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Scoping and path of travel upgrade requirements for facility alteration, addition and structural repair projects

Did you know there are specific requirements that must be met when you make additions or alterations to your property? I have listed, with detailed explanation, the requirements below for your convenience and review.

    1. Accessibility: You must make certain that the facility that is being altered is accessible to all patrons. The accessible path of travel must extend from the altered primary function area to site arrival points, including public sidewalks, parking and passenger loading zones provided on the site. The path of travel also includes access to restrooms, telephones, and drinking fountains, where they are provided to serve the primary function area. In leased facilities, alterations made by a tenant to primary function areas that only the tenant occupies do not trigger a path of travel obligation upon the landlord with respect to areas of the facility under the landlord’s authority if those areas are not otherwise being altered.

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  1. Disproportionality Rule: If, for some reason, the path cannot be made accessible, you must submit an analysis to the Building Official demonstrating that the cost of making the path of travel accessible is disproportionate to the cost of the alterations or the additions to the primary area. Regulations implementing the standards define “disproportionate” as exceeding 20% of the total cost of alterations to the primary function area. The 20% cap applies only to costs associated with the accessible path of travel, including an accessible route to the primary function area from site arrival points, entrances, and retrofits to restrooms, telephones, and drinking fountains.
  2. Prioritization: Compliance is required up to the point the 20% cost cap is reached, even where it does not result in a fully accessible path of travel. Where costs exceed this cap, compliance should be prioritized in this order:
    • an accessible entrance
    • an accessible route to the primary function area
    • restroom access
    • an accessible telephone
    • an accessible drinking fountain
    • access to other elements such as parking and storage

I hope this has provided you with useful information. I am available to assist you to ensure you are in compliance with all codes. Here are some additional websites and documents you may find of use.

www.documents.dgs.ca.gov/dsa/pubs/IR_11B-10_04-27-15.pdf

www.documents.dgs.ca.gov/dsa/pubs/PR_15-01.pdf

www.disabled-world.com/definitions/ada-glossary.php

Bill Holl is the Bay Area’s premier ADA consultant with over 45 years architectural experience. He specializes in providing Silicon Valley ADA Consultant services and ADA Compliance services across South Bay cities including San Jose, Palo Alto, Santa Clara, Los Gatos, Campbell and more. He also provides ADA compliance consulting throughout most areas of California including Monterey, Carmel, Santa Cruz, Morgan Hill, Gilroy and the entire San Francisco Bay Area. Give us a call today to schedule your next consultation, and let us keep your business protected from fines and lawsuits.