Common ADA Errors and Omissions in New Construction and AlterationsAdobe Acrobat 
(PDF) version of this document with illustrations


U.S. Department of Justice
Civil Rights Division
Disability Rights Section
(seal of the U.S. Department of Justice)
 
Common ADA Errors and Omissions in New Construction and Alterations
 
Introduction
The ADA requires that new construction and alterations to existing facilities 
comply with the ADA Standards for Accessible Design1 (Standards). ADA 
requirements for new construction and alterations include detailed provisions 
for elements, spaces, and facilities. Successful accessibility is often measured 
in inches, so attention to detail can make the difference between achieving 
access and excluding or injuring someone. When the ADA's minimum requirements 
are not met, the results can limit or exclude a person with a disability and can 
be dangerous. For example, when a curb ramp extends into an access aisle at an 
accessible parking space, a person using a wheelchair may not be able to get out 
of the car or van. When the slope of a sidewalk that is an accessible route 
becomes steeper than 1 to 20, railings and edge protection are required for safe 
use. Objects that project into circulation spaces from the side or that do not 
provide at least 80 inches of head clearance can be extremely hazardous to 
people who are blind or who have low vision.
(illustration showing a man going down a ramp in a wheelchair and falling out of 
the wheelchair after it rolls off the edge of a ramp because the ramp lacks edge 
protection)
This document lists a sampling of common accessibility errors or omissions that 
have been identified through the Department of Justice's ongoing enforcement 
efforts. The specific requirement of the Standards that has not been met follows 
each error/omission. All references to figures can be found in the Standards. 
The list of errors/omissions provides examples of common deficiencies. It is not 
intended to be comprehensive or exhaustive. Any failure to comply with the 
Standards violates the ADA.
For additional information about the design and construction requirements of the 
Americans with Disabilities Act (ADA), contact the Department of Justice ADA 
Information Line. This free service provides answers to general and technical 
questions about ADA requirements and is a source for free ADA materials 
including the ADA Standards for Accessible Design. You may reach the ADA 
Information Line at: 800 - 514 - 0301 (voice) or 800 - 514 - 0383 (TTY).
ADA information is also available on the Department's ADA Home Page on the World 
Wide Web at (http://www.usdoj.gov/crt/ada/adahom1.htm).
Footnote 1 State and local governments currently have the option to choose the 
Standards or the Uniform Federal Accessibility Standard (UFAS).
 
Parking
Error/Omission:
  The built-up curb ramp projects into the access aisle.
  The accessible parking space and access aisle is not level in all directions.
Result:
  When an access aisle has a sloped surface, a wheelchair may roll away from a 
  car or van preventing the wheelchair user from getting out of the vehicle. The 
  sloped surface also prevents a van-mounted wheelchair lift from being 
  fully-lowered to the access aisle surface.
Requirement:
  4.6.3* Parking Spaces. ...Parking spaces and access aisles shall be level with 
  surface slopes not exceeding 1:50 (2%) in all directions.
 
Error/Omission:
  There is no accessible route from accessible parking to an accessible 
entrance.
Result:
  A person using a wheelchair, scooter, or walker has no way of getting from the 
  accessible parking space to the building entrance. Often when there is an 
  inaccessible walkway provided for others, wheelchair users must use a roadway 
  or vehicular route which can be dangerous.
Requirement:
  4.6.3* Parking Spaces. ...Parking access aisles shall be part of an accessible 
  route to the building or facility entrance and shall comply with 4.3.
 
Footnote * Asterisk denotes that related, non-mandatory material is in the 
Appendix to the Standards.
 
(illustration showing an overhead view of a van and a car parked in accessible 
parking spaces that share an access aisle. A person using a wheelchair is 
positioned next to the drivers side of the car and the door to the car is open. 
A dashed line with an arrowhead shows the accessible route from the access aisle 
to the sidewalk.)
 
Error/Omission:
  No van accessible spaces are provided in the parking area.
Result:
  A person who uses a van equipped with a wheelchair lift has inadequate space 
  to lower the wheelchair lift and get out of the vehicle.
Requirement:
  4.1.2 (5)(b) One in every eight accessible spaces, but not less than one, 
  shall be served by an access aisle 96 in (2440 mm) wide minimum and shall be 
  designated "van accessible" as required by 4.6.4. The vertical clearance at 
  such spaces shall comply with 4.6.5. All such spaces may be grouped on one 
  level of a parking structure.
 
Accessible Route - Exterior
Error/Omission:
  The pedestrian routes on a site from public transportation stops, accessible 
  parking spaces, passenger loading zones, and public streets and sidewalks to 
  the accessible entrance(s) are not accessible.
Result:
  People with disabilities cannot travel from the site entry points to the 
  accessible entrance(s). In some cases, people must use vehicular routes which 
  can be dangerous.
Requirement:
  4.1.2 (1) At least one accessible route complying with 4.3 shall be provided 
  within the boundary of the site from public transportation stops, accessible 
  parking spaces, passenger loading zones if provided, and public streets or 
  sidewalks, to an accessible building entrance.
 
Curb Ramps
Error/Omission:
  Curb ramp that is located across a circulation path has steep unprotected side 
  flares.
Result:
  People walking across the curb ramp may trip and be injured. People who use 
  wheelchairs can tip over if they accidentally roll over the non-flared sides.
Requirement:
  4.7.5 Sides of Curb Ramps. If a curb ramp is located where pedestrians must 
  walk across the ramp, or where it is not protected by handrails or guardrails, 
  it shall have flared sides; the maximum slope of the flare shall be 1:10 (see 
  Fig. 12(a)). Curb ramps with returned curbs may be used where pedestrians 
  would not normally walk across the ramp (see Fig. 12(b)).
(illustration showing a flared curb ramp located in a sidewalk area that is 
adjacent the access aisle of an accessible parking space. People can walk across 
the curb ramp while using the sidewalk and can use the curb ramp to get from the 
access aisle to the sidewalk.)
 
Ramps
Error/Omission:
  Landing areas where ramps change direction (e.g., switchbacks or 90° turns) 
  are too small.
Result:
  Wheelchair users are unable to go up or down the ramp because there is not 
  enough space to turn on a level surface. This makes the ramp unusable.
Requirement:
  4.8.4* (3) If ramps change direction at landings, the minimum landing size 
  shall be 60 in by 60 in (1525 mm by 1525 mm).
 
Error/Omission:
  Parts of an accessible route with slopes that exceed 1:20 lack required 
  features including handrails and edge protection.
Result:
  When a walkway or other pedestrian surface has a slope greater then 1:20, it 
  is more difficult to maintain control of a wheelchair. Wheelchair users may 
  also not be able to climb up the sloped route without railings. Lack of edge 
  protection may result in injury if a wheelchair user rolls off the side of the 
  route. People who use a mobility device such as crutches, a cane, or a walker 
  may lose their balance or fall while using a sloped section that does not have 
  handrails or edge protection.
(illustration showing a man going down a ramp in a wheelchair and falling out of 
the wheelchair after it rolls off the edge of a ramp because the ramp lacks edge 
protection)
Requirement:
  4.8.1* General. Any part of an accessible route with a slope greater than 1:20 
  shall be considered a ramp and shall comply with 4.8.
 
Stairs
Error/Omission:
  Handrail extensions are not provided at the top and bottom risers.
Result:
  People who use crutches or a cane or who have limited balance may fall at the 
  top or bottom of the stairs because they have no railing to hold onto as they 
  make the transition from the steps to the landing.
Requirement:
  4.9.4(2) If handrails are not continuous, they shall extend at least 12 in 
  (305 mm) beyond the top riser and at least 12 in (305 mm) plus the width of 
  one tread beyond the bottom riser. At the top, the extension shall be parallel 
  with the floor or ground surface. At the bottom, the handrail shall continue 
  to slope for a distance of the width of one tread from the bottom riser; the 
  remainder of the extension shall be horizontal (see Fig. 19(c) and (d)). 
  Handrail extensions shall comply with 4.4.
(illustration showing the handrail extensions on the top and bottom sections of 
the stair)
 
Doors
Error/Omission:
  Adequate maneuvering clearance is not provided at doors, including doors to 
  accessible toilet stalls.
Result:
  A person using a wheelchair cannot open the door without a clear level area in 
  front of and adjacent to the door that provides a place to maneuver.
(illustration showing a plan view of a person using a wheelchair trying to pull 
a hinged door toward them to open it. No clear space is provided adjacent to the 
latch side of the door.)
Requirement:
  4.13.6 Maneuvering Clearances at Doors. Minimum maneuvering clearances at 
  doors that are not automatic or power-assisted shall be as shown in Fig. 25. 
  The floor or ground area within the required clearances shall be level and 
  clear.
  4.17.5* Doors. Toilet stall doors, including door hardware, shall comply with 
  4.13. If toilet stall approach is from the latch side of the stall door, 
  clearance between the door side of the stall and any obstruction may be 
  reduced to a minimum of 42 in (1065 mm) (Fig. 30).
(illustration showing a plan view of an accessible door that has clear floor 
space next to the latch side of the door on the pull side and adequate 
maneuvering space in front of the door. A person using a walker is pulling the 
door open while the walker is positioned in the clear space next to the latch.)
 
Error/Omission:
  The shape of the door hardware requires tight grasping, pinching, and twisting 
  of the wrist to use.
Result:
  The door cannot be opened if the user cannot operate the latch or handle.
Requirement:
  4.13.9* Door Hardware. Handles, pulls, latches, locks, and other operating 
  devices on accessible doors shall have a shape that is easy to grasp with one 
  hand and does not require tight grasping, tight pinching, or twisting of the 
  wrist to operate. Lever-operated mechanisms, push-type mechanisms, and 
  U-shaped handles are acceptable designs. When sliding doors are fully open, 
  operating hardware shall be exposed and usable from both sides. Hardware 
  required for accessible door passage shall be mounted no higher than 48 in 
  (1220 mm) above finished floor.
(illustration showing a hand pushing down on a lever handle to open the door)
 
Circulation Paths
Error/Omission:
  Objects protrude into circulation paths from the side or from posts.
  Objects that overhang circulation paths do not provide clear headroom.
(illustration of a blind person walking into the side of a wall-mounted drinking 
fountain that is a protruding object)
Result:
  People who are blind or who have low vision can be seriously injured when they 
  cannot detect an object by using the sweep of their cane.
Requirement:
  4.1.2 (3) All objects that protrude from surfaces or posts into circulation 
  paths shall comply with 4.4.
  4.1.3 (2) All objects that overhang or protrude into circulation paths shall 
  comply with 4.4.
  4.4.1* General. Objects projecting from walls (for example, telephones) with 
  their leading edges between 27 in and 80 in (685mm and 2030 mm) above the 
  finished floor shall protrude no more than 4 in (100 mm) into walks, halls, 
  corridors, passageways, or aisles (see Fig. 8(a)). Objects mounted with their 
  leading edges at or below 27 in (685 mm) above the finished floor may protrude 
  any amount (see Fig. 8(a) and (b)). Free-standing objects mounted on posts or 
  pylons may overhang 12 in (305 mm) maximum from 27 in to 80 in (685 mm to 2030 
  mm) above the ground or finished floor (see Fig. 8(c) and (d)). Protruding 
  objects shall not reduce the clear width of an accessible route or maneuvering 
  space (see Fig.8(e)).
(illustration of a wall-mounted Automated Teller Machine (ATM) with a wing wall 
installed adjacent to the ATM to eliminate the protruding object hazard.)
  4.4.2 Head Room. Walks, halls corridors, passageways, aisles, or other 
  circulation spaces shall have 80 in (2030 mm) minimum clear head room (see 
  Fig. 8(a)). If vertical clearance of an area adjoining an accessible route is 
  reduced to less than 80 in (nominal dimension), a barrier to warn blind or 
  visually-impaired persons shall be provided (see Fig. 8(c-1)).
 
 
Toilet Rooms and Bathrooms
Error/Omission:
  Where toilet rooms or bathrooms are provided, not all public and common use 
  toilet rooms and bathrooms (including locker rooms and toilet rooms for 
  employee use) are accessible.
Result:
  People with disabilities are restricted to a limited number of toilet rooms 
  and may have to travel long distances to the accessible toilet room while 
  others can use any toilet room.
Requirement:
  4.1.3(11) Toilet Facilities: If toilet rooms are provided, then each public 
  and common use toilet room shall comply with 4.22. Other toilet rooms provided 
  for the use of occupants of specific spaces (i.e., a private toilet room for 
  the occupant of a private office) shall be adaptable. If bathing rooms are 
  provided, then each public and common use bathroom shall comply with 4.23. 
  Accessible toilet rooms and bathing facilities shall be on an accessible 
route.
 
Error/Omission:
  Toilet rooms with 6 or more toilet stalls lack a 36" wide "ambulatory" toilet 
  stall.
Result:
  Too few accessible stalls are provided for people with mobility disabilities. 
  People who walk with crutches, a cane, a walker, or who have limited balance 
  generally find it easier and safer to use a stall that has parallel grab bars.
Requirement:
  4.22.4, 4.23.4 Water Closets. If toilet stalls are provided, then at least one 
  shall be a standard toilet stall complying with 4.17; where 6 or more stalls 
  are provided, in addition to the stall complying with 4.17.3, at least one 
  stall 36 in (915 mm) wide with an outward swinging, self-closing door and 
  parallel grab bars complying with Fig. 30(d) and 4.26 shall be provided. Water 
  closets in such stalls shall comply with 4.16. If water closets are not in 
  stalls, then at least one shall comply with 4.16.
(illustration of a woman who uses crutches and leg braces sitting down on a 
toilet. She is using the two parallel grab bars.)
 
Error/Omission:
  The door to the toilet room swings into the required clear floor space at 
  accessible fixtures, controls, and dispensers.
Result:
  The entry door to the toilet room cannot be fully opened when a wheelchair 
  user is using the accessible fixture, control, or dispenser. For example, if a 
  person using a wheelchair is positioned in the clear floor space at the paper 
  towel dispenser and that clear floor space overlaps the space needed to swing 
  the door open, the door cannot be fully-opened.
Requirement:
  4.22.3*, 4.23.3* Clear Floor Space. The accessible fixtures and controls 
  required in 4.22.4, 4.22.5, 4.22.6, 4.22.7 and 4.23.4, 4.23.5, 4.23.6, and 
  4.23.7 shall be on an accessible route. An unobstructed turning space 
  complying with 4.2.3 shall be provided within an accessible toilet room. The 
  clear floor space at fixtures and controls, the accessible route, and the 
  turning space may overlap.
 
Error/Omission:
  When a transfer shower is used, it is often larger than the required 36" x 36" 
  size.
Result:
  People with disabilities may be injured when using a transfer shower that is 
  too large. Users may slide off the seat and fall onto the floor of the shower 
  while reaching for the shower controls and hand-held showerhead.
(illustration showing a plan view of a transfer shower with a man sitting on the 
folding seat and his wheelchair positioned outside the shower adjacent to the 
seat.)
Requirement:
  4.21.2 Size and Clearances. Except as specified in 9.1.2, shower stall size 
  and clear floor space shall comply with Fig. 35(a) or (b). The shower stall in 
  Fig. 35(a) shall be 36 in by 36 in (915 mm by 915 mm). Shower stalls required 
  by 9.1.2 shall comply with Fig. 57(a) or (b). The shower stall in Fig. 35(b) 
  will fit into the space required for a bathtub.
(illustration showing a 36 in by 36 in shower compartment equipped with seat, 
hand-held shower head, grab bar and shower curtain.)
 
Signage
Error/Omission:
  Where permanent room identification signage is provided, it is mounted in the 
  wrong location.
Result:
  People who are blind or visually impaired are trained to look in a consistent 
  location for tactile signs. They cannot find the sign if it is not mounted in 
  the correct location.
Requirement:
  4.1.3(16)(a) Signs which designate permanent rooms and spaces shall comply 
  with 4.30.1, 4.30.4, 4.30.5 and 4.30.6.
  4.30.6 Mounting Location and Height. Where permanent identification is 
  provided for rooms and spaces, signs shall be installed on the wall adjacent 
  to the latch side of the door. Where there is no wall space to the latch side 
  of the door, including at double leaf doors, signs shall be placed on the 
  nearest adjacent wall. Mounting height shall be 60 in (1525 mm) above the 
  finish floor to the centerline of the sign. Mounting location for such signage 
  shall be so that a person may approach within 3 in (76 mm) of signage without 
  encountering protruding objects or standing within the swing of a door.
(illustration showing a sign designating room number 131 with raised characters 
and Braille. The sign is mounted next to the latch side of the door.)
 
Visual Alarms
Error/Omission:
  No visual alarms are provided although an audible alarm system is installed.
Result:
  People who are deaf have no way of knowing that a building emergency has been 
  declared while others who can hear are alerted by the audible alarm. This is 
  especially true of toilet rooms, and study carrel areas where occupants cannot 
  observe others leaving the facility.
Requirement:
  4.1.3(14) If emergency warning systems are provided, then they shall include 
  both audible alarms and visual alarms complying with 4.28. Sleeping 
  accommodations required to comply with 9.3 shall have an alarm system 
  complying with 4.28. Emergency warning systems in medical care facilities may 
  be modified to suit standard health care alarm design practice.
  4.28.1 General. Alarm systems required to be accessible by 4.1 shall comply 
  with 4.28. At a minimum, visual signal appliances shall be provided in 
  buildings and facilities in each of the following areas: restrooms and any 
  other general usage areas (e.g., meeting rooms), hallways, lobbies, and any 
  other area for common use.
 
Drinking Fountains
Error/Omission:
  All drinking fountains are mounted with the spout at 36" A.F.F.
Result:
  People who have difficulty stooping or bending over are not able to get a 
  drink from the accessible 36" high drinking fountain.
Requirement:
  4.1.3(10)* Drinking Fountains:
  (a) Where only one drinking fountain is provided on a floor there shall be a 
  drinking fountain which is accessible to individuals who use wheelchairs in 
  accordance with 4.15 and one accessible to those who have difficulty bending 
  or stooping. (This can be accommodated by the use of a "hi-lo" fountain; by 
  providing one fountain accessible to those who use wheelchairs and one 
  fountain at a standard height convenient for those who have difficulty 
  bending; by providing a fountain accessible under 4.15 and a water cooler; or 
  by such other means as would achieve the required accessibility for each group 
  on each floor.)
   
  (b) Where more than one drinking fountain or water cooler is provided on a 
  floor, 50% of those provided shall comply with 4.15 and shall be on an 
  accessible route.
 
Restaurants
Error/Omission:
  Food service queuing areas are too narrow and do not provide adequate clear 
  width for turns.
Result:
  People who use wheelchairs cannot get to the counter to purchase or pick up 
  food. Sometimes they get into the queuing area and get trapped.
Requirement:
  4.3.3 Width. The minimum clear width of an accessible route shall be 36 in 
  (915 mm) except at doors (see 4.13.5 and 4.13.6). If a person in a wheelchair 
  must make a turn around an obstruction, the minimum clear width of the 
  accessible route shall be as shown in Fig. 7(a) and (b).
 
Error/Omission:
  Condiment or utensil items are placed above the reach range or are not located 
  on an accessible route.
Result:
  Wheelchair users cannot obtain condiments and other items because the items 
  are out of reach or there is no way to get to the items.
Requirement:
  5.6 Tableware and Condiment Areas. Self-service shelves and dispensing devices 
  for tableware, dishware, condiments, food and beverages shall be installed to 
  comply with 4.2 (see Fig. 54).
 
Transient Lodging
Error/Omission:
  In hotels, motels, or other lodging facilities of 50 or more sleeping rooms, 
  no rooms with roll-in showers are provided, or the roll-in showers that are 
  provided lack a fold-down seat.
Result:
  People who must use a roll-in shower or a shower with a fold-down seat cannot 
  bathe. When a roll-in shower is provided without a folding seat, guests may 
  resort to using guest room furniture in the shower.
(illustration showing a person using a wheelchair in a roll-in shower that is 
not equipped with a fold-down seat.)
Requirement:
  9.1.2 Accessible Units, Sleeping Rooms, and Suites. Accessible sleeping rooms 
  or suites that comply with the requirements of 9.2 (Requirements for 
  Accessible Units, Sleeping Rooms, and Suites) shall be provided in conformance 
  with the table below. In addition, in hotels, of 50 or more sleeping rooms or 
  suites, additional accessible sleeping rooms or suites that include a roll-in 
  shower shall also be provided in conformance with the table below. Such 
  accommodations shall comply with the requirements of 9.2, 4.21, and Figure 
  57(a) or (b).
 
Error/Omission:
  Wheelchair-accessible rooms are not equipped with visual alarms and 
  notification devices.
Result: 
  People who are deaf or hard of hearing and who also need to use a guest room 
  with accessible features have no accommodation.
Requirement:
  9.2.2 (8) Sleeping room accommodations for persons with hearing impairments 
  required by 9.1 and complying with 9.3 shall be provided in the accessible 
  room or suite.
 
Error/Omission:
  Doors into and within guest rooms that are not accessible guest rooms do not 
  provide at least 32" clear opening width.
Result: 
  People who use a wheelchair, scooter, or walker are unable to enter standard 
  guest rooms and are excluded from accommodations when accessible guestrooms 
  are occupied.
Requirement:
  9.4 Other Sleeping Rooms and Suites. Doors and doorways designed to allow 
  passage into and within all sleeping units or other covered units shall comply 
  with 4.13.5.
(illustration showing a man who is using a wheelchair passing through a doorway. 
The door is equipped with round doorknobs.)
 
 
Reproduction of this document is encouraged.
 
6/97

 
Return to the ADA Publications Page
Return to the ADA Home Page 
last update October 15, 2002