disabilities Act Accessibility Guidelines
(ADAAG). These ideas must not be used interchangeably. If the above guides
answer the question of “What” then the principles of Universal Design answer the
question of “How.”

Universal design principles should be applied to the planning and design of all
projects to the greatest extent possible.

A good resource on this topic is The Center for Universal Design, which is a
national research, information, and technical assistance center that evaluates,
develops, and promotes universal design in public and commercial facilities, and
related products. The Center has an extensive publications list including material
on many aspects of universal design, including accessibility as well as slide
shows and videotapes to supplement print resources.

General Accessibility Guidelines for Individuals with Disabilities

Providing facilities that are accessible to individuals with disabilities is as critical a
project goal as providing facilities that respond to scientific program needs or
provide ease of maintenance, energy efficiency, or a pleasing aesthetic. A design
team should place the same importance on designing for accessibility during the
entire design process as for all other project elements. Accessibility features
should be seamlessly incorporated into the design from the beginning and at the
earliest planning stages and not be developed as an afterthought when
compromises often result.

Applicable Legislation
The Architectural Barriers Act (ABA) of 1968 required the U.S. Department of
Defense, U.S. Department of Housing and Urban Development, U.S. Postal
Service, and General Services Administration (GSA) to prescribe standards for
the design, construction, and alteration of facilities to ensure that all structures
are readily accessible to individuals with physical disabilities. The ABA
represented the first attempt by the Federal Government to acknowledge that
people with disabilities had fundamental rights that were abridged by
architectural barriers that limited access to programs and services

Section 504 of the Rehabilitation Act of 1973 requires program access and
reasonable accommodations for individuals with disabilities when doing business
with the Federal Government. Section 504 was the first statute to recognize the
fundamental civil rights of persons with disabilities and the first time the people
with disabilities enjoyed the values of a protected class. The GSA prescribes
standards for all buildings subject to the Architectural Barriers Act that are not
covered by standards issued by the other three standard-setting agencies.

Congress established the Architectural and Transportation Barriers Compliance
Board (the Access Board) under the Rehabilitation Act of 1973 to set minimum
guidelines and requirements for uniform Federal standards and to ensure
compliance with the standards set by the four standard-setting agencies. The
Access Board Guidelines were implemented under 36 CFR Part 1190 and
resulted in publication of the Uniform Federal Accessibility Standards (UFAS),
Federal Standard 795. UFAS is enforceable by the standard-setting agencies
and the Access Board.

In 1988 Congress passed the Fair Housing Act Amendments that offered
protected class status to people with disabilities seeking housing. HUD
published the Fair Housing Guidelines by 1990 and in doing so required most
rental housing to meet certain guidelines that afforded at least minimal access to
first floor apartments. These guidelines represented the first time that the
Federal Government imposed minimum accessibility requirements on the private
sector. That same year HUD promulgated regulations implementing Section 504
of the Rehabilitation Act which required all entities using Federal Funds to make
at a minimum 5% of the units constructed accessible to people with mobility
impairments and 2% of those units accessible to people with sensory
impairments such as blindness.

Also in 1990 Congress passed the Americans with Disabilities Act (ADA). Title I
of the Act protects certain employment rights for people with disabilities. Title II
of the Act protects people with disabilities against discrimination in programs and
procedures of state and federal government. Title III of the act afforded people
with disabilities certain rights to private sector goods and services and prohibited
the private sector from discriminating against people with disabilities.

Nothing in the ADA spoke to housing or protecting the rights of people with
disabilities when the issues turned to housing. Congress left this domain to the
Fair Housing Amendments.

Revision of ABA and ADA Accessibility Guidelines
The Access Board’s guidelines issued under the ADA and the ABA are in the
process of being completely updated and revised. The ADA Accessibility
Guidelines (ADAAG) cover the construction and alteration of facilities in the
private sector (places of public accommodation and commercial facilities) and the
public sector (State and local government facilities). The accessibility guidelines
issued under the ABA primarily address facilities in the Federal sector and others
designed, built, altered, or leased with Federal funds. The guidelines under both
laws are being updated together in one rule that contains three parts: a scoping
document for ADA facilities, a scoping document for ABA facilities, and a
common set of technical criteria that the scoping sections will reference. As a
result, the requirements for both ADA and ABA facilities will be made more

The Board is reviewing and analyzing the comments received during the public
hearing and comment period. After the guidelines are republished in a final rule,
other Federal departments responsible for the standards to enforce the ADA and
ABA must then develop their standards so that they are consistent with the
updated guidelines. Until then, the current standards remain in effect.

Requirements for Making Facilities Accessible

The UFAS is mandatory on all projects that use federal funds or that are
sponsored by programs that use federal funds. Current GSA policy has been
adopted to also encourage compliance with the requirements of the ADAAG
where those requirements are more stringent than UFAS.

The criteria in these standards are considered a minimum in providing access to
persons with disabilities. Where dimensions for clearances are stated, allowance
must be made in design for construction tolerances to ensure that the completed
construction is in full compliance. Compliance demonstration is mandatory.
In general, programs using federal dollars are required to make all facilities,
buildings, and grounds accessible to individuals with disabilities without the use
of special facilities for the disabled. The intent of this policy is to use standard
building products, set at prescribed heights and with prescribed maneuvering
clearances, to allow easy use by individuals with disabilities.
To this end the Principles of Universal Design and the products developed using
those principles can prove indispensable in meeting both the compliance
requirements and the usability and esthetic requirements dictated by good
design. Examples of this principle include rear drain sinks, levered doors knobs
and press pad switches.

Leased Buildings and Facilities

Facilities, buildings, and grounds, or portions thereof, that are leased by
organizations receiving federal funds or by the Federal or State Government,
must be accessible to individuals with disabilities under the same standards as
owned facilities.

Historic Structures

Special accessibility requirements may be applied to “qualified” historic buildings
and facilities. “Qualified” buildings or facilities are those buildings or facilities that
are eligible for listing on the National Register of Historic Places. Accessibility
provisions defined in the UFAS and ADAAG should be applied to historic facilities
to the maximum practical extent. In cases where accessibility modifications
would damage the significant historic features, a review shall be requested of
competent authorities, to determine whether a change to the building as
described in the accessibility standards would have an adverse affect on the
historic significance of the property. If a competent authority determines that the
undertaking will have an adverse effect on historic property, the State Historic
Preservation Officer (SHPO) in accordance with 36 CFR 800 Section 106 will be
consulted for guidance. Nevertheless, historic buildings are covered by the
Architectural Barriers Act and must adhere to the provisions of UFAS when
renovations are undertaken.

Application of the More Stringent of UFAS or ADAAG
The following information is provided to assist designers in determining where
UFAS is more stringent or contains different requirements than the ADAAG. Bold
type designates which standard should be applied to the project.

Both the UFAS and the ADAAG references used for this comparison were
current as of the date of this writing (2/15/07). The A/E should check all updates
to the respective requirements before proceeding with the design.

The following two conditions apply:
Those elements where UFAS provisions are clearly more stringent than ADAAG;
Those elements where differences are “de minimis,” or where provisions result in
an equivalent level of access, do not significantly impact accessibility, or are
outdated and no longer serve the intended purpose. In these cases, the design
professional has the option to choose between the relevant options.

Where UFAS Is Clearly More Stringent
No Elevator Exemption: UFAS has no exception to the elevator requirement
and requires elevators in all multi-story buildings and facilities. ADAAG provides
an exception to the elevator requirement in certain buildings that are under three
stories or have less than 279 m2 (3 000 square feet) per story. [UFAS 4.1.2(5);
ADAAG 4.1.3(5) Exception 1]

Entrances in Multi-Grade Buildings: UFAS requires at least one principal
entrance at each grade floor level to a building to be accessible. ADAAG requires
(1) that at least 50 percent of all public entrances be accessible and (2) that the
number of exits required by the applicable building/fire code be used in
determining the total number of accessible entrances required in a building or
facility. UFAS would require more accessible entrances in certain “multi-grade”
buildings. [UFAS 4.1.2(8); ADAAG 4.1.3(8)]

Work Surface Scoping: UFAS requires that 5 percent of all fixed or built-in
employee work surfaces be accessible. ADAAG does not require work surfaces
in work areas to be accessible. Both UFAS and ADAAG require that 5 percent of
fixed tables in public and common use areas be accessible. [UFAS 4.1.2(17) and
4.32; ADAAG 4.1.1(3) and 4.1.3(18)]

Work Areas: UFAS requires that all areas that may result in the employment of
physically disabled persons be accessible. ADAAG requires only that people with
disabilities be able to approach, enter, and exit a work area. [UFAS 4.1.4;
ADAAG 4.1.1(3)]

Vertical Clearance at Van Parking Spaces: UFAS requires that the vertical
clearance at accessible van spaces should be 2 895 mm (114 inches). ADAAG
requires that the vertical clearance at accessible van parking spaces be 2 490
mm (98 inches). [UFAS 4.6.6; ADAAG 4.6.5]

Elevator Controls: UFAS requires elevator controls to be mounted no higher
than 1 220 mm (48 inches) “unless there is a substantial increase in cost,” in
which case the maximum mounting height may be increased to 1 400 mm (54
inches). ADAAG allows 1 400 mm (54 inches) whenever a parallel approach is
provided. [UFAS 4.10.12(3); ADAAG 4.10.12(3)]

Where UFAS/ADAAG Differences Are “De Minimis”
Entrance Signage: UFAS always requires the International Symbol of
Accessibility (ISA) at accessible entrances. ADAAG requires the ISA at
accessible entrances only when there are inaccessible building entrances in the
facility. If all entrances are accessible, the ISA is not required by ADAAG. [UFAS
4.1.1(7); ADAAG 4.1.2(7)]A.4 User Input

Stairs Exception: UFAS exempts stairs from complying with Section 4.9 only if
an elevator connects the same levels the stairs do. ADAAG exempts stairs from
Section 4.9 when there is any accessible means of vertical access connecting
the same levels that are connected by the stairs. [UFAS 4.1.2(4); ADAAG

Handrail Height: UFAS requires that handrails at stairs and ramps be placed
with the gripping surface between 800 mm and 900 mm (30 and 34 inches)
above the surface of the stair or ramp. ADAAG requires that such gripping
surface be placed between 900 mm and 1 000 mm (34 and 38 inches). [UFAS
4.8.5(5) and 4.9.4(5); ADAAG 4.8.5(5) and 4.9.4(5)]

Tactile Warnings: UFAS requires that doors to hazardous areas be equipped
with tactile warnings. This provision is reserved in ADAAG. [UFAS 4.1.2(14),
4.13.9, 4.29.3, and 4.29.7; ADAAG 4.29.3]

Pictograms: UFAS requires pictogram symbols to be tactile and does not permit
simple serif characters. ADAAG does not require pictograms (pictorial symbol
signs) to be raised and does allow the use of simple serif and sans serif tactile
characters. UFAS allows only sans serif characters. [UFAS 4.30.4; ADAAG

Special Occupancies

Assembly Areas. Scoping for 101 or More Fixed Seats: UFAS requires a
greater number of wheelchair locations than ADAAG in larger assembly areas
where the number of fixed seats exceeds 101. [UFAS 4.1.2(18); ADAAG

Dispersion for 300 or Fewer Fixed Seats: UFAS requires that wheelchair
spaces be dispersed throughout the seating area, regardless of seating capacity.
ADAAG requires that wheelchair spaces be provided in more than one location
when seating capacity exceeds 300. [UFAS 4.33.3; ADAAG 4.33.3]

Transient Lodging. Scoping: UFAS requires 5 percent of transient lodging
facilities to be accessible to persons with mobility impairments that, in very large
facilities, would result in a higher number of accessible units than ADAAG would
require. As required by the ADA, ADAAG provides for an exception for facilities
with five or fewer units that contain the residence of the proprietor. UFAS does
not provide for such an exception. [UFAS 4.1.4(11); ADAAG 9.1.1 Exception
Scoping and Technical Provisions: UFAS has scoping and technical
provisions for housing. Section 13 Housing of ADAAG interim final rule has not
been adopted as a standard by the U.S. Department of Justice. The Board is
considering reserving Section 13 in its entirety when the final guidelines for State
and local government facilities are issued. [UFAS 4.1.1(5)(d), 4.1.4(11), 4.34;
ADAAG – proposes to reserve housing]

Restaurants and Cafeterias

Table Aisles: UFAS requires that there be access aisles between tables in
restaurants and cafeterias that comply with 4.3 Accessible Routes. ADAAG
requires that all accessible fixed tables shall be accessible by means of an
access aisle of at least 900 mm (36 inches) clear between parallel edges of
tables or between a wall and the table edges. [UFAS 5.1; ADAAG 5.3]

Vending Machine Controls: UFAS requires that the controls and operating
mechanisms of vending machines in restaurants and cafeterias comply with 4.27.
ADAAG only requires that the spaces where vending machines are located
comply with the space allowances and reach ranges requirements. [UFAS 5.4;
ADAAG 5.8]

Health Care
Canopy at Passenger Loading Zone: The application of the term “Health Care
buildings and facilities” in UFAS, which is not expressly defined, may require
more facilities to provide a canopy or roof overhang and a passenger loading
zone at their entrances. ADAAG specifically defines “Medical Care Facilities”
which must have a roof canopy or overhang and a passenger-loading zone at an
accessible entrance. [UFAS 6.1; ADAAG 6.1]

Patient Bed Spacing: UFAS requires that there be 900 mm (36 inches) along
each side of a bed in patient bedrooms, 1 200 mm (48 inches) between beds, 1
100 mm (42 inches) between the foot of a bed and the wall, and 1 200 mm (48
inches) between the foot of the bed and the foot of the opposing bed. UFAS
separately identifies requirements for one-bed rooms, two-bed rooms, and four-
bed rooms. ADAAG treats beds in all rooms similarly and requires that there be
900 mm (36 inches) along each side of a bed. [UFAS 6.3; ADAAG 6.3]

Service Counters: UFAS requires that “a portion” of service counters in
mercantile facilities be between 700 mm and 860 mm (28 and 34 inches) high.
ADAAG requires a 900 mm (36 inch) length of service counter, which is a
maximum of 900 mm (36 inches) high. [UFAS 7.2; ADAAG 7.2]
Check-Out Counter Height: UFAS requires at least one checkout counter to be
no higher than 900 mm (36 inches). ADAAG requires that a specific number of
checkout counters be no higher than 970 mm (38 inches) and that the top of the
lip of the counter not exceed 1 000 mm (40 inches). [UFAS 7.3(2); ADAAG


Knee Space at Check-Out Areas: UFAS requires that at least one lane at each
check-out area provide a counter surface that is between 700 mm and 860 mm
(28 to 34 inches) high with knee clearances that are 700 mm (27 inches) high,
800 mm (30 inches) wide, and 500 mm (19 inches) deep in libraries. ADAAG
requires that at least one lane at each check-out area provide a 900 mm (36
inch) length of counter which is a minimum of 900 mm (36 inches) high. ADAAG
does not require knee space. [UFAS 8.3; ADAAG 8.3]

Additions and Alterations Where UFAS Is More Stringent or
Different From ADAAG
Additions: UFAS requires that if an addition to a building or facility does not
provide an accessible route, an accessible entrance, or accessible toilet facilities,
and such facilities are provided in the existing building, then at least one of each
shall be made accessible. ADAAG may require these items to be accessible
under the path of travel obligation, depending on the amount of money required
to build the addition. [UFAS 4.1.5; ADAAG 4.1.5]

Substantial Alterations: UFAS requires greater accessibility when substantial
alterations are made to a facility depending on the amount of money spent on the
alteration and the size of the building or site. ADAAG requires that, when an
alteration is made to an area containing a primary function, the path of travel to
that altered area and the restrooms, telephones, and drinking fountains that
serve that area be made accessible unless the additional cost of doing so would
be disproportionate to the overall cost and scope of the original alteration to the
primary functional area. The level of disproportionality is set at 20 percent of the
cost of the original alteration to the primary function area. [UFAS 4.1.6(3);
ADAAG 4.1.6(2)]

Alterations: ADAAG provides that, in alterations, the requirements of 4.1.3(9),
4.3.10, and 4.3.11 concerning egress and areas of rescue assistance do not
apply. UFAS does not have a similar exception but does not define areas of
refuge. [UFAS – no exception; ADAAG 4.1.6(g)]
Procedural Where UFAS Is More Stringent or Different From
Equivalent Facilitation: UFAS does not include a provision for equivalent
facilitation. Entities covered by the Architectural Barriers Act of 1968 (ABA) must
use the waiver and modification process as provided in the ABA in order to
deviate from the requirements of UFAS. [UFAS – no provision; ADAAG 2.2]

Advisory Committee on Historic Preservation: UFAS allows only the Advisory
Council on Historic Preservation to make determinations in cases of alterations to
historic properties. ADAAG allows both the Advisory Council and the State
Historic Preservation Officer to make such determinations. [UFAS 4.1.7(1)(b);
ADAAG 4.1.7(2)(a)(ii)]

Technical Assistance
The Access Board provides technical assistance on the ADAAG and UFAS for
project specific questions. They can be reached at the following numbers:

1-800-872-2253 (voice)
1-800-993-2822 (TTY)
(202) 272-0080 (voice)
(202) 272- 0082 (TTY)
(202) 272-0081 (fax)

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