US Department of Justice Civil Rights Division - Letter - Tal529

JUL 22 1994
Mr. Gene Colin

Chair
State Building Code Council
State of Washington
906 Columbia Street SW
P.O. Box 48300
Olympia, Washington 98504-8300
Dear Mr. Colin:
Thank you for your supplemental submissions of August 20,

1993, and March 23, 1994, in support of your request for
certification that the Washington State Regulations for Barrier
Free Design (WSR), as adopted on November 8, 1991, and amended on
November 13, 1992, meet or exceed the new construction and
alterations requirements of title III of the Americans with
Disabilities Act (ADA). We greatly appreciate your thorough
responses to our initial review of the WSR.
We are still awaiting written confirmation from your staff

of the legal effect of the State Building Code Council's
(Council) "interpretations" of the WSR, and without such
confirmation we are unable to issue a preliminary determination
regarding certification. However, in order to avoid any
unnecessary delay, we have proceeded to review the WSR and the
additional information, explanations, interpretations, and
amendments provided in your recent submissions.
Our analysis of the material you have submitted is discussed

in detail in the attached side-by-side comparison. That analysis
addresses only the issues raised in our initial response to your
certification request and those raised by the 1992 amendments to
the WSR. For each issue, the side-by-side comparison contains
the relevant ADA provision in the left column, the WSR provision,
with any amendments, in the center column, and the Department's
original (May 1993) comment in the right column. Following that,
the comparison provides, in the center column, the Council's
cc: Records; Chrono; Wodatch; Blizard; Hill; FOIA

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"comment" (italicized) and, in the right column, our response
(underlined and bracketed) to the Council's comment. Following
that, the analysis provides, in the center column, any
interpretation (italicized and underlined) issued by the Council
to address the issue, and, in the right column, our response
(underlined and bracketed) to the interpretation.
Based on this analysis, we have determined that in only a

very few areas does the WSR not meet or exceed the relevant
requirements of title III of the ADA. Therefore, upon correction
of these few remaining problems, we propose to recommend that the
Assistant Attorney General issue a preliminary determination of
equivalency pursuant to 42 U.S.C. S 12188(b)(1)(A)(ii) and 28
C.F.R. SS 36.601 et seq.
The remaining areas of nonequivalency are discussed below

and noted in the right column of the side-by-side analysis in
underlined and bracketed text. Many of these issues may be
addressed through further interpretations of the WSR. A few
others may require amendments to the WSR.
A number of items that do not necessarily pose obstacles to

certification require further discussion:
1) A number of items that are addressed by the ADA

Standards for Accessible Design (ADA Standards), 28 C.F.R. Part
36 Appendix A, are not addressed by the WSR, including limited-
flow toilet paper dispensers (Standard 4.16.6), telephone books
(Standard 4.31.7), and audible alarms (Standard 4.28.2). These
omissions from the WSR are based, in part, on the difficulty of
regulating such items at the pre-construction/pre-occupancy
stage. Because the omissions are limited to such "non-code"
items, they will not prevent certification. Rather, the
certification determination will not apply to those omitted items
at all. Therefore, if such equipment is installed in a building,
the certification determination will not constitute evidence of
ADA compliance with respect to such equipment. 28 C.F.R.
S36.607(a)(1). This limitation of the certification
determination should be noted in any publication of the WSR if
certification is issued.
2) The certification determination will be limited to the

version of the WSR, including the amendments and interpretations,
that has been submitted to the Department. The certification
determination will not apply to amendments or interpretations
that have not been submitted to and reviewed by the Department.
This limitation should be noted in any publication of the WSR if
certification is issued. In addition, any future uncertified
amendments should be distinguished from the certified version of
the WSR. Finally, because the certification determination will
be based, in part, on official interpretations of the WSR, those
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interpretations should be made public and published together with

the WSR.
3) The certification determination will not apply to

waivers granted under the WSR by local building officials. 56
Fed. Reg. 35592 (July 26, 1991), 28 C.F.R. Part 36, Appendix B.
Therefore, if a builder receives a waiver, modification,
variance, or other exemption from the requirements of the WSR for
any element of construction or alterations, the certification
determination will not constitute evidence of ADA compliance with
respect to that element. Examples of such waiver provisions
include WAC S 51-20-3101(e) (allowing modifications where full
compliance is impractical), WAC S 51-20-3113 and S 51-20-3114
(allowing modifications when full compliance would threaten or
destroy the historic value of a historic building), and WAC S 51-
20-3112(a)(2) (allowing a 20% cost limit on provision of access
in the path of travel to altered primary function areas). This
limitation of the certification determination should be noted in
any publication of the WSR if certification is issued.
4) The WSR relies on building classifications that differ

from those used by the ADA. This will not prevent certification
of the WSR because the effects of these differences on
accessibility have been substantially eliminated by the Council's
interpretations. It should be made clear to building code
enforcement officials that the WSR's general classifications
should be applied flexibly in the context of accessibility to
ensure full ADA compliance.
5) The Appendix to the WSR contains the "U.S.

Architectural and Barriers Compliance Board Americans with
Disabilities Act Guidelines for Automated Teller Machines," WAC
S 51-20-93120. These provisions contain the former ADA Standards
for ATMS. On January 18, 1994, however, the Department amended
the ADA Standards regarding ATMs. The amended version is
enclosed. The WSR Appendix, therefore, should be amended to
reflect the current ADA Standards.
6) The WSR does not address transportation facilities.

The ADA provides special accessibility requirements for such
facilities (by amendment dated January 18, 1994, enclosed). This
difference between the WSR and ADA will not prevent
certification. However, the certification determination will not
apply to any elements in transportation facilities that are
subject to section 10 of the ADA Standards and, therefore, will
not constitute evidence of ADA compliance with respect to such
elements. This limitation on the certification determination
should be noted in any publication of the WSR if certification is
issued. If the Council were to adopt accessibility requirements
for transportation facilities, those requirements could be
submitted to the Department for certification at a later date.
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The following issues need to be corrected before a

certification determination can be issued (page references are to
the side-by-side comparison):
1) Maneuvering clearances at doors (Standard 4.13.6, p.

77). The WSR fails to address the different requirements for
different approaches to doors (i.e., hinge-side and latch-side).
Instead, the code addresses only front approaches, assuming that
providing the maneuvering clearance required for front approach
will be sufficient, even if a side approach is required. This
assumption is not valid. The size, shape, and placement of
maneuvering clearances must change when the approach changes.
Nor is it always possible to provide a front approach. In
addition, the WSR assumes that the size of the maneuvering space
is the only important factor. To the contrary, the shape and
placement of the maneuvering space are also essential. In order
to meet the ADA Standard, the WSR will need to be amended to
provide the different space configurations needed for different
approaches.
2) Grab bars (Standard 4.16.4, p. 86). The WSR does not

correctly address all aspects of the required placement of grab
bars at water closets. The WSR fails to require side grab bars
to begin no more than 12 inches from the back wall and to extend
at least 54 inches from the back wall (WSR would require only
extension to 48 inches from the back wall). This extension is
necessary for people who need to reach far forward to pull to a
standing position. The WSR also fails to require back grab bars
to extend at least 12 inches beyond the center of the water
closet and at least 24 inches toward the open side of the water
closet. This placement is necessary to allow a diagonal transfer
to the toilet when needed. An amendment will be necessary to
meet the ADA Standard.
3) Food service shelves (Standard 5.5, p. 108). The WSR

generally requires at least one shelf to be accessible. However,
for food service lines, the ADA requires 50% of shelves to be
accessible. The Council has issued an interpretation purporting
to require 50% to be accessible. However, because this
interpretation contradicts the code provision, the
"interpretation" approach fails to provide appropriate guidance
of the requirement. An amendment to the WSR is needed here.
4) Tableware and condiment areas (Standard 5.6, p. 109).

The WSR provision references another code provision. However,
the reference is erroneous. The Council has issued an
interpretation directing readers to the correct provision.
However, simply issuing an interpretation does not provide
effective notice of the change and does not effectively correct
the error in the code.
01-03195 -5-
5) Elements in showers and bathtubs:
a) Shower seats (Standard 4.21.3, p. 92). The WSR

fails to require that shower seats be L-shaped. The L shape
permits people to sit in the corner of the shower and use both
walls for support.
b) Shower controls (Standard 4.21.5, p. 93). The WSR

addresses placement of shower controls only in an interpretation.
That interpretation fails to specify that such controls must be
located at specific points on the wall, but, instead, simply
requires them to be offset. Offsetting controls is not
sufficient to ensure that they are always reachable. If a shower
were built to the minimum accessibility requirements, offsetting
may be acceptable, but if a shower were built larger than the
minimum, offset controls may not be reachable.
c) Bathtub controls (Standard 4.20.5, p. 90). The
WSR requires bathtub controls to be placed no more than 24 inches
from the clear side of the tub. The ADA requires them to be
offset between the midpoint of the tub and the outer edge.
Although in very wide tubs (over 48 inches), the Washington
requirement may exceed the ADA requirement, in standard tubs the
ADA provision is better, because the midpoint of the tub will
likely be 15-16 inches from the edge.
d) Clear floor space (Standard 4.21.2, p. 91). The

WSR does not require the clear floor space at a transfer shower
to extend 12 inches beyond the seat wall, as ADA Figure 35 does.
This space is necessary to allow a wheelchair to be placed to
permit transfer without obstructing the seat.
6) Parking at medical care facilities (Standard 4.1.2(5),

p. 26). The ADA requires accessible parking in increased
percentages at medical care facilities - 10% at outpatient
facilities and 20% at (inpatient and outpatient) facilities that
specialize in mobility impairments. The WSR requires 10% at all
outpatient facilities and doctors' offices and 20% only at
inpatient mobility-specialty facilities. Thus, outpatient
mobility specialists are required to provide 20% accessible
parking under the ADA, but only 10% under the WSR.
The WSR requires provision of 10% accessible spaces at

physicians' offices; the ADA does not. However, outpatient
mobility specialists create the greatest need for accessible
parking, while physicians' offices create a lesser such need.
Although the WSR approach may result in a larger total number of
accessible spaces in the State of Washington, the spaces will be
not be placed where they are most needed.
7) Elevator exception (Standard 4.1.3(5), p. 28; see also

pp. 21 and 24). The ADA provides that, generally, no elevator is
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required in multi-story buildings (1) that are less than three
stories or (2) that have less than 3000 square feet per story.
The comparable WSR provision provides an exception to the general
requirement to install an elevator for "floors above and below
accessible levels that have areas of less than 3000 square feet
per floor." S 51-20-3103(b)(2). This language is ambiguous
because it is not clear that all floors must be less than 3000
square feet (not just the accessible floor). This language
raises the possibility that if one floor is accessible and has
less than 3000 square feet, the Washington code would allow all
other floors to have no elevator access, regardless of the size
of the floors.
Although the WSR exceeds the ADA in that it does not extend
the elevator exception to most two-story buildings, this is not
sufficient to make up for the nonequivalency of the exception for
small floors.
8) Alterations. Because the WSR requires all routes in

new construction to be accessible, a number of the ADA Standards'
requirements that items be placed on an accessible route are
superfluous in the context of new construction under WSR.
However, such requirements are necessary under WSR for
alterations, where not all routes may be accessible:
a) Protruding objects (Standard 4.1.2(3), p. 25;

Standard 4.4, p. 58). The WSR provision regarding protruding
objects limits protrusions into an "accessible route of travel,
corridor, pathway, or aisle." S 51-20-3106(e). This appears to
apply only to routes that are accessible to people who use
wheelchairs. However, the ADA protrusion limits serve primarily
people with vision impairments. Therefore, protrusions cannot be
allowed in any route.
b) Self-service shelves (Standard 5.5, p. 108). The

WSR was amended to remove the requirement that self-service
shelves be on an accessible route.
9) Unisex toilet rooms (Standard 4.1.6(3)(e), p. 48). The

WSR fails to require that, when a unisex toilet room is installed
in alterations, it must be placed in the same area as the
existing toilet facilities.
10) Companion seating (Standard 4.33.3, p. 104). The WSR

fails to require companion seats to be adjacent to accessible
seats. The Council states that the code's requirement that
accessible seating be "an integral part of any fixed seating
plan" is sufficient. However, it is not clear that "integral"
means that every accessible seat must be next to a companion
seat. That meaning needs to be made more clear.
1-03197 -7-
11) Location of lavatories:
a) Water closets (Standard 4.16.2, p. 85). The WSR

allows a lavatory to be installed in the clear floor space at a
water closet. The ADA does not permit such a lavatory if the
water closet is in a stall. The Council responded to this issue
by stating that a lavatory could not be put in a stall because
such a lavatory would reduce the required width of the stall.
The reasoning behind this statement is unclear and needs to be
explained.
b) Bathtubs (Standard 4.20.2, p. 88). The WSR fails

to specify that, if a lavatory is placed in the clear floor space
of a bathtub, it can never be placed at the end of the tub where
the seat is located, but may only be placed at the control end of
the tub.
12) Diagonal curb ramps (Standard 4.7.10, p. 63). The ADA

provides special standards for diagonal curb ramps; the WSR does
not. The Council argues that it is not necessary to address
diagonal curb ramps because they are rarely used in private
development. The WSR would require such ramps to be accessible
if they were in an accessible route. However, the standards for
accessibility would be the same as that for curb ramps generally.
Therefore, the bottom of the ramp would not be required to have
48 inches of clear space. This clear space limitation is
necessary at diagonal ramps to allow people to maneuver out of
the intersection. In addition, 24 inches of straight curb on
either side would not be required if the ramp had flared sides.
This straight space is needed to lessen foot traffic on diagonal
ramps.
13) Tactile signage (Standard 4.30.4, p. 101). The WSR

technical requirements for raised characters have been amended.
The amendment has removed the requirement that such characters be
in simple typeface. Therefore, the amended code is not
equivalent to the ADA.
14) Knee clearance at tables (Standard 4.32.3, p. 103).

The WSR fails to require that knee clearance be at least 19
inches deep at tables and counters.
15) Transient lodging (Standard 9.2.2(6), p. 116). The WSR

does not specifically require carports that serve accessible
hotel rooms to be accessible. It only addresses such facilities
if they serve type A (residential) dwelling units.
We understand from your letter of March 23, 1994, that the

Council is currently in the process of updating the WSR and we
hope that our analysis will be helpful in that effort. Our staff
would also be happy to meet with Council representatives to
answer any questions that you may have about our analysis.
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Our offices have worked diligently together over a long

period of time and we stand on the threshhold of achieving the
nation's first ADA-certified State code. Almost all of our work
is done. I hope that we can reach agreement on the few remaining
issues. We look forward to recommending certification of the WSR
as soon as the remaining issues can be resolved. If you have any
questions concerning this letter, please call Eve Hill at (202)
307-0663.
Sincerely,
John L. Wodatch
Chief
Public Access Section
Enclosures:
Side-by-side comparison
Regulations Regarding ATMs and
Transportation Facilities
cc: Mr. Lawrence W. Roffee

Executive Director
U.S. Architectural & Transportation Barriers
Compliance Board
01-03199
ADA Requirements
1. Purpose. This document sets guidelines for accessibility to

places of public accommodation and commercial facilities by
individuals with disabilities. These guidelines are to be applied
during the design, construction, and alteration of such buildings
and facilities to the extent required by regulations issued by
Federal agencies, including the Department of Justice, under the
Americans with Disabilities Act of 1990.
The technical specifications 4.2 through 4.35 of these guidelines

are the same as those of the American National Standard
Institute's document A117.1-1980, except as noted in this text by
italics. However, sections 4.1.1 through 4.1.7 and sections 5
through 10 are different from ANSI A117.1 in their entirety and
are printed in standard type.
The illustrations and text of ANSI A117.1 are reproduced with

permission from the American National Standards Institute.
Copies of the standard may be purchased from the American
National Standards Institute at 1430 Broadway, New York, New
York 10018.
Washington State Regulations
51-20-002 Purpose. The purpose of these rules is to

implement the provisions of chapter 19.27 RCW, which
provides that the state building code council shall maintain
the State Building Code in a status which is consistent with
the purpose as set forth in RCW 19.27.020. In maintaining
the codes the council shall regularly review updated versions
of the codes adopted under the act, and other pertinent
information, and shall amend the codes as deemed
appropriate by the Council.
RCW 19-27-020 (5). To provide for standards and
specifications for making buildings and facilities accessible to
and usable by physically disabled persons.
51-20-003 Uniform Building Code. The 1991 edition of the
Uniform Building Code as published by the International
Conference of Building Officials and available from the
International Conference of Building Officials, 5360 South
Workman Mill Road, Whittier, California 90601 is hereby
adopted by reference with the following additions, deletions,
and exceptions.
41-20-005 Uniform Building Code Requirements for Barrier-
Free Accessibility. Chapter 31 and other Uniform Build Code
requirements for barrier-free access are adopted pursuant to
chapters 70.92 and 19.27 RCW.
Commentary
E - Equivalent
NE - Not equivalent to ADA provisions
PNE - Possibly/potentially not equivalent to ADA provisions
Strike through = material deleted since prior DOJ review

[Underline] = material added since prior DOJ review
Italic = Washington response to DOJ comments
ADA/Washington State July 12, 1994
01-03200
1. Purpose, continued.
Pursuant to RCW 19.27.040, Chapter 31 and requirements

affecting barrier-free access in Sections 3304 (b), 3304 (h),
3306 (g) and 3306 (i) shall not be amended by local
governments.
In case of conflict with other provisions of this code, chapter

31 and requirements affecting barrier-free access in Sections
3304 (b), 3304 (h), 3306 (g), and 3306 (i) shall govern.
51-20-3101 Scope. (a) General. Buildings or portions of

buildings shall be accessible to persons with disabilities as
required by this chapter. Chapter 31 has been amended to
comply with the Federal Fair Housing Act (FFHA) Guidelines
as published by the U.S. Department of Housing and Urban
Development (March 1991) and the Americans with
Disabilities Act (ADA) Guidelines as published by the
Architectural and Transportation Barriers Compliance Board
and the Department of Justice (July 1991).
Reference is made to appendix Chapter 31 for FFHA and ADA

requirements not regulated by this chapter.
(b) Design. The design and construction of accessible

building elements shall be in accordance with this chapter.
For a building, structure, or building element to be considered
to be accessible, it shall be designed and constructed to the
minimum provisions of this chapter.
51-20-3102 Person with Disability is an individual who has

an impairment, including a mobility, sensory, or cognitive
impairment, which results in a functional limitation in access
to and use of a building or facility.
2 ADA/Washington State July 12, 1994
01-03201
Comment: Issue 1. It is acknowledged that the purpose of

the ADA is a civil rights law designed to prohibit
discrimination against persons with disabilities as defined in
the Act and its regulations. It is further recognized that the
ADA regulations attempt to provide for compliance with the
act through regulations affecting policies and procedures as
well as construction.
The Washington Barrier-free facilities regulations are only

construction regulations. The State Building Code Council is
granted authority to promulgate accessibility construction
standards under Chapter 70-92 of the Revised Code of
Washington (RCW). The WAC process is similar to the
federal regulatory process. Through the WAC process
legislation is clarified and rules for enforcement are
established. The Council can expand coverage in the
adoption of the WAC as long as it isn't conflicting with the
RCW. The provision of concern in the analysis is a provision
of the RCW as adopted in 1973. The WAC is broader in
application. Review of the scope and purpose statements
found in Sec. 3101 will not reveal similar language limiting
application to the "physically handicapped." Also to be taken
into consideration is the adopted definition of "person with
disability" found in Sec. 3102 which reads: "person with
disability is an individual who has an impairment, including a
mobility, sensory, or cognitive impairment, which results in a
functional limitation in access to and use of a building or
facility."
The Washington regulations were written to incorporate the

standards for new construction and alteration contained in
the Title III regulations of ADA. As such, the intent of the
Washington regulations is to "protect" persons with
disabilities as well as they are "protected" by the ADAAG,
regardless of there [sic] specific type of disability. While the
"stated" purpose may not be identical, the net result is the
same, construction and alteration of buildings to be
accessible.
[E. Section 3102 does seem to include all disabilities that

are affected by building construction. Therefore, the
substantive coverage is equivalent.]
01-03202
Assembly Area. A room or space accommodating a group of

individuals for recreational, educational, political, social, or
amusement purposes, or for the consumption of food and drink.
Chapter 4 Definitions and Abbreviations Section 402.

Assembly Building is a building or portion of a building used
for the gathering together of 50 or more persons for such
purposes as deliberation, education, instruction, worship,
entertainment, amusement, drinking or dining or awaiting
transportation.
Comment: Issue 2. The Uniform Building Code treats small

assembly spaces as part of the major occupancy of the
building. Most of these are Business (B) or Education (E)
occupancies. For example, a small restaurant, is a B-2
occupancy. A small conference room in an office building is
a B-2 occupancy. A classroom at a university or private or
technical college is a B-2. A classroom at a grade school or
high school will either be a E-1 or E-2. Anticipating this
difference, the requirement for assistive listening systems is
specifically referenced in the requirements for B and E
occupancies (Sec. 3103(a)3 and 4, respectively). In addition
the regulation on fixed seats and tables which you might find
in a small restaurant is a general requirement contained in
Sec. 3105(d)5. Since the exception to allow a portion of
seats in a restaurant to be located in an inaccessible
mezzanine applies only to A occupancies in the Washington
regulations, it could not be used in smaller assembly spaces.
In this regard the WSR code provides greater accessibility
than ADA.
Not clearly referenced for small assembly spaces are the

requirements for wheelchair spaces. The code does require
each space, including such small assembly spaces to be
accessible. We believe that assembly spaces where the total
occupant load is less than 50 which also have fixed seats are
fairly rare. The most likely location would be in some
classrooms. In order to clarify the application of the code to
these circumstances, the Council has issued Interpretation
No. 93-32. It should be noted that the Washington Code
requires distribution of wheelchair locations in all assembly
occupancies, even those with fewer than 300 fixed seats.
On balance we believe that the total set of regulations of
assembly areas is equivalent.
01-03203
Dwelling Unit. A single unit which provides a kitchen or food

preparation area, in addition to rooms and spaces for living,
bathing, sleeping, and the like. Dwelling units include a single
family home or a townhouse used as a transient group home; an
apartment building used as a shelter; guestrooms in a hotel that
provide sleeping accommodations and food preparation areas; and
other similar facilities used on a transient basis. For purposes of
these guidelines, use of the term "Dwelling Unit" does not imply
the unit is used as a residence.
Interpretation 93-32.
Question: Are wheelchair spaces required in assembly areas
which are not assembly occupancies, specifically assembly
spaces with fixed seats and an occupant load of less than
50?
Answer: Yes. The intent of the code, as provided in Sec.

3101(a), is to provide standards equivalent to the ADA
Accessibility Guidelines. Regardless of occupancy
classification, for assembly areas of 4 to 25 seats, one
wheelchair location is required, for areas of 26 to 50 seats,
two wheelchair locations are required. (See Table 31-A).
Sec. 405 D. Dwelling Unit is any building or portion thereof

which contains living facilities, including provisions for
sleeping, eating, cooking and sanitation, as required by this
code, for not more than one family, or a congregate residence
for 10 or less persons.
Dwelling Unit, Type A is an accessible dwelling unit that is

designed and constructed [in accordance with this chapter] to
provide greater accessibility than a Type B dwelling unit.
(Type A dwelling units constructed in accordance with this
Chapter also meet the design standards for Type B dwelling
units.)
Dwelling Unit, Type B is an accessible dwelling unit that is

designed and constructed [in accordance with this chapter.]
[(Type B Dwelling Unit Standards are based on] the U.S.
Department of Housing and Urban Development [(HUD)]
Federal Fair Housing Act Accessibility Guidelines.[)]
Single-Story Dwelling Unit is a dwelling unit with all finished

living spaces located on one floor.
Multistory Dwelling Unit is a dwelling unit with finished living

space located on one floor, and the floor or floors
immediately above or below it.
[E. when read together with Table 31-A and S 3105.]
01-03204
Mezzanine or Mezzanine Floor. That portion of a story which is an

intermediate floor level placed within the story and having
occupiable space above and below its floor.
Primary Entry[ance] is a principal entrance through which

most people enter the building. A building may have more
than one primary entry.
Primary Entry[ance] Level is the floor or level of the building
on which the primary entry is located.
Comment: Issue 4. The 1992/93 amendments changed the

term entry to entrance in all locations to eliminate this
possible difference between ADA and Washington. [See
page 599b of the Published Code.] The intent is the same
and training being provided around the State includes the
ADA concept of entrances.
Chapter 4 Definitions and Abbreviations Section 414

Mezzanine or Mezzanine Floor is an intermediate floor placed
within a room.
Comment: Issue 5. ADA and Washington definitions are

very similar. The ADA differentiation between mezzanine and
raised or lowered floor area does not occur in the ADA
definition, but must be discovered by combining the various
provisions in Section 5.
Similarly, the limitations on mezzanine design are found in

Section 1717 of the UBC and Washington Code (attached).
The key regulation is that the "clear height above and below
the mezzanine floor construction shall not be less than 7
feet." It is clear from UBC that more than a simple raised or
lowered area must be provided to be considered a mezzanine.
This is clearer than the ADA which does not succinctly
distinguish when a raised area becomes an intermediate floor
level.
Chapter 4, Section 408 Grade (Adjacent Ground Elevation) is
the lowest point of elevation of the finished surface of the
ground, paving or sidewalk within the area between the
building and the property line or, when the property line is
more than 5 feet from the building, between the building and
a line 5 feet from the building.
[E.]
[E.]

01-03205
Comment: Issue 3. The analysis has confused the

application of the phrase of "for 10 or less persons"
contained in the UBC definition as applying to the whole
definition. In[sic] only applies to congregate residences of 10
or less persons as being included in the definition of a
"dwelling unit." Congregate residences of larger than 10
persons are treated differently in the UBC. The ADA
definitions of dwelling unit is at odds with the definition of
dwelling unit used in almost all building and zoning codes by
indicating a dwelling unit is used as transient lodging. This
definitional difference has no effect on the accessibility
requirements as applied in the Washington Code. In order to
give assistance to local building officials in applying the
Washington Code in these cases, the Council has issued
Interpretation No. 93-39.
01-03206
Entrance. Any access point to a building or portion of a building

or facility used for the purpose of entering. An entrance includes
the approach walk, the vertical access leading to the entrance
platform, the entrance platform itself, vestibules if provided, the
entry door(s) or gate(s), and the hardware of the entry door(s) or
gate(s).
Interpretation 93-39:
Question: For purposes of accessibility requirements of
Chapter 31, how should buildings such as homeless shelters,
halfway houses, transient group homes, and similar social
service establishments where people may sleep or temporarily
reside be classified? Similarly, how should apartments or
condominium complexes be classified where some or all of
the units are rented to short term quests.
Answer: The intent of the code, as provided in Sec. 3101(a),
is to provide standards equivalent with the ADA Accessibility
Guidelines.
For the purpose of determining accessibility requirements per

Chapter 31, uses such as homeless shelters, halfway houses,
transient group homes, and similar facilities should be
reviewed on a case by case basis. While these uses are
"residential" in nature, if the residents are considered
transient, classification as R-1 hotel, or R-3 lodging house is
more appropriate. Some may need to be classified either in
an I (Institutional) or B (Business) category. If services are
provided at the site such as job or health counseling,
classification should be in a category which requires
accessibility. These uses should not be categorized as
congregate residence when the residents are essentially
transient.
Apartments or condominiums which are rented on a short

term basis to transient guests should be categorized as either
a Group R-1, hotel, or Group R-3 lodging house with
appropriate accessibility provided.
[E.]
01-03207
Ground Floor. Any occupiable floor less than one story above or
below grade with direct access to grade. A building or facility
always has at least one ground floor and may have more than one
ground floor as where a split level entrance has been provided for
where a building is built into a hillside.
Story. That portion of a building included between the upper

surface of a floor and upper surface of the floor or roof next
above. If such portion of a building does not include occupiable
space, it is not considered a story for purposes of these guidelines.
There may be more than one floor level within a story as in the
case of a mezzanine or mezzanines.
51-20-0407 Section 407 Floor Area is the area included

within the surrounding exterior walls of a building or portion
thereof, exclusive of vent shafts and courts. The floor area
of a building, or portion thereof, not provided with
surrounding exterior walls shall be the usable area under the
horizontal projection of the roof or floor above.
Ground Floor is any occupiable floor less than one story
above or below grade with direct access to grade. A building
may have more than one ground floor.
51-20-0420 Section 420 Story is that portion of a building

included between the upper surface of any floor and the
upper surface of the floor next above, except that the
topmost story shall be that portion of a building included
between the upper surface of the topmost floor and the
ceiling or roof above. If the finished floor level directly above
a usable or unused under-floor space is more than 6 feet
above grade as defined herein for more than 50 percent of
the total perimeter or is more than 12 feet above grade as
defined herein at any point, such usable or unused under-floor
space shall be considered as a story.
51-20-0320 Section 420 Story. First is the lowest story in a

building which qualifies as a story, as defined herein, except
that a floor level in a building having only one floor level shall
be classified as a first story, provided such floor level is not
more than 4 feet below grade, as defined herein, for more
than 50 percent of the total perimeter, or not more than 8
feet below grade, as defined herein, at any point.
01-03208
Comment: Issue 6. The term "story" in the UBC serves

more specific purposes than the term does in ADA and
therefore the definition is more specific. The UBC limits
types of construction (wood vs concrete vs steel) based on
the number of stories. The UBC also limits certain
occupancies (uses) are limited to 1st stories. These examples
show the importance of knowing exactly what a story is.
There is no effect on accessibility as regulated in Washington
since all stories and basements must be accessible (with the
limited exception of not providing elevator access to some
small stories).
[E. The potential problem here is that a building might be

built with one or more floors below ground (for parking) and
only one floor above ground. Under this definition, the
below-ground floors would not be considered a "story".
Thus, this would be considered a one-story building and no
elevator would be required. However, the Washington
accessibility provisions do not exempt a basement from
accessibility requirements, even if it is not a "story", so a
builder would be required to provide an accessible entrance
and an accessible route to all parts of the building.]
01-03209
Transient Lodging. A building, facility, or portion thereof,

excluding inpatient medical care facilities, that contains one or
more dwelling units or sleeping accommodations. Transient
lodging may include, but is not limited to, resorts, group homes,
hotels, motels, and dormitories.
DOJ 36.104(1). An inn, hotel, motel, or other place of lodging,

except for an establishment located within a building that contains
not more than five rooms for rent or hire and that is actually
occupied by the proprietor of the establishment as the residence of
the proprietor.
51-20-0404 Section 404 Congregate Residence is any

building or portion thereof which contains facilities for living,
sleeping and sanitation, as required by this code, and may
include facilities for eating and cooking, for occupancy by
other than a family. A congregate residence may be a
shelter, convent, monastery, dormitory, fraternity or sorority
house but does not include jails, hospitals, nursing homes,
hotels or lodging houses.
Chapter 4, Section 413 Lodging House is any building or

portion thereof containing not more than five guest rooms
where rent is paid in money, goods, labor or otherwise.
51-20-0409 Section 409 Hotel is any building containing six

or more guest rooms intended or designed to be used, or
which are used, rented or hired out to be occupied, or which
are occupied for sleeping purposes by guests.
51-20-0409 Section 409 Motel is any building containing six
or more guest rooms intended or designed to be used, or
which are used, rented or hired out to be occupied, or which
are occupied for sleeping purposes by guests.
(See definition of Hotel) 51-20-1201 Group R. Occupancies

Defined. Group R Occupancies shall be:
Division 1. Hotels and apartment houses. Congregate

residence (each accommodating more than 10 persons)
Division 2. Not used.
Division 3. Dwellings, family child day care homes and
lodging houses. Congregate residences (each
accommodating 10 persons or less).
01-03210
Comment: Issue 7. (See also Issue No. 19) ADA defines

terms to clarify which activities are regulated for accessibility.
UBC defines terms to distinguish how buildings must be
constructed, safely occupied and exited. The UBC does not
use the term transient directly but it is a factor in all the
regulations which distinguish a hotel from and[sic] an
apartment building. A careful review and understanding of
Chapters 12 and 33 of the UBC clarifies this approach. Every
activity someone wishes to conduct in a building must fall in
one of the UBC occupancy categories. If it is not specifically
listed, the building official must categorize it as being similar
to one of those listed and regulate it accordingly. See
Section 501 of the UBC (attached). Thus any facility
providing residential services on a transient basis will be
categorized either as a hotel or lodging house by the building
official and accessibility will be required at that change [sic]
of occupancy. In order to assist local building officials
address this potential concern, the Council has issued

01-03211
Interpretation 93-39.
the units are rented to short term quests.
Guidelines.

provided at the site such as job or health counseling.
transient.

[E.]
01-03212
ACCESSIBLE ELEMENTS AND SPACES: SCOPE AND TECHNICAL
REQUIREMENTS.
4.1 Minimum Requirements
4.1.1* Application.
(1) General. All areas of newly designed or newly constructed

buildings and facilities required to be accessible by 4.1.2 and
4.1.3 and altered portions of existing buildings and facilities
required to be accessible by 4.1.6 shall comply with these
guidelines, 4.1 through 4.35, unless otherwise provided in this
section or as modified in a special application section.
51-20-3101 Scope (a) General. Buildings or portions of

buildings shall be accessible to persons with disabilities as
required by this chapter.
Chapter 31 has been amended to comply with the Federal

Fair Housing Act (FFHA) Guidelines as published by the
U.S. Department of Housing and Urban Development (March
1991) and the Americans with Disabilities Act (ADA)
Guidelines as published by the U.S. Architectural and
Transportation Barriers Compliance Board and Department of
Justice (July, 1991).
Reference is made to Appendix Chapter 31 for FFHA and

ADA requirements not regulated by this chapter.
51-20-3101 (b) Design. The design and construction of

accessible building elements shall be in accordance with this
chapter. For a building, structure or building element to be
considered to be accessible, it shall be designed and
constructed to the minimum provisions of this chapter.
51-20-3103 Building Accessibility (a) Where required. 1.

General. Accessibility to temporary or permanent buildings or
portions thereof shall be provided for all occupancy
classifications except as modified by this chapter. See also
Appendix Chapter 31.
51-20-0104 Application to Existing Buildings and Structures.

(a) General. Buildings and structures to which additions,
alterations or repairs are made shall comply with all the
requirements of this code for new facilities except as
specifically provided in this section. See Section 1210 for
provisions requiring installation of smoke detectors in existing
Group R, Division 3 Occupancies.
01-03213
4.1.1 (2) Application Based on Building Use. Special application

sections 5 through 10 provide additional requirements for
restaurants and cafeterias, medical care facilities, business and
mercantile, libraries, accessible transient lodging, and
transportation facilities. When a building or facility contains more
than one use covered by a special application section, each portion
shall comply with the requirements for that use.
51-20-3106 Accessible Design and Construction Standards.

(a) General. Where accessibility is required by this chapter,
it shall be designed and constructed in accordance with this
section, unless otherwise specified in this chapter.

UBC Section 503. (a) ... When a building houses more than
one occupancy, each portion of the building shall conform to
the requirements of the occupancy housed therein.
01-03214
4.1.1*(2) Continued.
51-20-3103 Building Accessibility. (a) Where required. 1.

(a) 2. Group A. Occupancies. A. General. All Group A
Occupancies shall be accessible as provided in this chapter.
(a) 3. Group B. Occupancies. All Group B Occupancies shall
be accessible as provided in this chapter. Assembly spaces in
Group B Occupancies shall comply with Section 3103 (a) 2.
B.
4. Group E. Occupancies. All Group E. Occupancies shall be
accessible as provided in this chapter. Assembly spaces in
Group E Occupancies shall comply with Section 3103 (a) 2.
B.
5. Group H Occupancies. All Group H Occupancies shall be
accessible as provided in this chapter.
6. Group I Occupancies. All Group I Occupancies shall be
accessible in all public use, common use and employee use
areas, and shall have accessible patient rooms, cells and
treatment or examination rooms as follows:
6.A. In Group I, Division 1.1 hospitals which specialize in
treating conditions that affect mobility, all patient
each nursing unit, including associated toilet rooms and
bathrooms.
6.B. In Group I, Division 1.1 hospitals which do not
specialize in treating conditions that affect mobility, all patient
rooms in each nursing unit, including associated toilet rooms
and bathrooms.
6.C. In Group I, Division 1.1 and Division 2 nursing homes
and long-term care facilities, at least 1 in every 2 patient
rooms, including associated toilet rooms and bathrooms.
6.D. In Group I, Division 3, mental health Occupancies, at
least 1 in every 10 patient rooms, including associated toilet
rooms and bathrooms.
01-03215
4.1.1 (2) Continued.

6.E. In Group I, Division 3 jail, prison and similar

Occupancies, at least 1 in every 100 rooms or cells, including
associated toilet rooms and bathrooms.
[6.F. In Group I Occupancies, all treatment and examination

rooms shall be accessible.]
In Group I, Division 1.1 and 2 Occupancies, at least one
accessible entrance that complies with Section 3103 (b) shall
be under shelter. Every such entrance shall include a
passenger loading zone which complies with Section 3108 (b)
3.
51-20-3103 (a) 7. Group M. Occupancies. Group M,

Division 1 Occupancies shall be accessible. [as follows:]
[A.] Private garages, [and] carports
[which contain accessible parking serving Type A dwelling
units.]
[B]. In Group M., Division 1 agricultural buildings, access
need only be provided to paved work areas and areas open to
the general public.
51-20-3103 (a) 8. Group R. Occupancies. A. General. All

Group R Occupancies shall be accessible as provided in this
chapter. Public and common-use areas and facilities such as
recreational facilities, laundry facilities, garbage and recycling
collection areas, mailbox locations, lobbies, foyers and
management offices, shall be accessible.
[EXCEPTION: Common- or public-use facilities accessory to
buildings not required to contain either Type A or Type B
dwelling units in accordance with Section 3103(a)8B.]
B. Number of Dwelling Units. In all Group R, Division 1

apartment buildings the total number of Type A dwelling units
shall be as required by Table No. 31-B. All other dwelling
units shall be designed and constructed to the requirements
for Type B units as defined in this chapter.
EXCEPTIONS: 1. Group R Occupancies containing **[no more

than] three dwelling units [need not be accessible]*
**
01-03216
4.1.1 (3)* Areas Used Only by Employees as Work Areas. Areas

that are used only as work areas shall be designed and
constructed so that individuals with disabilities can approach,
enter, and exit the areas. These guidelines do not require that any
areas used only as work areas be constructed to permit
maneuvering within the work area or be constructed or equipped
(i.e., with racks or shelves) to be accessible.
51-20-3152
TABLE NO. 31-B

REQUIRED TYPE A DWELLING UNITS
Total Number of Dwelling Required Number of Type A

Units on Site Dwelling Units
0-10 None
11-20 1
21-40 2
41-60 3
61-80 4
81-100 5
For every 20 units or fractional 1 additional
part thereof, over 100
See Occupancy Groups above
01-03217
Comment: Issue 8. Except in Group M occupancies, the

Washington code does not distinguish areas in a building
which are employee versus public areas. It requires all areas
of a building to provide equal accessibility. In this regard the
Washington Code provides greater accessibility than the
ADA. For example if a plan shows a room with a series of
built in work stations, ADA would simply ask if the room can
be approached, entered and exited. Under the Washington
code, accessible aisles would be required between work
stations and 5% of the stations would be accessible.
Over time use of specific rooms change without need for a

building permit or review by a building official. It is better in
the long term of accessibility to require full accessibility at the
time of construction.
Group M occupancies are small, miscellaneous buildings that

are limited in size to less than 1000 square feet and don't fit
in other categories. Typically they are accessory buildings at
other buildings. A typical garage at a house in [sic] an M-1.
So is the storage shed at the house. Another broad category
is agricultural buildings, also limited to 1000 square feet or
less. Most things that small are at family farms, but not
always. Thus for these small buildings which might be places
of employment or places of public accommodation,
accessibility is required by the Washington code.
[E.]
01-03218
4.1.1 (4) Temporary Structures. These guidelines cover temporary

buildings or facilities as well as permanent facilities. Temporary
buildings and facilities are not of permanent construction but are
extensively used or are essential for public use for a period of
time. Examples of temporary buildings or facilities covered by
these guidelines include, but are not limited to: reviewing stands,
temporary classrooms, bleacher areas, exhibit areas, temporary
banking facilities, temporary health screening services, or
temporary safe pedestrian passageways around a construction
site. Structures, sites and equipment directly associated with the
actual processes of construction, such as scaffolding, bridging,
materials hoists, or construction trailers are not included.
51-20-3103 (a) 1. EXCEPTION 2. Temporary structures,

sites and equipment directly associated with the construction
process such as construction site trailers, scaffolding,
bridging, or material hoists are not required to be accessible.
[This exception does not include walkways or pedestrian
protection required by Chapter 44.]
51-20-0104 (e) Moved Buildings and Temporary Buildings.

Buildings or structures moved into or within the jurisdiction
shall comply with the provisions of this code for new
buildings or structures.
Temporary structures such as reviewing stands and other

miscellaneous structures, sheds, canopies or fences used for
the protection of the public around and in conjunction with
construction work may be erected by special permit from the
building official for a limited period of time. Such buildings or
structures need not comply with the type of construction or
fire-resistive time periods required by this code. Temporary
buildings or structures shall be completely removed upon the
expiration of the time limit stated in the permit.
Comment: Issue 9. Section 3103(a)1, Exception 3 has been

amended to include the following sentence. "This exception
does not include walkways or pedestrian protection required
by Chapter 44." (See Page 599c of the Published Code.) By
adding this limitation to the exception, these walkways must
still be accessible.
Section 104(e) is primarily a permit process section. It allows

a special permit for such temporary structures and allows
waiver of construction type and fire-resistive standards. It
does not waive requirements of Chapter 31 regarding
accessibility.
[E.]
01-03219
4.1.1 (5) General Exceptions.

(a) In new construction, a person or entity is not required to
meet fully the requirements of these guidelines where that person
or entity can demonstrate that it is structurally impracticable to do
so. Full compliance will be considered structurally impracticable
only in those rare circumstances when the unique characteristics
of terrain prevent the incorporation of accessibility features. If full
compliance with the requirements of these guidelines is
structurally impracticable, a person or entity shall comply with the
requirements to the extent it is not structurally impracticable. Any
portion of the building or facility which can be made accessible
shall comply to the extent that it is not structurally impracticable.
51-20-3103(a) 1. EXCEPTIONS:
51-20-3103(b) 2. EXCEPTION[S]: [1. A single accessible

route shall be permitted to pass through a kitchen or storage
room in an accessible dwelling unit. 2. Floors above and
below accessible levels that have areas of less than 3,000
square feet per floor, need not be served by an accessible
route of travel from an accessible level. This exception shall
not apply to: A. The offices of health care providers: or, B.
Transportation facilities and airports: or, C. Buildings owned
or leased by government agencies: or D. Multi-tenant Group
B, Division 2, retail and wholesale occupancies of five tenant
spaces or more.] [3] For sites where natural terrain or other
unusual property characteristics do not allow the provision of
an accessible route of travel from the public way to the
building, the point of vehicular debarkation may be
substituted for the accessible entrance to the site.
51-20-3105(a) General . . . [For Group R, Division 1
apartment buildings.] Where specific floors of a building are
required to be accessible, the requirements shall apply only to
the facilities located on accessible floors.

01-03220
4.1.1(5) Continued.
4.1.1(5)(b) Accessibility is not required to (i) observation galleries

used primarily for security purposes; or (ii) in non-occupiable
spaces accessed only by ladders, catwalks, crawl spaces, very
narrow passageways, or freight (non-passenger) elevators, and
frequented only by service personnel for repair purposes; such
spaces include, but are not limited to, elevator pits, elevator
penthouses, piping or equipment catwalks.
Comment: Issue 10. The elevator exception has been

revised and is now generally equivalent and, for two story
buildings, requires substantially greater accessibility than the
ADA. See also Issue No. 16, below.
51-20-3101(e) Modifications. Where full compliance with

this chapter is impractical due to unique characteristics of the
terrain, the building official may grant modifications in
accordance with Section 106, provided that any portion of
the building or structure that can be made accessible shall be
made accessible to the greatest extent practical.
Comment: Issue 11. In preparing the Washington's

regulations it was noted that this provision of the ADA was
very limited in potential application, therefore an equivalent
provision was not adopted. Under Section 105 and 3101(d),
building officials can approve alternative designs which
provide substantially equivalent or greater accessibility. In
addition, a specific exception based on terrain which allows
an alternative approach than providing an accessible route
from the street is provided by Sec. 3103(b)2. Through these
provisions, the Washington Code is more restrictive than the
appearance of the ADA provisions and provides greater
accessibility.
51-20-3103(a) 1. EXCEPTIONS: 1. Floors or portions of

floors not customarily occupied, including, but not limited to,
elevator pits, observation galleries used primarily for security
purposes, elevator penthouses, nonoccupiable spaces
accessed only by ladders, catwalks, crawl spaces, very
narrow passageways or freight elevators, piping and
equipment catwalks and machinery, mechanical and electrical
equipment rooms.
[Amendment: P.N.E. The language raises the possibility that

the phrase "that have areas of less than 3000 square feet
per floor" refers to "accessible levels" without limiting "floors
above and below" or vice versa. Thus, if the ground floor
were less than 3000 square feet, WAC would not require an
elevator, even though any number of floors above or below it
were greater than 3000 square feet. It needs to be clear
that no floor can exceed 3000 square feet. Although WAC
does exceed the ADA in that WAC does not allow an
elevator exemption for two-story buildings, that does not
make up for the possible problem caused by the ambiguity
regarding square footage per floor.]
[WAC applies a lower standard than "structurally

impracticable". However, because this is a waiver provision,
it is not part of the certification determination. Rather, any
waiver will be non-certified.]
01-03221
Comment: Issue 12. It was the intent of the WSR to have

the same effect as the ADA. The language of the exception
may be poorly crafted but was intended as a long list of ways
in which areas not customarily occupied would be accessed.
To clarify application of this exception the Council has issued
Question: 1. Do spaces such as machinery, mechanical,
electrical, and telephone equipment rooms need to be
accessible? Since these spaces typically work areas only open
to employees, is it sufficient to have these rooms designed
that persons with disabilities can approach, enter, and exit
from these areas?
2. Are rooms used for storage considered to "not
customarily occupied" and able to be nonaccessible?
Answer: 1. The intent of the code, as provided in Sec.
Accessibility Guideline. Machinery, mechanical, electrical,
and telephone equipment rooms must be accessible, as must
rooms identified as or other service spaces such as custodial,
janitors', and supply rooms must be accessible when the
primary occupancy must be accessible. Such rooms must be
designed so they can be approached, entered, and exited by a
person with disabilities. The intent of the exception is to only
apply to spaces of the building which are very rarely accessed
even by building service personnel such as a mechanical or
plumbing chase, crawl space, plenum, or space above a
suspended ceiling. The listing of the equipment rooms in this
exception is intended only to be examples of locations where
the small, non-occupiable spaces might be accessed.
2. Storage rooms are not spaces which are "not customarily
occupied," and must meet accessibility standards of Chapter
31.
[P.E. The interpretation has so many typographical errors

that it is very confusing.]
01-03222
4.1.2 Accessible Sites and Exterior Facilities: New Construction.

An accessible site shall meet the following minimum requirements:
(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.
4.1.2 (2) At least one accessible route complying with 4.3 shall
connect accessible buildings, accessible facilities, accessible
elements, and accessible spaces that are on the same site.
51-20-3105 Facility Accessibility (a) General. Where
buildings are required to be accessible, building facilities shall
be accessible to persons with disabilities as provided in this
section. **[For Group R, Division 1 apartment buildings.] Where
specific floors of a building are required to be accessible, the
requirements shall apply only to the facilities located on
accessible floors.
51-20-3103(b)2. Accessible Route of Travel. When a

building or portion of a building, is required to be accessible,
an accessible route of travel shall be provided to all portions
of the building, to accessible building entrances and
connecting the building and the public way.
The accessible route of travel to
areas of primary function may serve but shall not pass
through kitchens, storage rooms, toilet rooms, bathrooms,
closets or other similar spaces.
EXCEPTION[S]: [1. A single accessible route shall be

permitted to pass through a kitchen or storage room in an
accessible dwelling unit. 2. Floors above and below
accessible levels that have areas of less than 3,000 square
feet per floor, need not be served by an accessible route of
travel from an accessible level. This exception shall not apply
to: A. The offices of health care providers; or, B.
Transportation facilities and airports; or, C. Buildings owned
or leased by government agencies; or, D. Multi-tenant Group
B, Division 2, retail and wholesale occupanices of five tenant
spaces or more.] **[moved up #3] For sites where natural
terrain or other unusual property characteristics do not allow
the provision of an accessible route of travel from the public
way to the building, the point of vehicular debarkation may
be substituted for the accessible entrance to the site.
[Amendment: P.N.E. It appears that the phrase "that have

areas of less than 3000 square feet per floor" refers to
"accessible levels" without limiting "floors above and below"or vice versa. It
needs to be clear that no floor can exceed
3000 square feet (see discussion above at Standard
4.1.1(5)).]
01-03223
Continued.
4.1.2 (3) All objects that protrude from surfaces or posts into
circulation paths shall comply with 4.4.
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.
EXCEPTION: Provision of all required parking spaces in

conformance with "Universal Parking Design" (see appendix
A4.6.3) is permitted.
4.1.2(5)(c) If passenger loading zones are provided, then at least

one passenger loading zone shall comply with 4.6.6.
Accessible routes of travel serving any accessible space or

element shall also serve as a means of egress for
emergencies or connect to an area of evacuation assistance.
When more than one building or facility is located on a site,

accessible routes of travel shall [connect]
accessible buildings and accessible site facilities.
The accessible route of travel shall be the most practical
direct route connecting accessible building entrances,
accessible site facilities and the accessible site entrances.
51-20-3106(e) Protruding Objects. Protruding objects shall

not reduce the clear width of an accessible route of travel or
maneuvering space. Any wall- or post-mounted object with
its leading edge between 27 inches and 79 inches above the
floor may project not more than 4 inches into [an accessible
route of travel.] corridor,
passageway, or aisle]. Any wall-or post-mounted projection
greater than 4 inches shall extend to the floor.
51-20-3107(a)[5] . . . [For other than Group R, Division 1

apartment buildings, where accessible parking is required,]
one [of] every eight accessible parking spaces,
[or fraction thereof], shall
[be designed to be accessible to vans].
51-20-3107(b)2. . . . Van accessible parking spaces shall

have an adjacent access aisle not less than 96 inches in
width.
[(c) Signs. . . . Van accessible parking spaces shall have an

additional sign mounted below the International Symbol of
Access identifying the spaces as "Van Accessible."
EXCEPTION: Where all of the accessible parking spaces
comply with the standards for van accessible parking spaces.]
51-20-3108 Passenger Loading Zones. (a)
Location. Where provided, passenger loading
zones shall be located on an accessible route of travel
[Amendment: E.]
[Amendment: N.E. The amendment creates an ambiguity
because of the placement of "accessible" at the beginning of
the list of covered pathways. We need to be clear that
objects must not protrude into any corridor or passageway or
aisle, regardless of whether it is otherwise accessible.
Because, in new construction, WAC requires all routes to be
accessible, this distinction is a problem only for alterations.]
[Amendment: E.]
[Amendment: E.]
01-03224
4.1.2(5)(d) At facilities providing medical care and other services

for persons with mobility impairments, parking spaces complying
with 4.6 shall be provided in accordance with 4.1.2(5)(a) except
as follows:
(i) Outpatient units and facilities: 10 percent of the total

number of parking spaces provided serving each such outpatient
unit or facility;
(ii) Units and facilities that specialize in treatment or services

for persons with mobility impairments: 20 percent of the total
number of parking spaces provided serving each such unit or
facility.
4.1.2 (6) If toilet facilities are provided on a site, then each such
public or common use toilet facility shall comply with 4.22. If
bathing facilities are provided on a site, then each such public or
common use bathing facility shall comply with 4.23.
For single user portable toilet or bathing units clustered at a single

location, at least 5% but no less than one toilet unit or bathing
unit complying with 4.22 or 4.23 shall be installed at each cluster
whenever typical inaccessible units are provided. Accessible units
shall be identified by the International Symbol of Accessibility.
EXCEPTION: Portable toilet units at construction sites used
exclusively by construction personnel are not required to comply
with 4.1.2(6).
51-20-3107 (a) Accessible Parking Required. . . . [2]

Inpatient Medical Care Facilities] For Group I, Division 1.1,
1.2 and 2 medical care Occupancies specializing in the
treatment of persons with mobility impairments, 20 percent
of parking spaces provided accessory to such occupancies
shall be accessible.
[3. Outpatient Medical Care Facilities. For Group I, Division
1.1 and 1.2 and Group B, Division 2 Occupancies providing
outpatient medical care facilities, 10 percent of the parking
spaces provided accessory to such occupancies shall be
accessible.]
Comment: Issue 13. Section 3107 has been amended to

include a 10 percent requirement for outpatient medical care
facilities at either hospitals (Group 1.1), Outpatient surgery
centers (Group 1.2) or doctors and dentists offices (Group B-
2). (See page 604s of the Published Code.) Ironically this
WSR provision will require more accessible parking than the
ADA based on the interpretation of this provision contained in
the January 1993 supplement to the Title III technical
assistance manual.
51-20-3106 (k) 1. General. Bathrooms, toilet rooms,

bathing facilities and shower rooms shall be designed in
accordance with this section. (3106)
[Amendment: N.E. WAC requires 20% at inpatient mobility-

specialists and 10% at outpatient facilities. Under S 3107
outpatient mobility-specialty facilities would only need 10%.
The ADA would require 20% for all (inpatient and outpatient)
mobility-specialty facilities. Although WAC does exceed the
ADA in that it requires the additional (10%) accessible
spaces at doctors' offices, the increased accessible parking is
most needed in the places WAC does not provide it
(outpatient mobility specialists) and least needed in the
places WAC does provide it (doctors' and dentists' offices).]
01-03225
4.1.3 (4) Interior and exterior stairs connecting levels that are not
connected by an elevator, ramp, or other accessible means of
vertical access shall comply with 4.9.
Comment: Issue 14. Section 3103(a) 1 only exempts

temporary structures which are directly related to the
construction process. The standards for accessible toilets are
provided and are applicable to permanent and temporary
facilities. If someone gets a local building permit for portable
toilets, there is nothing in Chapter 31 which exempts them
from complying with 3105(b) or 3106(k). The code
specifically regulates temporary as well as permanent
structures in Section 3103(a)1. Not all jurisdictions require
building permits for these temporary installations, thus it is
not uniformly covered by local application of the code. This
in no way exempts them from ADA compliance.
51-20-3306 Stairways. (a) General. Every stairway having

two or more risers serving any building or portion thereof
shall conform to the requirements of this section. When
aisles in assembly rooms have steps, they shall conform with
the provisions in Section 3315.
51-20-3106 (i) Stairways. 1. General. Stairways required

to be accessible shall comply with section 3306 and
provisions of this section.
51-20-5105 (c)3. Stairways. Stairways shall comply with
Section 3106(i).
Comment: Issue 15. Section 3105(c) has been amended to

provide scoping for elevators, platform lifts and stairways.
(See pages 603a and 603b of the Published Code.) The net
result is the Washington regulations provide greater
accessibility than the ADA in that all stairways in covered
buildings must comply with 3106(i). This is significantly
more than the ADA which only applies to stairways where
floors are not accessible by elevator or ramp.
[E.]
[E.]
01-03226
4.1.3 (5)* One passenger elevator complying with 4.10 shall
serve each level, including mezzanines, in all multi-story buildings
and facilities unless exempted below. If more than one elevator is
provided, each full passenger elevator shall comply with 4.10.
EXCEPTION 1: Elevators are not required in facilities that are less

than three stories or that have less than 3000 square feet per
story unless the building is a shopping center, a shopping mall, or
the professional office of a health care provider, or another type of
facility as determined by the Attorney General. The elevator
exemption set forth in this paragraph does not obviate or limit in
any way the obligation to comply with the other accessibility
requirements established in section 4.1.3. For example, floors
above or below the accessible ground floor must meet the
requirements of this section except for elevator service. If toilet or
bathing facilities are provided on a level not served by an elevator,
then toilet or bathing facilities must be provided on the accessible
ground floor. In new construction if a building or facility is eligible
for this exemption but a full passenger elevator is nonetheless
planned, that elevator shall meet the requirements of 4.10 and
shall serve each level in the building. A full passenger elevator
that provides service from a garage to only one level of a building
or facility is not required to serve other levels.
EXCEPTION 2: Elevator pits, elevator penthouses, mechanical

rooms, piping or equipment catwalks are exempted from this
requirement.
EXCEPTION 3: Accessible ramps complying with 4.8 may be used

in lieu of an elevator.
51-20-3105 (c) Elevators[, Platform Lifts and Stairways].
1. [Elevators. A.] Where Required. In multi-story buildings or
portions thereof required to be accessible by Section 3103, at
least one elevator shall serve each level, including
mezzanines. Other than within an individual dwelling unit,
when an elevator is provided but not required, it shall be
accessible.
EXCEPTIONS: 1. In Group R. Division 1 apartment

occupancies, an elevator is not required where accessible
dwelling units and guest rooms are accessible by ramp or by
grade level route of travel. 2. In a building of fewer than
three stories an elevator is not required where ramps, grade-
level entrances or accessible horizontal exits from an adjacent
building, are provided to each floor. 3. In multistory parking
garages, an elevator is not required where an accessible route
of travel is provided from accessible parking spaces on levels
with accessible horizontal connections to the primary building
served. 4. In Group R, Division 1 hotels and lodging houses
less than 3 stories in height, an elevator is not required
provided that accessible guest rooms are provided on the
ground floor.
[B. Design. All elevators shall be accessible.]

EXCEPTIONS: 1. Private elevators serving only one dwelling
unit. 2. Where more than one elevator is provided in the
building, elevators used exclusively for movement of freight.
01-03227
4.1.3 (5)* Continued.
4.1.3 (5)* Continued.
51-20-3103 EXCEPTION 2:
floors above
and below accessible levels that have areas of less than
3000 square feet per floor, need not be
[served by an accessible route of travel
from an accessible level. This exception shall not apply to:
A. The offices of health care providers; or, B. Transportation
facilities and airports; or, C. Buildings owned or leased by
government agencies; or D. Multi-tenant Group B, Division 2,
retail and wholesale occupancies of five tenant spaces or
more.]
51-20-3105 (c) [1. Elevators.B.] Design. All elevators

EXCEPTIONS: 1. Private elevators serving only one dwelling

unit.
2. Where more than one elevator is provided in the building,

elevators used exclusively for movement of freight.
Elevators required to be accessible

shall be designed and constructed to comply with Chapter
296-81 of the Washington Administrative Code.
[Amendment. P.N.E. The language raises the possibility that

the phrase "that have areas of less than 3000 square feet
per floor" refers to "accessible levels" without limiting "floors
above and below" or vice versa. Thus, if the ground floor
were less than 3000 square feet, WAC would not require an
elevator, even though any number of floors above or below it
were greater than 3000 square feet. It needs to be clear
that no floor can exceed 3000 square feet. Although WAC
does exceed the ADA in that WAC does not allow an
elevator exemption for two-story buildings, that does not
make up for the possible problem caused by the ambiguity
regarding square footage per floor.]
01-03228
EXCEPTION 4: Platform lifts (wheelchair lifts) complying with

4.11 of this guideline and applicable state or local codes may be
used in lieu of an elevator only under the following conditions:
(a) To provide an accessible route to a performing area in
an assembly occupancy.
(b) To comply with the wheelchair viewing position line-of-

sight and dispersion requirements of 4.33.3.
(c) To provide access to incidental occupiable spaces and

rooms which are not open to the general public and which house
no more than five persons, including but not limited to equipment
control rooms and projection booths.
(d) To provide access where existing site constraints or

other constraints make use of a ramp or an elevator infeasible.
Comment: Issue 16. Item 1: Section 3103(a) 1 and

3103(b)2 have been revised to clarify that the exception for
elevators is truly only an accessible route exception. It no
longer exempts whole spaces from all accessibility standards.
See also amendments to 3105(a). The Washington code
now clearly provides greater accessibility than the ADAAG.
See pages 599c, 601a and 603 of the Published Code.
Item 2: The Washington State elevator standards were
revised through an amendment to WAC Chapter 296-81
which was effective on July 1, 1992 to be consistent with
the ADAAG. Section 296-81-007(5) specifically adopts the
ANSI A117.1-1990 elevator standard which includes standards
for wheelchair and platform lifts. In addition sections .300
through .360 and .370 adopts additional standards for
elevator design and installation which are consistent with the
ADA requirements. See Issue No. 46 for a comparison of the
ADA and Washington regulations. (A copy of WAC 296-81
is attached.)
51-20-3105 (c) [2] Platform Lifts. Platform lifts may be

used in lieu of an elevator under one of the following
conditions subject to approval by the building official:
[A.] To provide an accessible route of travel to a
performing area in a Group A. Occupancy; or,
[B.] To provide unobstructed sight lines and
distribution for wheelchair viewing positions in Group A
Occupancies; or,
[C.] To provide access to spaces with an occupant
load of less than 5 [that are not open to the public]; or
[D.] To provide access where existing site constraints
or other constraints make use of a ramp or elevator
infeasible.
All platform lifts used in lieu of an elevator shall be capable of

independent operation and shall comply with Chapter 296-81
of the Washington Administrative Code.
[E. Equivalency of technical standards is addressed

separately below.]
01-03229
4.1.3 (8) In new construction, at a minimum, the requirements in

(a) and (b) below shall be satisfied independently:
(a) (i) At least 50% of all public entrances (excluding

those in (b) below) must be accessible. At least
one must be a ground floor entrance. Public
entrances are any entrances that are not loading or
service entrances.
(ii) Accessible entrances must be provided in a

number at least equivalent to the number of exits
required by the applicable building/fire codes. (This
paragraph does not require an increase in the total
number of entrances planned for a facility.)
(iii) An accessible entrance must be provided to

each tenancy in a facility (for example, individual
stores in a strip shopping center).
One entrance may be considered as meeting more than one of the

requirements in (a). Where feasible, accessible entrances shall be
the entrances used by the majority of people visiting or working in
the building.
[296-81-007. National Elevator Code adopted. ...(5) The

American National Standard Safety Code for Elevators,
Dumbwaiters, Escalators, and Moving Walks, ANSI A17.1,
1990 Edition, is adopted as the standard for elevators,
dumbwaiters, escalators, and moving walks installed on or
after July 1, 1992, with the exceptions of ANSI A17.1, Part
XIX, and ANSI A17.1, Part V, Section 513, which is replaced
by chapter 296-94 WAC.]
Comment: Issue 17. Section 3105(c) 2C has been revised to

read "To provide access to spaces with an occupant load of
less than 5, that are not open to the public." (See paged (sic)
603a and 603b of the Published Code.) The provisions are
now equivalent.
Comment: Issue 18. See comment on Issue No. 16, above.
51-20-3103 (b) 3. Primary Entry[ance] Access. At least

50% of all public entries, or a number equal to the number of
exits required by Section 3303 (a), whichever is greater, shall
be accessible. One of the accessible public entries shall be
the primary entry to a building. At least one accessible entry
must be a ground floor entrance. Public entries do not
include loading or service entries.
EXCEPTION: In Group R. Division 1 apartment buildings only

the primary entry need be accessible, provided that the
primary entry provides an accessible route of travel to all
dwelling units required to be accessible.
Where a building is designed not to have common or primary

entries, the primary entry to each individual dwelling unit
required to be accessible, and each individual tenant space,
[E. Technical requirements addressed separately below.]
01-03230
Comment: Issue 19. (See also comment on Issue No. 7,

above.) Except where an apartment building is used as a
hotel, the ADA does not regulate apartment buildings. Under
the UBC a permit issued for an apartment building is for
residential apartment use and does not include transient use
as covered by the ADA. A transient use of an apartment
building would require a new building permit and occupancy
certificate. If this is the intended use at the first permit, the
applicant needs to so state so that the building is reviewed
according to the proper standards. If that information is
withheld there is a violation of the building code. Where the
permit process is properly followed, this exception does not
result in less accessibility than the ADA. To assist local
building officials in understanding this difference, the Council
has issued Interpretation No. 93-39.
01-03231
Question: For purposes of accessibility requirements ofChapter 31, how should
buildings such as homeless shelters,
halfway houses, (transient group homes, and similar social
the units are rented to short term guests.
Guidelines.

transient.
[E.]
01-03232
4.1.3 (8)(b)(i) In addition, if direct access is provided for

pedestrians from an enclosed parking garage to the building, at
least one direct entrance from the garage to the building must be
accessible.
(ii) If access is provided for pedestrians from a pedestrian tunnel

or elevated walkway, one entrance to the building from each
tunnel or walkway must be accessible.
One entrance may be considered as meeting more than one of the

requirements in (b).
Because entrances also serve as emergency exits whose proximity

to all parts of buildings and facilities is essential, it is preferable
that all entrances be accessible.
51-30-3103 (b)2. ...The accessible route of travel shall be

the most practical direct route connecting accessible building
entrances, accessible site facilities and the accessible site
entrances.
Comment: Issue 20. Per the definition contained in Section

3102, these are primary entrances to a building and would
need to be accessible, including the provision of accessible
routes. Further, the side by side comparison appears to only
compare this ADA requirement with one small part of the
Washington provisions. Other provisions are critical to this
comparison. The rest of 3103(b)2 is important, see attached.
It clearly states that where there is more than one facility on
the site, accessible routes be provided connected each
facility. No exemption of any kind is provided for tunnels or
elevated walkways. Section 3107 requires parking to be on
an accessible route which is the shortest possible to
accessible building entrance(s). In case there is any question
as to the intent of the provision, the Council has issued
Intrepretation 93-30
Question: Must tunnels, elevated walkways, (pedestrian
walkways) and doorways providing direct access from
parking garages to a building provide an accessible entrance.
Accessibility Guideline. These types of entrances and
connections between buildings are considered to be primary
entrances and must be accessible.
[E.]
01-03233
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.
51-20-3105 (b) Bathing and Toilet Facilities. 1. Bathing

Facilities. When bathing facilities are provided, at least 2
percent but not less than 1, bathtub or shower shall be
accessible. In dwelling units where both a bathtub and
shower are provided in the same room, only one need be
accessible.
51-20-3105 (b) 2. Toilet Facilities. Toilet facilities located

within accessible dwelling units, guest rooms and congregate
residences shall comply with Sections 3106(k) and 3106
(aa).
In each toilet facility in other occupancies, at least one
wheelchair accessible toilet stall with an accessible water
closest shall be provided. In addition, when there are 6 or
more water closets within a toilet facility, at least one other
accessible toilet stall complying with Section 3106(k) 4, also
shall be installed.
Where urinals are provided, at least one urinal shall be

accessible.
51-20-3105 (b) 3. Lavatories, Mirrors and Towel Fixtures.

At least one accessible lavatory shall be provided within any
toilet facility. Where mirrors, towel fixtures and other toilet
and bathroom accessories are provided, at least one of each
51-20-3106(k) 1. General. Bathrooms, toilet rooms,

bathing facilities and shower rooms shall be designed in
accordance with this section. For dwelling units see also
Section 3106(aa).
01-03234
Comment: Issue 21. Item 1: 2% of Bathing Facilities. The

intent of Interpretation No. 93-31 is to require accessible
bathing facilities as required by ADA. It states that if only
one bathing facility is provided in a building, it must be unisex
and have 2% of its bathing features accessible; if multiple
facilities are provided, they also must be accessible at the
rate of 2% of the bathing fixtures.
Item 2: Toilet Facilities without Stalls. The application of
this section has been that each toilet facility is accessible,
regardless of the number of facilities in a building or the
number of water closets in the room or the presence of an
actual "stall." In each "toilet facility" at least one fixture of
each type provided must be accessible. The intent is to
provide accessibility whether or not there is a stall. Read
literally the WSR actually require a stall in all instances. No
official interpretation of this has been issued and the
questions received to date have been to nuances of meeting
these provisions such as overlapping clear spaces in a single
user facility, not whether it even has to be accessible
because there is not a stall.
Question: What is the application of the requirements for 2
percent of bathing facilities to be accessible when there is
only one bathing facility in a building, or when there are
multiple bathing facilities? Must separate facilities for each
sex be provided?
is to provide standards equivalent to the ADA Accessibility
Guidelines.
Where only one bathing facility is provided in a building, 2

percent of the shower or bathtub fixtures within that facility
must be accessible and the facility must be accessible to all
persons (unisex). Where there are multiple bathing facilities
in a building, each bathing facility must provide 2 percent of
the shower or bathtub fixtures as accessible. Chapter 31
does not restrict how those bathing facilities are designated
(men, women or unisex).
[E.]
01-03235
4.1.3 (12) Storage, Shelving and Display Units:

(a) If fixed or built-in storage facilities such as cabinets, shelves,
closets, and drawers are provided in accessible spaces, at least
one of each type provided shall contain storage space complying
with 4.25. Additional storage may be provided outside of the
dimensions required by 4.25.
(b) Shelves or display units allowing self-service by customers in
mercantile occupancies shall be located on an accessible route
complying with 4.3. Requirements for accessible reach range do
not apply.
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.
4.1.3 (15) Detectable warnings shall be provided at locations as

specified in 4.29.
51-20-3105 (d) 6. Storage

[Facilities]. In other than Group R, Division 1 apartment
buildings, where fixed or built-in storage facilities such as
cabinets, shelves, closets and drawers are provided in
accessible spaces, at least one of each type provided shall
contain storage space complying with Section 3106(r).
Comment: Issue 22. See comment to Issue No. 19, above.
51-20-3105 (d) 9. Alarms. where provided,

[alarm systems] shall include both audible and visible alarms.
[Visible] alarm devices shall be located in all
[assembly areas;] common-use areas
including toilet rooms and bathing facilities,[;] hallways and
lobbies[; and hotel guest rooms as required by Section
3103(a)8C].
EXCEPTIONS: 1. Alarm systems in Group I, Division 1.1 and

1.2 Occupancies may be modified to suit standard health care
design practice.
2. Visible alarms are not required in Group R, Division 1

apartment buildings.
Comment: Issue 23. See comment to Issue No. 19, above.
51-20-3106 (d) 5. B. Detectable Warnings. Curb ramps shall

have detectable warnings complying with Section 3106 (g).
Detectable warnings shall extend the full width and depth of
the curb ramp.
51-20-3106 (d) [8]. Vehicular Areas. Where an accessible

route of travel crosses or adjoins a vehicular way, and where
there are no curbs, railings or other elements [which separate
the pedestrian and vehicular areas and which are] detectable
by a person who has a severe vision impairment,
the boundary between the
areas shall be defined by a continuous detectable warning not
less than 36 inches wide, complying with Section 3106 (q).
[E.]
[E.]
01-03236
4.1.3 (17) Public Telephones:
(a) If public pay telephones, public closed circuit telephones, or

other public telephones are provided, then they shall comply with
4.31.2 through 4.31.8 to the extent required by the following
table:
Number of each type of Number of telephones

telephone provided on required to comply with
each floor 4.31.2 through 4.31.81
1 or more single unit 1 per floor

1 bank2 1 per floor
2 or more banks2 1 per bank. Accessible unit may
be installed as a single unit in
proximity (either visible or with
signage) to the bank. At least one
public telephone per floor shall
meet the requirements for a
forward reach telephone3.
1 Additional public telephones may be installed at any height.

Unless otherwise specified, accessible telephones may be either
forward or side reach telephones.
2 A bank consists of two or more adjacent public telephones, often

installed as a unit.
3 EXCEPTION: For exterior installations only, if dial tone first

service is available, then a side reach telephone may be installed
instead of the required forward reach telephone (i.e., one
telephone in proximity to each bank shall comply with 4.31).
Comment: Issue 24. The references have been corrected to

3106(q) in the November 1992 amendments, see attached.
51-20-3105 (d) 2. Telephones. On any floor where public

telephones are provided at least one telephone shall be
accessible. On any floor where 2 or more banks of multiple
telephones are provided, at least one telephone in each bank
shall be accessible and at least one telephone per floor shall
be designed to allow forward reach complying with Section
3106...
Comment: Issue 25. To simplify the code provisions, the

Washington regulations lumped all telephones available to the
public as public telephones. Section 401(a) of the UBC
requires the use of Webster's Third New International
Dictionary of the English Language, Unabridged, copyright
1986, to provide ordinary meanings for words not defined in
the code. Webster's dictionary defines public as "a place
accessible or visible to all members of the community."
[E.]
[E.]
01-03237
4.1.3 (19) (b) This paragraph applies to assembly areas where

audible communications are integral to the use of the space (e.g.,
concert and lecture halls, playhouses and movie theaters, meeting
rooms, etc.). Such assembly areas, if (1) they accommodate at
least 50 persons, or if they have audio-amplification systems, and
(2) they have fixed seating, shall have a permanently installed
assistive listening system complying with 4.33. For other
assembly areas, a permanently installed assistive listening system,
or an adequate number of electrical outlets or other supplementary
wiring necessary to support a portable assistive listening system
shall be provided. The minimum number of receivers to be
provided shall be equal to 4 percent of the total number of seats,
but in no case less than two. Signage complying with applicable
provisions of 4.30 shall be installed to notify patrons of the
availability of a listening system.
4.1.3 (20) Where automated teller machines are

provided, each machine shall comply with the requirements
of 4.34 except where two or more machines are provided at a
location, then only one must comply.
EXCEPTION: Drive-up-only automated teller machines are not

required to comply with 4.34.2 and 4.34.3.
51-20-3103 (a) 2. B. Assistive Listening Devices. Assistive

listening systems complying with Section 3106 (u) 3 shall be
installed in assembly areas where audible communications are
integral to the use of the space including stadiums, theaters,
auditoriums, lecture halls, and similar areas; where fixed
seats are provided; as follows:
1. Areas with an occupant load of 50 or more.

2. Areas where an audio-amplification system is installed.
Receivers for assistive-listening devices shall be provided at a
rate of 4 percent of the total number of seats, but in no case
fewer than two devices. In other assembly areas, where
permanently installed assistive-listening systems are not
provided, [electrical outlets shall be provided at a rate of not
less than 4 percent of the total occupant load].
Signage complying with Section 3106 (p) shall be installed to
notify patrons of the availability of the listening system.

Also, for assembly spaces without fixed seats, the ADA
language requiring "an adequate number of electrical outlets.
... to support a portable assistive listening system" is not
readily enforceable. To provide more specific standards for
building designers and regulators, the Washington code
provides an exact number of electrical outlets. If the intent
of the ADA is only an outlet for the system transmitter, then
a number of outlets which is 4% of the occupant load is
going to be more than "adequate" and will provide greater
accessibility than the ADA.
[Appendix 51-20-93120(a) Purpose. The purpose of this

division is to provide the United States Architectural and
Transportation Barriers Compliance Board Americans with
Disabilities Act Guidelines for automated teller machines.]
[E.]
01-03238
Comment: Issue 27. The ADA standards for ATM's are now
located in the Appendix to Chapter 31. See page 970j of the
Published Code.) As a total document, standards equivalent
to the ADA are present and available for use.
51-20-3105 (d) 4. [Recreation Facilities.

Where common or public use [recreation facilities,] swimming
pools, hot tubs, spas and similar facilities are provided, they
shall be accessible. Swimming pools shall be accessible by
transfer tier, hydraulic chair, ramp or other means. Hot tubs
and spas [need] be accessible only to the edge of the
facility.

[This still does not provide scoping requirements. However,

28 C.F.R. S 36.607 provides that "if certain equipment is not
covered by the [submitted] code, the determination of
equivalency cannot be used as evidence with respect to the
question of whether equipment in a building built according
to the code satisfies the Act's requirements with respect to
such equipment."]
[Amendment: E.]

01-03239
4.1.5 Accessible Buildings: Additions. Each addition to an

existing building or facility shall be regarded as an alteration. Each
space or element added to the existing building or facility shall
comply with the applicable provisions of 4.1.1 to 4.1.3, Minimum
Requirements (for New Construction) and the applicable technical
specifications of 4.2 through 4.35 and sections 5 through 10.
Each addition that affects or could affect the usability of an area
containing a primary function shall comply with 4.1.6(2).
51-20-3111 Additions. New additions may be made to

existing buildings without making the entire building comply,
provided the new additions conform to the provisions of Part
II of this chapter except as follows:
1. Entries. Where a new addition to a building or facility

does not have an accessible entry, at least one entry in the
existing building or facility shall be accessible.
2. Accessible Route. Where the only accessible entry to the

addition is located in the existing building or facility, at least
one accessible route of travel shall be provided through the
existing building or facility to all rooms, elements and spaces
in the new addition which are required to be accessible.
3. Toilet and Bathing Facilities. Where there are no toilet
rooms and bathing facilities in an addition and these facilities
are provided in the existing building, then at least one toilet
and bathing facility in the existing facility shall comply with
Section 3106 or with Section 3112 (c) 5.
4. Group I Occupancies. Where patient rooms are added to
an existing Group I Occupancy, a percentage of the additional
rooms equal to the requirement of Section 3103 (a) 6., but in
no case more than the total number of rooms required by
Section 3103 (a) 6. shall comply with Section 3106 (w).
Where toilet or bath facilities are part of the accessible
rooms, they shall comply with Section 3106 (k).
5. Group R, Division 1 Apartment Buildings. Additions of 3
or fewer dwelling units in Group R, Division 1 apartment
buildings need not comply with Part 1 of this chapter.
Where an addition affects the access to or use of an area of
primary function, to the maximum extent feasible, the path of
travel to the area of primary function shall be made
accessible.
Comment: Issue 28. See comment on to Issue No. 19,
above.
[E.]
01-03240
4.1.6 Accessible Buildings: Alterations.
(1) General. Alterations to existing buildings and facilities shall

comply with the following:
(1) (a) No alteration shall be undertaken which decreases or has

the effect of decreasing accessibility or usability of a building or
facility below the requirements for new construction at the time of
alteration.
(1)(b) If existing elements, spaces, or common areas are altered,

then each such altered element, space, feature, or area shall
comply with the applicable provisions of 4.1.1 to 4.1.3 Minimum
Requirements (for New Construction). If the applicable provision
for new construction requires that an element, space, or common
area be on an accessible route, the altered element, space, or
common area is not required to be on an accessible route except
as provided in 4.1.6(2) (Alterations to an Area Containing a
Primary Function).
51-20-3110 Alteration is any change, addition or modification

in construction or occupancy.
51-20-3112 Alterations. (a) General. 1. Compliance

Alterations to existing buildings or facilities shall comply with
this section. No alteration shall reduce or have the effect of
reducing accessibility or usability of a building, portion of a
building or facility. If compliance with this section is
technically infeasible, the alteration shall provide accessibility
to the maximum extent feasible. 51-20-3112 (a) 1.
EXCEPTION: Except when substantial as defined by Section
3110, alterations to Group R, Division 1 apartment buildings
need not comply with this section.
51-20-0104 Application to Existing Buildings and Structures.

(a) General. Buildings and structures to which additions,
alterations or repairs are made shall comply with all the
requirements of this code for new facilities except as
specifically provided in this section. See Section 1210 for
provisions requiring installation of smoke detectors in existing
Group R, Division 3 Occupancies.
(b) Addition, Alterations or Repairs. Additions, alterations

or repairs may be made to any building or structure without
requiring the existing building or structure to comply with all
the requirements of this code, provided the addition,
alteration or repair conforms to that required for a new
building or structure. Additions or alterations shall not be
made to an existing building or structure which will cause the
existing building or structure to be in violation of any of the
provisions of this code nor shall such additions or alterations
cause the existing building or structure to become unsafe. . .
(c) Any change in the use or occupancy of any existing

building or structure shall comply with the provisions of
Sections 308 and 502 of this code.
For existing buildings, see Appendix Chapter 1.
01-03241
4.1.6, Continued.
(1) (c) If alterations of single elements, when considered together,

amount to an alteration of a room or space in a building or facility,
the entire space shall be made accessible.
4.1.6(k) EXCEPTION:
(i) These guidelines do not require the installation of an elevator in
an altered facility that is less than three stories or has less than
3,000 square feet per story unless the building is a shopping
center, a shopping mall, the professional office of a health care
provider, or another type of facility as determined by the Attorney
General.
4.1.6(k) EXCEPTION: (ii) The exemption provided in paragraph (i)

does not obviate or limit in any way the obligation to comply with
the other accessibility requirements established in these guidelines.
For example, alterations to floors above or below the ground floor
must be accessible regardless of whether the altered facility has
an elevator. If a facility subject to the elevator exemption set
forth in paragraph (i) nonetheless has a full passenger elevator,
that elevator shall meet, to the maximum extent feasible, the
accessibility requirements of these guidelines.
51-20-3112 (a) 2. Existing Elements. If existing elements,

spaces, essential features or common areas are altered, each
such altered element, space feature or area shall comply with
the applicable provisions of Part II of this Chapter. Where an
alteration is to an area of primary function, to the maximum
extent feasible, the path of travel to the altered area shall be
made accessible. See also Appendix Chapter 31 Division II.
EXCEPTION 1: Accessible route of travel need not be
provided to altered elements, spaces or common areas which
are not areas of primary functions.
51-20-3112 (a) 4. Other Requirements. A. Where

alterations of single elements, when considered together,
amount to an alteration of a room or space in a building or
facility, the entire area or space shall be accessible.
51-20-3112 (b) Substantial Alterations. Where substantial
alteration as defined in Section 3110 occurs to a building or
facility, the entire building or facility shall comply with Part II
of this code.
[EXCEPTION: Areas of evacuation assistance need not be

added to a substantially altered building.]
51-20-3112(a)4.B. No alteration of an existing element,

space or area of a building shall impose a requirement for
greater accessibility than that which would be required for
new construction.
[E.]
NE No equivalent provision. Section 51-30-3103 (a) 1

allows floors of more than 3000 square feet above and
below accessible floors to be constructed without access
features.
01-03242
4.1.6 (2) Alterations to an Area Containing a Primary Function: 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 shall 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). (See Section
36.403)
51-20-3112 (a) 2. Existing Elements. If existing elements,

spaces, essential features or common areas are altered, each
such altered element, space feature or area shall comply with
the applicable provisions of Part II of this chapter. Where an
alteration is to an area of primary function, to the maximum
extent feasible, the path of travel to the altered area shall be
made accessible. See Also Appendix Chapter 31, Division II.
EXCEPTIONS: 1. Accessible route of travel need not be
provided to altered elements, spaces or common areas which
are not areas of primary function.
2. Areas of evacuation assistance need not be added to an

altered building.
[3. Subject to the approval of the building code official, the

path of travel need not be made accessible if the cost of
compliance with this part would exceed 20 percent of the
total cost of construction, inclusive of the cost of eliminating
barriers, within an 36-month period.]
51-20-3114 (a)
01-03243
Comment: Issue 31. With respect to this requirement, the

Washington regulations will result in substantially more
accessibility than the ADA. The Washington provision, now
located in Sections 51-20-3111 and 3112(a)2 read as
follows: ... [see above]
The Washington provisions will result in more, rather than
less improvements to the path of travel because of three
differences between ADA and WSR:
1. Use of the exception is subject to review of the building
official. The building official has the option of turning down
the exception request, even if it exceeds 20%.
2. The Washington regulations do not require barrier
removal. When a place of public accommodation does
remove barriers, that action is treated as an alteration under
the Washington regulations. If that action is occurring in an
area of primary function, Washington law requires
improvement to the path of travel, the ADA does not.
3. The Washington regulations require that 20% of the
"total cost of construction" of the addition or alteration be
applied to improving the path of travel. ADA requirements
stated in Section 36.403(a) apply only to alterations which
affect usability of, or access to an area of primary function.
As such building modifications which don't affect access are
not alterations under the ADA. These actions would not
trigger the path of travel requirements nor their costs
included in the determination of disproportional costs. In the
Washington regulations, all the costs of the remodeling are
included.
[The 36-month provision will create a snowball effect,

because you take 20% of the past 3 years, regardless of
whether the path of travel requirement was satisfied in the
previous alterations. The ADA looks back only if the path of
travel requirement was not met on the prior alterations.
However, this does not result in less accessibility.
In addition, because the disproportionality provision in WAC
is a waiver, it is not covered by the certification
determination.]
01-03244
Example: A owner proposes remodels of a building which

include alterations to areas of primary function, removal of
barriers and other changes. The total cost of the
construction is $200,000. Under Washington regulations,
$40,000 must also be applied to improvements to the path of
travel. Under the ADA, much less will be spent. $50,000 is
being spent to remove barriers. Another $40,000 is being
spent on elements which do not affect accessibility or
usability. Leaving only $110,000 being applied to
"alterations," as defined in ADA. Under ADA, only $22,000
need be applied to improving the path of travel, before a
claim of disproportionality can be made.
For further clarification of the application of the Washington
regulations see Council Interpretation No. 93-14.
Question: 1. A 500 square foot addition is being proposed
to the basement of an existing Group B, Division 2
Occupancy. The existing basement area is 3,200 square
feet. Currently the building has two stairway exits from the
basement, but it is not served by an elevator. The addition is
primary function area. When applying the path of travel
requirements, where the applicant intends to pursue an
appeal because of costs over 20%, is it required that up to
20% be spent, or can it be waived.
2. Are items 1, 2, and 3 of Section 51-20-3111 redundant
with the requirement for improvements to the path of travel?
Answer: 1. Each project should be considered on a case by

case basis. If alterations to the path of travel exceed 20%,
the intent of the code is that improvements to the path of
travel be made to at least the 20% level.
If however the only item needed to improve the path of travel
costs more than the 20%, e.g. an elevator, then the
expenditure on the path of travel can be "waived" at this
time, but the amount should be added to future alterations or
additions made in the subsequent 36 months.
The code only requires improvements to the path of travel
serving the addition or altered area.
2. Yes, items 1, 2, and 3 are part of the path of travel when
additions are made to the area of primary function.
01-03245
4.1.6 (3) (c) Elevators:
(i) If safety door edges are provided in existing automatic

elevators, automatic door reopening devices may be omitted (see
4.10.6).
(ii) Where existing shaft configuration or technical infeasibility

prohibits strict compliance with 4.10.9, the minimum car plan
dimensions may be reduced by the minimum amount necessary,
but in no case shall the inside car area be smaller than 48 in by 48
in.
(iii) Equivalent facilitation may be provided with an elevator car of

different dimensions when usability can be demonstrated and
when all other elements required to be accessible comply with the
applicable provisions of 4.10. For example, an elevator of 47 in
by 69 in (1195 mm by 1755 mm) with a door opening on the
narrow dimension, could accommodate the standard wheelchair
clearances shown in Figure 4.
Fig. 4 Minimum Clear Floor Space for Wheelchairs.
Fig. 4(d) Clear Floor Space in Alcoves. For a front

approach, where the depth of the alcove is equal to or less than,
24 inches (610 mm), the required clear floor space is 30 inches by
48 inches (760 mm by 1220 mm).
For a side approach, where the depth of the alcove is equal

to or less than 15 inches (380 mm), the required clear floor space
is 30 inches by 48 inches (760 mm by 1220 mm).
Fig. 4(e) Additional Maneuvering Clearances for Alcoves.

For a front approach, if the depth of the alcove is greater than 24
inches (610 mm), then in addition to the 30 inch (760 mm) width,
a maneuvering clearance of 6 inches (150 mm) in width is
required.
For a side approach, where the depth of the alcove is

greater than 15 inches (380 mm), then in addition to the 48 inch
(1220 mm) length, an additional maneuvering clearance of 12
inches in length (305 mm) is required.
51-20-3112 (c) 4. Elevators. Elevators shall comply with

Chapter 296-81, Washington Administrative Code.
[E.]
01-03246
4.1.6 (3) (e) Toilet Rooms:
(i) Where it is technically infeasible to comply with 4.22 or 4.23,

the installation of at least one unisex toilet/bathroom per floor,
located in the same area as existing toilet facilities, will be
permitted in lieu of modifying existing toilet facilities to be
accessible. Each unisex toilet room shall contain one water closet
complying with 4.16 and one lavatory complying with 4.19, and
the door shall have a privacy latch.
(ii) Where it is technically infeasible to install a required standard

stall (Fig. 30(a)), or where other codes prohibit reduction of the
fixture count (i.e., removal of a water closet in order to create a
double-wide stall), either alternate stall (Fig.30(b)) may be provided
in lieu of the standard stall.
(iii) When existing toilet or bathing facilities are being altered and
are not made accessible, signage complying with 4.30.1, 4.30.2,
4.30.3, 4.30.5, and 4.30.7 shall be provided indicating the
location of the nearest accessible toilet or bathing facility within
the facility.
4.1.7 Accessible Buildings: Historic Preservation.
(1) Applicability:
(a) General Rule. Alterations to a qualified historic building or

facility shall comply with 4.1.6 Accessible Buildings: Alterations,
the applicable technical specifications of 4.2 through 4.35 and the
applicable special application sections 5 through 10 unless it is
determined in accordance with the procedures in 4.1.7(2) that
compliance with the requirements for accessible routes (exterior
and interior), ramps, entrances, or toilets would threaten or
destroy the historic significance of the building or facility in which
case the alternative requirements in 4.1.7(3) may be used for the
feature.
51-20-3112 (c) 7. Toilet Rooms. A. Shared Facilities. The

addition of one unisex toilet facility accessible to all
occupants on the floor may be provided in lieu of making
existing toilet facilities accessible when it is technically
infeasible to comply with either part of Chapter 31.
B. Number. The number of toilet facilities and water closets
required by the Uniform Plumbing Code may be reduced by
one, in order to provide accessible features.
[C. Signage. When existing toilet facilities are altered and

not all are made accessible, directional signage complying
with Section 3106(p)3 and 4 shall be provided indicating the
location of the nearest accessible toilet facility.]
51-20-3113 Historic Preservation (a) General. Generally,

the accessibility provisions of this part shall be applied to
historic buildings and facilities as defined in Section 104 (f) of
this code. The building official, after consultation with the
appropriate historic preservation officer, shall determine
whether provisions required by this part for accessible routes
of travel (interior or exterior), ramps, entrances, toilets,
parking or signage would threaten or destroy the historic
significance of the building or facility.
If it is determined that any of the accessibility requirements

listed above would threaten or destroy the historic
significance of a building or facility, the modifications of
Section 3112 (c) for that feature may be utilized.
[N.E. Need to address placement of the unisex toilet in the

same area as existing facilities.]
01-03247
4.1.7 (1) (b) Definition. A qualified historic building or facility is

abuilding
or facility that is:
(i) Listed in or eligible for listing in the National Register of

Historic Places; or
(ii) Designated as historic under an appropriate State or local

law.
4.1.7 (2) Procedures: (a) Alterations to Qualified Historic

buildings and Facilities Subject to Section 106 of the National
Historic Preservation Act:
4.1.7 (2) (a) (i) Section 106 Process. Section 106 of the National
Historic Preservation Act (16 U.S.C. 470 f) requires that a Federal
agency with jurisdiction over a Federal, federally assisted, or
federally licensed undertaking consider the effects of the agency's
undertaking on buildings and facilities listed in or eligible for listing
in the National Register of Historic Places and give the Advisory
Council on Historic Preservation a reasonable opportunity to
comment on the undertaking prior to approval of the undertaking.
4.1.7 (2) (a) (ii) ADA Application. Where alterations are

undertaken to a qualified historic building or facility that is subject
to section 106 of the National Historic Preservation Act, the
Federal agency with jurisdiction over the undertaking shall follow
the section 106 process. If the State Historic Preservation Officer
or Advisory Council on Historic Preservation agrees that
compliance with the requirements for accessible routes (exterior
and interior), ramps, entrances, or toilets would threaten or
destroy the historic significance of the building or facility, the
alternative requirements in 4.1.7(3) may be used for the feature.
51-20-0104 (f) Historic Buildings. Repairs, alterations and

additions necessary for the preservation, restoration,
rehabilitation or continued use of a building or structure may
be made without conformance to all the requirements of this
code when authorized by the building official, provided:
1. The building or structure has been designated by official
action of the legally constituted authority of this jurisdiction
as having special historical or architectural significance.
2. Any unsafe conditions as described in this code are
corrected.
3. The restored building or structure will be no more
hazardous based on life safety, fire safety and sanitation than
the existing building.

01-03248
4.1.7 (2) (b) Alterations to Qualified Historic Buildings and

Facilities Not Subject to Section 106 of the National Historic
Preservation Act. Where alterations are undertaken to a qualified
historic building or facility that is not subject to section 106 of the
National Historic Preservation Act, if the entity undertaking the
alterations believes that compliance with the requirements for
accessible routes (exterior and interior), ramps, entrances, or
toilets would threaten or destroy the historic significance of the
building or facility and that the alternative requirements in 4.1.7(3)
should be used for the feature, the entity should consult with the
State Historic Preservation Officer. If the State Historic
Preservation Office agrees that compliance with the accessibility
requirements for accessible routes (exterior and interior), ramps,
entrances or toilets would threaten or destroy the historical
significance of the building or facility, the alternative requirements
in 4.1.7(3) may be used.
4.1.7 (2) (c) Consultation With Interested Persons. Interested

persons should be invited to participate in the consultation
process, including State or local accessibility officials, individuals
with disabilities, and organizations representing individuals with
disabilities.
4.1.7 (2) (d) Certified Local Government Historic Preservation

Programs. Where the State Historic Preservation Officer has
delegated the consultation responsibility for purposes of this
section to a local government historic preservation program that
has been certified in accordance with section 101(c) of the
National Historic Preservation Act of 1966 (16 U.S.C. 470a (c))
and implementing regulations (36 CFR 61.5), the responsibility
may be carried out by the appropriate local government body or
official.
51-20-3113 (a) ... The building official, after consultation

with the appropriate historic preservation officer, shall
determine whether provisions required by this part for
accessible routes of travel (interior or exterior), ramps,
entrances, toilets, parking or signage would threaten or
destroy the historic significance of the building or facility.
If it is determined that any of the accessibility requirements

listed above would threaten or destroy the historic
significance of a building or facility, the modifications of
Section 3112 (c) for that feature may be utilized.
01-03249
4.1.7 (3) Historic Preservation: Minimum Requirements:
(a) At least one accessible route complying with 4.3 from a

site access point to an accessible entrance shall be provided.
EXCEPTION: A ramp with a slope no greater than 1:6 for a run

not to exceed 2 ft (610 mm) may be used as part of an accessible
route to an entrance.
51-20-3113 (b) Special Provisions. Where removing

architectural barriers or providing accessibility would threaten
or destroy the historic significance of a building or facility, the
following special provisions may be used; 51-20-3113 (b) 1.
At least one accessible route from a site access point to an
accessible route shall be provided.
51-20-3112 (c) Modifications. 1. General. The following

modifications set forth in this section may be used for
compliance where the required standard is technically
infeasible or when providing access to historic buildings
51-20-3112 (c) 2. Ramps. Curb ramps and ramps

constructed on existing sites, or in existing buildings or
facilities, may have slopes and rises as specified for existing
facilities in Chapter 31, where space limitations prohibit the
use of 1 vertical in 12 horizontal slope or less provided that:
A. A slope of not greater than 1 vertical in 10 horizontal is
allowed for a maximum rise of 6 inches.
B. A slope not greater than 1 vertical in 8 horizontal is
allowed for a maximum rise of 3 inches.
C. Slopes greater than 1 vertical in 8 horizontal are
prohibited.
01-03250
51-20-3114 Appeal (a) Request for Appeal. An appeal from

the standards for accessibility for existing buildings may be
filed with the building official in accordance with Section
204, when
Existing structural elements or physical constraints of the

site prevent full compliance or would threaten or destroy the
historical significance of a historic building.
51-20-3114 (b) Review. 1. Consideration of Alternative
Methods. Review of appeal requests shall include
consideration of alternative methods which may provide
partial access.
51-20-3114 (b) 2. Waiver or Modification of Requirements.
The appeals board may waive or modify the requirements of
this section when it is determined that compliance with
accessibility requirements would threaten or destroy the
historic significance of a building or facility.
01-03251
Comment: Issue 33. The Washington request is for a

determination of equivalency of the design and construction
standards between the Washington Building Code and the
ADA provisions. In the commentary to the final rule
publication (page 35591, Federal Register, Volume 56, No
144); the Department of Justice implies that it will not be
reviewing procedures as part of the certification process.
The Washington procedure is only at slight variance from
those contained in the ADA. The Washington law requires
that the building official consult with the appropriate
preservation officer. Therefore, if the building is on the
National Register of Historic Places, the national process will
have to be consulted. If it is a State or local landmark, that
state or local process will be followed.
Under the building code, the ultimate authority for review and
issuance of permits lies with the building official. That duty
technically can't be delegated to another agency or person
outside of the direct authority of the building official. This is
the main reason behind the difference in the Washington
procedure. The net effect may actually be more accessibility,
in that a building official may be less likely to waive
accessibility standards and requirements because of perceived
impacts on historic significance than the specific historic
preservation officer.
[Because the historic preservation provisions of WAC

constitute a waiver, they are not covered by the certification
determination.]
01-03252
3/23/94 letter from Washington State Building Code Council.

Issue 33 - Historic Buildings. The Washington State Building
Code requires local building officials to consult with the
appropriate preservation officer prior to approving use of
alternative standards for accessibility for an historic building.
Questions were raised whether the state process was similar
to the national process. According to Mary Thompson,
Assistant Director of the Washington State Office of
Archeology and Historic Preservation, state and local historic
offices are required to parallel the national process. See
attached letter.
Thompson letter. This letter is written to describe the
process for entering properties onto the Washington State
Register of Historic Places. The State Register is intended to
give recognition and encourage protection to places having
historic significance in the State of Washington.
The State Register process closely parallels the National
Register process. Nominations are accepted by this office
and are reviewed against the State Register Criteria (copy
enclosed). That review takes place first at a staff level and
then before the Washington State Advisory Council on
Historic Preservation. If, in the judgment of the Advisory
Council, a property meets the outlined criteria, they may
recommend it to the State Historic Preservation Officer that it
be placed on the State Register. The final decision on
whether the property is listed belongs to the State Historic
Preservation Officer.
Properties that are reviewed and recommended for the
National Register of Historic Places are automatically included
on the State Register. Separate votes of the Advisory
Council are taken for each listing....
01-03253
4.2.3* Wheelchair Turning Space. The space required for a

wheelchair to make a 180-degree turn is a clear space of 60 in
(1525 mm) diameter (see Fig. 3(a)) or a T-shaped space (see Fig.
3(b)).
Fig. 3 Wheelchair Turning Space.
Fig. 3(b) T-Shaped Space for 180 degree Turns. The T-

shape space is 36 inches (915 mm) wide at the top and stem
within a 60 inch by 60 inch (1525 mm by 1525 mm) square.
51-20-3106 (b) 2. Wheelchair Turning Spaces. Wheelchair

turning spaces shall be designed and constructed to satisfy one of
the following requirements:
A. A turning space not less than 60 inches in diameter; or,
B. A turning space at T-shaped intersections or within a room,

where the minimum width is not less than 36 inches. Each
segment of the T shall be clear of obstructions not less than 24
inches in each direction.
[Wheelchair turning space may include knee and toe clearance in

accordance with Section 3106(b)4C.]
[Amendment: E.]
01-03254
4.3.2 Location.
(1) At least one accessible route within the boundary of the site
shall be provided from public transportation stops, accessible
parking, and accessible passenger loading zones, and public streets
or sidewalks to the accessible building entrance they serve. The
accessible route shall, to the maximum extent feasible, coincide
with the route for the general public.
(2) At least one accessible route shall connect accessible

buildings, facilities, elements, and spaces that are on the same site.
(3) At least one accessible route shall connect accessible building

or facility entrances with all accessible spaces and elements and
with all accessible dwelling units within the building or facility.
(4) An accessible route shall connect at least one accessible

entrance of each accessible dwelling unit with those exterior and
interior spaces and facilities that serve the accessible dwelling unit.
51-20-3103 (b) 2. Accessible Route of Travel. When a building,

or portion of a building, is required to be accessible, an accessible
route of travel shall be provided to all portions of the building, to
accessible building entrances and connecting the building and the
public way. The
accessible route of travel to areas of primary function may serve
but shall not pass through kitchens, storage rooms, toilet rooms,
bathrooms, closets or other similar spaces.
[EXCEPTIONS: 1. A single accessible route shall be permitted to
pass through a kitchen or storage room in an accessible dwelling
unit. 2. Floors above and below accessible levels that have areas
of less than 3,000 square feet per floor, need not be served by an
accessible route of travel from an accessible level. This exception
shall not apply to: A. The offices of health care providers; or, B.
Transportation facilities and airports; or, C. Buildings owned or
leased by government agencies; or, D. Multi-tenant Group B,
Division 2, retail and wholesale occupancies of five tenant spaces
or more.
Accessible routes of travel serving any accessible space or element
shall also serve as a means of egress for emergencies or connect
to an area of evacuation assistance.]
When more than one building or facility is located on a site,
accessible routes of travel shall be provided connecting accessible
buildings and accessible site facilities. The accessible route of
travel shall be the most practical direct route connecting accessible
building entrances, accessible site facilities and the accessible site
entrances.
EXCEPTION [3] [Move up]: For sites where natural terrain or other
unusual property characteristics do not allow the provision of an
accessible route of travel from the public way to the building, the
point of vehicular debarkation may be substituted for the
accessible entrance to the site.
[(For Group R, Division 1 occupancies, see Section 3105(c)1.)]
[Amendment: E.]
01-03255
4.3.8 Changes in Levels. Changes in levels along an accessible

route shall comply with 4.5.2. If an accessible route has changes
in level greater than 1/2 in (13 mm), then a curb ramp, ramp,
elevator, or platform lift (as permitted in 4.1.3 and 4.1.6) shall be
provided that complies with 4.7, 4.8, 4.10, or 4.11, respectively.
An accessible route does not include stairs, steps, or escalators.
See definition of "egress, means of" in 3.5.
4.3.11.3* Stairway Width. Each stairway adjacent to an area of

rescue assistance shall have a minimum clear width of 48 inches
between handrails.
4.3.11.4* Two-way Communication. A method of two-way

communication, with both visible and audible signals, shall be
provided between each area of rescue assistance and the primary
entry. The fire department or appropriate local authority may
approve a location other than the primary entry.
51-20-3106 (d) 4. Changes in Level. Changes in level along an

accessible route of travel shall comply with Section 3106 (f).
Stairs shall not be part of an accessible route of travel. Any raised
area within an accessible route of travel shall be cut through to
maintain a level route or shall have curb ramps at both sides and a
level area not less than 48 inches long connecting the ramps.
51-20-3106 (f) Changes in Level. Accessible routes of travel and

accessible spaces within buildings shall have continuous common
floor or ramp surfaces. Abrupt change in height greater than 1/4
inch shall be beveled to 1 vertical in 2 horizontal. Changes in level
greater than 1/2 inch shall be accomplished by means of a ramp
meeting the requirements of Section 3106 (h) [a curb ramp
meeting the requirements of Section 3106(d)7, or an elevator or
platform lift meeting the requirements of Section 3105(c)]. For
Type B dwelling units, see also Section 3106 (aa).
51-20-3104 (b) 3. Stairway Width. Each stairway adjacent to an

area for evacuation assistance shall have a minimum clear width of
48 inches [between handrails].
Comment: Issue 35. Section 3104(b)3 has been amended to read

in part ". . .shall have a minimum clear width of 48 inches
between handrails." See page 602 of the Published Code.
51-20-3104 (b) 4. Two-way Communication. A telephone with

controlled access to a public telephone system or another method
of two-way communication shall be provided between each area
for evacuation assistance and the primary entry. [The telephone or
other two-way communication system shall be located with the
reach ranges specified in Section 3106(b)4.] The fire department
may approve location other than the primary entrance. [The
communication system shall not require voice communication.]
Comment: Issue 36. Section 3104(b)4 has been amended to

include the following sentence: "The communication system shall
not require voice communication." See page 602 of the Published
Code.
[Amendment: E.]
[E.]
[E.]
01-03257
4.4 Protruding Objects.
4.4.1* General. Objects projecting from walls (for example,

telephones) with their leading edges between 27 in and 80 in (685
mm 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)).
Fig. 8 Protruding Objects.
Fig. 8(c-1) Overhead Hazards. As an example, the diagram

illustrates a stair whose underside descends across a pathway.
Where the headroom is less than 80 inches, protection is offered
by a railing (2030 mm) which can be no higher than 27 inches
(685 mm) to ensure detectability.
Fig. 8(d) Objects Mounted on Posts or Pylons. The

diagram illustrates an area where an overhang can be greater than
12 inches (305 mm) because the object cannot be approached in
the direction of the overhang.
Fig. 8(e) Example of Protection around Wall-Mounted

Objects and Measurements of Clear Widths. The minimum clear
width for continuous passage is 36 inches. Thirty two (32) inches
is the minimum clear width for a maximum distance of 24 inches
(610 mm). The maximum distance an object can protrude beyond
a wing wall is 4 inches (100 mm).
51-20-3106(e) Protruding Objects. Protruding objects shall not

reduce the clear width of an accessible route of travel or
maneuvering space. Any wall- or post-mounted object with its
leading edge between 27 inches and 79 inches above the floor
may project not more than 4 inches into
a [an accessible route of travel, corridor, passageway, or aisle].
Any wall-or post-mounted projection greater than 4 inches shall
extend to the floor.
[Amendment: N.E. It needs to be clear that "accessible"

refers only to "route of travel" and not to "corridor,
passageway, or aisle." Objects may not protrude into
pathways even if those pathways are not otherwise
"accessible". However, because WAC seems to require all
routes in new construction to be accessible, this is only a
potential problem in alterations.]
01-03258
4.5.2 Changes in Level. Changes in level up to 1/4 in (6 mm) may

be vertical and without edge treatment (see Fig. 7(c)). Changes in
level between 1/4 in and 1/2 in (6 mm and 13 mm) shall be
beveled with a slope no greater than 1:2 (see Fig. 7(d)). Changes
in level greater than 1/2 in (13 mm) shall be accomplished by
means of a ramp that complies with 4.7 or 4.8.
4.5.3* Carpet. If carpet or carpet tile is used on a ground or floor

surface, then it shall be securely attached; have a firm cushion,
pad, or backing, or no cushion or pad; and have a level loop,
textured loop, level cut pile, or level cut/uncut pile texture. The
maximum pile thickness shall be 1/2 in (13 mm) (see Fig. 8(f)).
Exposed edges of carpet shall be fastened to floor surfaces and
have trim along the entire length of the exposed edge. Carpet
edge trim shall comply with 4.5.2.

meeting the requirements of Section 3106 (h) [, a curb ramp
meeting the requirements of Section 3106(d)7, or an elevator or
platform lift meeting the requirements of Section 3105(c)]. For
Type B dwelling units, see also Section 3106 (aa).
51-20-3106 (g) 2. Carpeting. Carpeting and floor mats in

accessible areas shall be securely fastened to the underlying
surface, and shall provide a firm, stable, continuous and relatively
smooth surface.
Comment: Issue 37. The Washington State Building Code Council

did not feel that it was appropriate to include carpet pile height
(thickness) in a building code, nor would it be appropriate to
expect building inspectors to inspect for carpet pile height.
Instead the WSR provides performance rather than prescriptive
standards which have a better chance of resulting in accessible
surfaces. In addition it allows greater design flexibility than the
simplistic pile thickness standard.
The Washington accessibility regulations have contained the
requirement that carpeting provide a firm, stable, continuous and
relatively smooth surface since 1976. Experience with this
performance provision is that is adequate for the purpose. While
carpet pile height may be important, the density of carpet piles is
more critical and whether a surface is provided on which a person
in a wheelchair can move and maneuver. The Washington
regulation actually provides a more stringent, more accessible
standard than the ADA.
[Amendment: E.]
[E.]
01-03259
4.6.2 Location. Accessible parking spaces serving a particular

building shall be located on the shortest accessible route of travel
from adjacent parking to an accessible entrance. In parking
facilities that do not serve a particular building, accessible parking
shall be located on the shortest accessible route of travel to an
accessible pedestrian entrance of the parking facility. In buildings
with multiple accessible entrances with adjacent parking,
accessible parking spaces shall be dispersed and located closest to
the accessible entrances.
4.6.3* Parking Spaces. Accessible parking spaces shall be at least

96 in (2440 mm) wide. Parking access aisles shall be part of an
accessible route to the building or facility entrance and shall
comply with 4.3. Two accessible parking spaces may share a
common access aisle (see Fig. 9). Parked vehicle overhangs shall
not reduce the clear width of an accessible route. Parking spaces
and access aisles shall be level with surface slopes not exceeding
1:50 (2%) in all directions.
Fig. 9 Dimensions of Parking Spaces.
The access aisle shall be a minimum of 60 inches (1525

mm) wide for cars or a minimum of 96 inches (2440 mm) wide for
vans. The accessible route connected to the access aisle at the
front of the parking spaces shall be a minimum of 36 inches (915
mm).
51-20-3107 (a) . . .[6] Accessible parking spaces shall be
located on the shortest possible accessible route of travel to an
accessible building entrance. In facilities with multiple accessible
building entrances with adjacent parking, accessible parking spaces
shall be dispersed and located near the accessible entrances.
Wherever practical, the accessible route of travel shall not cross
lanes of vehicular traffic. Where crossing traffic lanes is
necessary, the route of travel shall be designated and marked as a
crosswalk.
[EXCEPTION: In multilevel parking structures, all accessible van
parking spaces may be located on the same level.
Where a parking facility is not accessory to a particular building,
accessible parking spaces shall be located on the shortest
accessible route to an accessible pedestrian entrance to the
parking facility.]
51-20-3107 (b) 2. Size. Parking spaces shall be not less than 96

inches in width and shall have an adjacent access aisle not less
than 60 inches in width. [Van accessible parking spaces shall
have an adjacent access aisle not less than 96 inches in width.]
Where two adjacent spaces are provided, the access aisle may be
shared between the two spaces. Boundaries of access aisles shall
be marked so that aisles will not be used as parking space.
51-20-3107 (b) 4. Slope. Accessible parking spaces and access

aisles shall be located on a surface with a slope not to exceed 1
vertical in 48 horizontal.
51-20-3107 (b) 5. Surface. Parking spaces and access aisles
shall be firm, stable, smooth and slip-resistant.
[Amendment: E]
[Amendment: E]
01-03260
4.6.4* Signage. Accessible parking spaces shall be designated as
reserved by a sign showing the symbol of accessibility (see
4.30.7). Spaces complying with 4.1.2(5)(b) shall have an
additional sign "Van-Accessible" mounted below the symbol of
accessibility. Such signs shall be located so they cannot be
obscured by a vehicle parked in the space.
4.6.5* Vertical Clearance. Provide minimum vertical clearance of

114 in (2895 mm) at accessible passenger loading zones and along
at least one vehicle access route to such areas from site
entrance(s) and exit(s). At parking spaces complying with
4.1.2(5)(b), provide minimum vertical clearance of 98 in (2490
mm) at the parking space and along at least one vehicle access
route to such spaces from site entrance(s) and exit(s).
51-20-3107 (c) Signs. Every parking space required by this

section shall be identified by a sign, centered between 3 and 5
feet above the parking surface, at the head of the parking space.
The sign shall include the International Symbol of Access and the
phrase "State Disabled Parking Permit Required." [Van accessible
parking spaces shall have an additional sign mounted below the
International Symbol of Access identifying the spaces as "Van
Accessible."
EXCEPTION: Where all of the accessible parking spaces comply
with the standards for van accessible parking spaces. (See also
Section 3106(aa)2.)]
Comment: Issue 38. Section 3107(c) has been amended to

require the additional van accessible signage. See page 604t of
the Published Code.
51-20-3107 (b) 3. Vertical Clearance. Where accessible parking

spaces are provided for vans, the vertical clearance shall be not
less than 114 inches [at the parking space and along at least one
vehicle access route to such spaces from site entrances and exits].
Comment: Issue 39. Section 3107(b)3 has been amended to read

in part ". . . the vertical clearance shall be not less than 114
inches at the parking space and along at least one vehicle access
route to such spaces from site entrances and exits." (See page
604s of the Published Code.) It should be noted that the
Washington van height provides greater accessibility than the
ADA.
The intent of the WSR van parking height requirement was to
apply to loading zones as well because these are essentially
temporary parking spaces for all types of vehicles. To clarify the
intent of the Code, the Council has issued interpretation No. 93-
33.
[E.]
[Amendment: E.]
[E.]
01-03261
4.6.6 Passenger Loading Zones. Passenger loading zones shall

provide an access aisle at least 60 in (1525 mm) wide and 20 ft
(240 in)(6100 mm) long adjacent and parallel to the vehicle pull-up
space (see Fig. 10). If there are curbs between the access aisle
and the vehicle pull-up space, then a curb ramp complying with 4.7
shall be provided. Vehicle standing spaces and access aisles shall
be level with surface slopes not exceeding 1:50 (2%) in all
directions.
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 guardrail, 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)).
Fig. 12 Sides of Curb Ramps.

Fig. 12(a) Flared Sides. If the landing depth at the top of a
curb ramp is less than 48 inches, then the slope of the flared side
shall not exceed 1:12.
Interpretation No. 93-33

Question: Are there any height (clearance) requirements for
passenger load zones?
Answer: The intent of the code, as provided in Sec. 3101(a), is to
provide standards equivalent to the ADA Accessibility Guidelines.
Accessible passenger load zones are essentially temporary parking
spaces. The loading zones and the vehicular route to and from the
load zones must have a clear height of 114 inches, as is required
for van parking spaces.
51-20-3108 Passenger Drop-off and Loading Zones. (a) Location.

Where provided, passenger loading zones shall be
located on an accessible route of travel.
51-20-3108 (b) [2] Size.

Passenger loading zones shall provide an access aisle not less than
5 feet in width by 20 feet in length with the long dimension
abutting and parallel to: (1) the vehicle space on one side and (2)
an accessible route of travel on the other.
51-20-3108 (b) 3. Slope. Such zones shall be located on a

surface with a slope not exceeding 1 vertical in 48 horizontal.
51-20-3106 (d) [7] C. Side Slopes of Curb Ramps. Curb ramps

located where pedestrians must walk across the ramp, or where
not protected by handrails or guardrails, shall have sloped sides.
The maximum side slope shall be 1 vertical in 10 horizontal. Curb
ramps with returned curbs may be used where pedestrians would
not normally walk across the ramp.
[EXCEPTION: Where the width of the walking surface at the top

of the ramp and parallel to the run of the ramp is less than 48
inches, the maximum side slope shall be 1 vertical in 12
horizontal.]
[E.]
[Amendment: E.]
01-03262
4.7.7 Detectable Warnings. A curb ramp shall have a detectable

warning complying with 4.29.2. The detectable warning shall
extend the full width and depth of the curb ramp.
4.7.10 Diagonal Curb Ramps. If diagonal (or corner type) curb

ramps have returned curbs or other well-defined edges, such edges
shall be parallel to the direction of pedestrian flow. The bottom of
diagonal curb ramps shall have 48 in (1220 mm) minimum clear
space as shown in Fig. 15(c) and (d). If diagonal curb ramps are
provided at marked crossings, the 48 in (1220 mm) clear space
shall be within the markings (see Fig. 15(c) and (d)). If diagonal
curb ramps have flared sides, they shall also have at least a 24 in
(610 mm) long segment of straight curb located on each side of
the curb ramp and within the marked crossing (see Fig. 15(c)).
Comment: Issue 40. Section 3106(d)7C has been amended to

add the following additional provision: ... [see above]. See page
604b of the Published Code.
51-20-3106 (d) 5. B. Detectable Warnings. Curb ramps shall

have detectable warnings complying with Section 3106 (q).
Detectable warnings shall extend the full width and depth of the
curb ramp.
51-20-3106 (d) [8]. Vehicular Areas. Where an accessible route

of travel crosses or adjoins a vehicular way, and where there are
no curbs, railings or other elements [which separate the pedestrian
and vehicular areas, and which are] detectable by a person who
has severe vision impairment
the boundary between the areas shall be defined
by a continuous detectable warning not less than 36 inches wide,
complying with Section 3106 (g).

Comment: Issue 42. Diagonal curb ramp standards are not
included in the WSR. Therefore, diagonal curb ramps are not
directly permitted by the Washington Code. This design is rarely
seen in designs for private development, but is more typically
found at street intersection designs. The Washington Building
Code does not apply to public rights of way, but only to
development off of public rights of way. If someone wishes to use
it, it could be approved by the local building official as an alternate
design (equivalent facilitation).
[E.]
[E.]
NE No equivalent provisions.
[N.E. WSR does not prohibit use of diagonal curb ramps

and leaves regulation of such ramps completely up to the
discretion of the inspector. The special provisions for
diagonal curb ramps are necessary to allow people enough
space to maneuver out of the way of traffic and to lessen
pedestrian traffic on the ramp so that individuals in
wheelchairs can use it.]
01-03263
4.8.2* Slope and Rise. The least possible slope shall be used for
any ramp. The maximum slope of a ramp in new construction shall
be 1:12. The maximum rise for any run shall be 30 in (760 mm)
(see Fig. 16). Curb ramps and ramps to be constructed on existing
sites or in existing buildings or facilities may have slopes and rises
as shown as allowed in 4.1.6(3)(a) if space limitations prohibit the
use of a 1:12 slope or less (see 4.1.6).
Fig. 16 Components of a Single Ramp Run and Sample Ramp

Dimensions.
If the slope of a ramp is between 1:12 and 1:16, the

maximum rise shall be 30 inches (760 mm) and the maximum
horizontal run shall be 30 feet (9 m). If the slope of the ramp is
between 1:16 and 1:20, the maximum rise shall be 30 inches (760
mm) and the maximum horizontal run shall be 40 feet (12 m).
51-20-3106 (h) 2. Slope and Rise. The maximum slope of a ramp

shall be 1 vertical in 12 horizontal. The maximum rise for any run
shall be 30 inches.
51-20-3315 (e) Ramp Slope. The slope of ramped aisles shall not
be more than 1 vertical in 8 horizontal. Ramped aisles shall have a
slip-resistant surface.
EXCEPTION: When provided with fixed seating, theaters may

have a slope not steeper than 1 vertical to 5 horizontal.
Comment: Issue 43. The ramped aisles allowed by Section

3315(e) of the UBC are not allowed as part of an accessible route.
Specifically Section 3315(a) states: "Aisles located within an
accessible route of travel shall also comply with Chapter 31."
Chapter 31 limits slope on accessible routes to a maximum rise of
1 in 12.
[E.]
01-03264
4.8.5* Handrails. If a ramp run has a rise greater than 6 in (150

mm) or a horizontal projection greater than 72 in (1830 mm), then
it shall have handrails on both sides. Handrails are not required on
curb ramps or adjacent to seating in assembly areas. Handrails
shall comply with 4.26 and shall have the following features:
(1) Handrails shall be provided along both sides of ramp

segments. The inside handrail on switchback or dogleg ramps shall
always be continuous.
51-20-3106 (h) 5. Handrails. Ramps having slopes steeper than 1

vertical in 20 horizontal shall have handrails as required for
stairways, except that intermediate handrails as required in Section
3306 (i) are not required. Handrails shall be continuous provided
that they shall not be required at any point of access along the
ramp, nor at any curb ramp. Handrails shall extend at least 12
inches beyond the top and bottom of any ramp segment.
EXCEPTION: Ramps having a rise less than or equal to 6 inches or

a run less than or equal to 72 inches need not have handrails.
51-20-3306 (i) Handrails. Stairways shall have handrails on each

side, and every stairway required to be more than 88 inches in
width shall be provided with not less than one intermediate
handrail for each 88 inches of required width. Intermediate
handrails shall be spaced approximately equally across the entire
width of the stairway.
EXCEPTION: 1. Stairways less than 44 inches in width or

stairways serving one individual dwelling unit in Group R, Division
1 or 3 Occupancies, or a Group R, Division 3 congregate residence
may have one handrail.
2. Private stairways 20 inches or less in height may have
handrails on one side only.
3. Stairways having less than four risers and serving one
individual dwelling unit in Group R, Division 1 or 3, or a Group R.
Division 3 congregate residence or serving Group M. Occupancies
need not have handrails.

01-03265
(2) If handrails are not continuous, they shall extend at least 12

in (305 mm) beyond the top and bottom of the ramp segment and
shall be parallel with the floor or ground surface (see Fig. 17).
(3) The clear space between the handrail and the wall shall be 1 -
1/2 in (38 mm).
(4) Gripping surfaces shall be continuous.
(5) Top of handrail gripping surfaces shall be mounted between

34 in and 38 in (865 mm and 965 mm) above ramp surfaces.
(6) Ends of handrails shall be either rounded or returned smoothly

to floor, wall, or post.
(7) Handrails shall not rotate within their fittings.
The top of handrails and handrail extensions shall be placed not

less than 34 inches or more than 38 inches above the nosing of
treads and landings. Handrails shall be continuous the full length
of the stairs and, except for private stairways, at least one handrail
shall extend in the direction of the stair run not less than 12 inches
beyond the top riser or less than 23 inches beyond the bottom
riser. Ends shall be returned or shall terminate in newel posts or
safety terminals.
The handgrip portion of handrails shall be not less than 1 1/2

inches or more than 2 inches in cross-sectional dimension or the
shape shall provide an equivalent gripping surface. The handgrip
portion of handrails shall have a smooth surface with no sharp
corners.
Handrails projecting from a wall shall have a space of not less than
1 1/2 inches between the wall and the handrail. Any recess
containing a handrail shall allow a clearance of not less than 18
inches above the top of the rail, and shall be not more than 3
inches in horizontal depth.
Handrails shall not rotate within their fittings.
Comment: Issue 44. The reference to Section 3306(i) for handrail

requirements could be construed to allow single handrails in some
circumstances. Since the exceptions only specifically state
stairways, it was the intent of the Council that these exceptions
not apply to ramps. The Council has issued Interpretation No. 93-
35 to clarify this limitation.
[E.]
01-03266

Question: Do the exceptions in Section 3306(i) allowing only one
handrail apply to ramps and stairways required to be accessible by
Chapter 31?
Answer: The intent of the code, as provided in Sec. 3101(a) is to
Ramps. The exceptions do not apply to ramps designed for
compliance with Chapter 31. Such ramps must provide handrails
on both sides.
Stairways. For stairways which provide access to areas of
buildings where the accessible route exceptions have been used
and no elevator or ramp is provided (per Sec. 3103(b)), handrails
must be provided on both sides of the stairway regardless of the
occupant load served.

01-03267
4.8.7 Edge Protection. Ramps and landings with drop-offs shall

have curbs, walls, railings, or projecting surfaces that prevent
people from slipping off the ramp. Curbs shall be a minimum of 2
in (50 mm) high (see Fig. 17).
[51-20-3106(h)7. Edge Protection. Any portion of the edge of a

ramp with a slope greater than 1 vertical in 20 horizontal, or
landing which is more than 1/2 inch above the adjacent grade or
floor, shall be provided with edge protection in accordance with
the following: A. Walls and Curbs. When used, walls or curbs
shall be not less than 2 inches in height above the surface of the
accessible route of travel. B. Railings. When used, railings shall
comply with Section 3106(h)5 and also shall have one of the
following features: (i) An intermediate rail mounted 17 to 19
inches above the ramp or landing surface, or (ii) A guardrail
complying with Section 1712.]
[Amendment: E.]
01-03268
4.9.4 Handrails. Stairways shall have handrails at both sides of all

stairs. Handrails shall comply with 4.26 and shall have the
following features:
(1) Handrails shall be continuous along both sides of stairs. The
inside handrail on switchback or dogleg stairs shall always be
continuous (see Fig. 19(a) and (b)).
(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.
(3) The clear space between handrails and wall shall be 1-1/2 in
(38 mm).
(4) Gripping surfaces shall be uninterrupted by newel posts,

other construction elements, or obstructions.
(5) Top of handrail gripping surface shall be mounted between

34 in and 38 in (865 mm and 965 mm) above stair nosing.
(6) Ends of handrails shall be either rounded or returned smoothly

to floor, wall or post.
(7) Handrails shall not rotate within their fittings.
51-20-3306 (i) Handrails. Stairways shall have handrails on each

side, and every stairway required to be more than 88 inches in
width shall be provided with not less than one intermediate
handrail for each 88 inches of required width. Intermediate
handrails shall be spaced approximately equally across the entire
width of the stairway.
EXCEPTION: 1. Stairways less than 44 inches in width or

stairways serving one individual dwelling unit in Group R, Division
1 or 3 Occupancies, or a Group R, Division 3 congregate residence
may have one handrail.
2. Private stairways 20 inches or less in height may have
handrails on one side only.
3. Stairways having less than four risers and serving one
individual dwelling unit in Group R, Division 1 or 3, or a Group R,
Division 3 congregate residence or serving Group M. Occupancies
need not have handrails.
3306 (i) Handrails. ... The top of handrails and handrail
extensions shall be placed not less than 34 inches or more than 38
inches above the nosing of treads and landings. Handrails shall be
continuous the full length of the stairs and, except for private
stairways, at least one handrail shall extend in the direction of the
stair run not less than 12 inches beyond the top riser or less than
23 inches beyond the bottom riser. Ends shall be returned or shall
terminate in newel posts or safety terminals.
The handgrip portion of handrails shall be not less than 1 1/2

inches or more than 2 inches in cross-sectional dimension or the
shape shall provide an equivalent gripping surface. The handgrip
portion of handrails shall have a smooth surface with no sharp
corners.
Handrails projecting from a wall shall have a space of not less than
1 1/2 inches between the wall and the handrail. Any recess
containing a handrail shall allow a clearance of not less than 18
inches above the top of the rail, and shall be not more than 3
inches in horizontal depth.
Handrails shall not rotate within their fittings.
01-03860
4.10 Elevators.
4.10.1 General. Accessible elevators shall be on an accessible

route and shall comply with 4.10 and with the ASME A17.1-1990,
Safety Code for Elevators and Escalators. Freight elevators shall
not be considered as meeting the requirements of this section
unless the only elevators provided are used as combination
passenger and freight elevators for the public and employees.
Comment: Issue 45. Section 3306(a) requires all stairways to be

44 inches wide or more unless the occupant load served is less
than 50. These are all fairly small buildings, and typically
stairways less than 44 inches only occur in residential (non
transient) apartment buildings. Use in commercial, educational or
assembly buildings is very rare. To clarify that handrails on
accessible stairs must have two handrails, the Council has issued

Question: Do the exceptions in Section 3306(i) allowing only one
handrail apply to ramps and stairways required to be accessible by
Chapter 31?
Answer: The intent of the code, as provided in Sec. 3101 (a) is to
Ramps. The exceptions do not apply to ramps designed for
compliance with Chapter 31. Such ramps must provide handrails
on both sides.
Stairways. For stairways which provide access to areas of
buildings where the accessible route exceptions have been used
and no elevator or ramp is provided (per Sec. 3103(b)), handrails
must be provided on both sides of the stairway regardless of the
occupant load served.
51-20-3105 (c) Elevators. 2-[B] Design. All elevators shall be
accessible.
EXCEPTION: 1. Private elevators serving only one dwelling unit.

2. Where more than one elevator is provided in the building,
elevators used exclusively for movement of freight.
Elevators required to be accessible shall be designed and

constructed to comply with Chapter 296-81 of the Washington
Administrative Code.
[296-81-007 (5) The American National Standard Safety Code for

Elevators, Dumbwaiters, Escalators, and Moving Walks, ANSI
A17.1, 1990 Edition is adopted as the standard for elevators,
dumbwaiters, escalators and moving walks installed on or after
July 1, 1992, with the exceptions of ANSI A17.1, part XIX, and
ANSI A17.1, part V, Section 513, which is replaced by chapter
296-94 WAC.]
[E.]
01-03861
4.10.2 Automatic Operation. Elevator operation shall be

automatic.
Each car shall be equipped with a self-leveling feature that will

automatically bring the car to floor landings within a tolerance of
1/2 in (13 mm) under rated loading to zero loading conditions.
This self-leveling feature shall be automatic and independent of the
operating device and shall correct the overtravel or undertravel.
4.10.3 Hall Call Buttons. Call buttons in elevator lobbies and halls
shall be centered at 42 in (1065 mm) above the floor. Such call
buttons shall have visual signals to indicate when each call is
registered and when each call is answered. Call buttons shall be a
minimum of 3/4 in (19 mm) in the smallest dimension. The button
designating the up direction shall be on top. (See Fig. 20.)
Buttons shall be raised or flush. Objects mounted beneath hall call
buttons shall not project into the elevator lobby more than 4 in
(100 mm).
4.10.4 Hall Lanterns. A visible and audible signal shall be provided

at each hoistway entrance to indicate which car is answering a
call. Audible signals shall sound once for the up direction and
twice for the down direction or shall have verbal annunciators that
say "up" or "down." Visible signals shall have the following
features:
(1) Hall lantern fixtures shall be mounted so that their centerline

is at least 72 in (1830 mm) above the lobby floor. (See Fig. 20.)
(2) Visual elements shall be at least 2-1/2 in (64 mm) in the

smallest dimension.
(3) Signals shall be visible from the vicinity of the hall call button
(see Fig. 20). In-car lanterns located in cars, visible from the
vicinity of hall call buttons, and conforming to the above
requirements, shall be acceptable.
Comment: Issue 46. See comment on Issue No. 16, above. Also
see attached side by side analysis of the adopted Washington
elevator standards and ADAAG standards.
[296-81-300. Operation and leveling. The elevator shall be

automatic and be provided with a self-leveling feature that will
automatically bring the car to the floor landings within a tolerance
of plus or minus 1/2 inch under normal loading and unloading
conditions. This self-leveling shall within its zone, be entirely
automatic and independent of the operating device and shall
correct for overtravel or undertravel. The car shall also be
maintained approximately level with the landing irrespective of
load.]
[296-81-355. Hall Buttons. The centerline of the hall call buttons

shall be a nominal (42) inches above the floor. The button
designating the UP direction shall be on top.
Direction buttons, exclusive of border, shall be a minimum of (3/4)
inch in size, raised or flush. Visual indication shall be provided to
show each call registered and extinguished when the call is
answered. Depth of flush buttons when operated shall not exceed
(3/8) inch.]
[296-81-360. Hall lantern. A visual and audible signal shall be

provided at each hoistway entrance, indicating to the prospective
passenger which car is answering the call and its direction of
travel.
The visual signal for each direction shall be at least two and one-
half inches in size and visible from the vicinity of the hall call
button. The audible signal shall sound once for the up direction
and twice for the down direction.
The centerline of the fixture shall be located at least six feet from
the floor.
The lanterns may be located in the jamb or in the car.]
[See below]
[Amendment: E.]
[Amendment: E.]
[Amendment: E.]
01-03862
4.10.5 Raised and Braille Characters on Hoistway Entrances. All

elevator hoistway entrances shall have raised and Braille floor
designations provided on both jambs. The centerline of the
characters shall be 60 in (1525 mm) above finish floor. Such
characters shall be 2 in (50 mm) high and shall comply with
4.30.4. Permanently applied plates are acceptable if they are
permanently fixed to the jambs. (See Fig. 20).
4.10.6* Door Protective and Reopening Device. Elevator doors

shall open and close automatically. They shall be provided with a
reopening device that will stop and reopen a car door and hoistway
door automatically if the door becomes obstructed by an object or
person. The device shall be capable of completing these
operations without requiring contact for an obstruction passing
through the opening at heights of 5 in and 29 in (125 mm and 735
mm) above finish floor (see Fig. 20). Door reopening devices shall
remain effective for at least 20 seconds. After such an interval,
doors may close in accordance with the requirements of ASME
A17.1-1990.
4.10.7* Door and Signal Timing for Hall Calls. The minimum
acceptable time from notification that a car is answering a call until
the doors of that car start to close shall be calculated from the
following equation:
T = D/(1.5 ft/s) or T = D/(445 mm/s)

where T total time in seconds and D distance (in feet or
millimeters) from a point in the lobby or corridor 60 in (1525 mm)
directly in front of the farthest call button controlling that car to
the centerline of its hoistway door (see Fig. 21). For cars with
in-car lanterns, T begins when the lantern is visible from the
vicinity of hall call buttons and an audible signal is sounded. The
minimum acceptable notification time shall be 5 seconds.
4.10.8 Door Delay for Car Calls. The minimum time for elevator
doors to remain fully open in response to a car call shall be 3
seconds.
[296-81-350. Door jamb marking. The floor designation shall be

provided at each hoistway entrance on both sides of jamb visible
from within the car and the elevator lobby at a centerline height of
(60) inches above the floor. Designations shall be on contrasting
color background (2) inches high and raised (.30) inch, and shall
be accompanied by Grade 2 Braille. Applied plates permanently
attached shall be acceptable.]
[296-81-310 Door delay. (1). Hall call. The minimum acceptable

initial transfer time from notification that a car is answering a call
(lantern and audible signal) until the doors of the car start to close
shall be 0 to 5 ft.-4 sec.; 10 ft.-7 sec.; 15 ft.-10 sec.; 20 ft.-13
sec. The distance shall be established from a point in the center of
the corridor or lobby (maximum 5 feet) directly opposite the
farthest hall button controlling that car to the centerline of the
hoistway entrance.]
[296-81-310 Door delay. (2). Car call. The minimum acceptable

initial transfer time for doors to remain fully open shall be not less
than 3 seconds.]
[Amendment: E.]
NE
[Amendment: E.]
[Amendment: E.]
01-03863
4.10.9 Floor Plan of Elevator Cars. The floor area of elevator cars
shall provide space for wheelchair users to enter the car, maneuver
within reach of controls, and exit from the car. Acceptable door
opening and inside dimensions shall be as shown in Fig. 22. The
clearance between the car platform sill and the edge of any
hoistway landing shall be no greater than 1-1/4 in (32 mm).
Fig. 22 Minimum Dimensions of Elevator Cars.
Diagram (a) illustrates an elevator with a door providing a

36 inch (915 mm) minimum clear width, in the middle of the
elevator. The width of the elevator car is a minimum of 80 inches
(2030 mm). The depth of the elevator car measured from the back
wall to the elevator door is a minimum of 54 inches (1370 mm).
The depth of the elevator car measured from the back wall to the
control panel is a minimum of 51 inches (1291 mm).
Diagram (b) illustrates an elevator with door providing a

minimum 36 inch (915 mm) clear width, located to one side of the
elevator. The width of the elevator car is a minimum of 68 inches
(1730 mm). The depth of the elevator car measured from the back
wall to the elevator door is a minimum of 54 inches (1370 mm).
The depth of the elevator car measured from the back wall to the
control panel is a minimum of 51 inches (1291).
4.10.10 Floor Surfaces. Floor surfaces shall comply with 4.5.
4.10.11 Illumination Levels. The level of illumination at the car

controls, platform, and car threshold and landing sill shall be at
least 5 footcandles (53.8 lux).
[296-81-315 Car interior. The car interior shall provide space for
wheelchair users to enter the car, maneuver within reach of
controls and exit the car. (1) Doors shall provide (36) inches clear
minimum width. (2) Car depth (51) inches minimum from rear wall
to return panel, with (54) inches minimum from rear wall to inside
face of cab door. (3) Cab width of cab for side opening door (68)
inches minimum, center opening door cab width (80) inches
minimum.
Clearance between car platform sill and edge of hoistway landing

sill shall be (1 1/4) inches maximum.
EXCEPTION: Elevators provided in existing schools, institutions,

or other buildings specifically authorized by local authorities may
have a minimum clear distance between walls or between wall and
door including return panels of not less than 54 X 54 inches.
Minimum distance from wall to return panel shall be not less than
51 inches.]
[296-81-335 Floor covering. Floor covering should have a nonslip

hard surface which permits easy movement of wheelchairs. If
carpeting is used, it should be securely attached, heavy duty, with
a tight weave and low pile, installed without padding.]
[296-81-345 Minimum illumination. The minimum illumination

shall be in accordance with the latest edition of ANSI A17.1.]
[Amendment: E.]
[Amendment: E.]
[Amendment: E.]
01-03864
4.10.12* Car Controls. Elevator control panels shall have the
following features:
(1) Buttons. All control buttons shall be at least 3/4 in (19 mm)
in their smallest dimension. They shall be raised or flush.
(2) Tactile, Braille, and Visual Control Indicators. All control
buttons shall be designated by Braille and by raised standard
alphabet characters for letters, arabic characters for numerals, or
standard symbols as shown in Fig. 23(a), and as required in ASME
A17.1-1990. Raised and Braille characters and symbols shall
comply with 4.30. The call button for the main entry floor shall be
designated by a raised star at the left of the floor designation (see
Fig. 23(a)). All raised designations for control buttons shall be
placed immediately to the left of the button to which they apply.
Applied plates, permanently attached, are an acceptable means to
provide raised control designations. Floor buttons shall be provided
with visual indicators to show when each call is registered. The
visual indicators shall be extinguished when each call is answered.
(3) Height. All floor buttons shall be no higher than 54 in (1370

mm) above the finish floor for side approach and 48 in (1220 mm)
for front approach. Emergency controls, including the emergency
alarm and emergency stop, shall be grouped at the bottom of the
panel and shall have their centerlines no less than 35 in (890 mm)
above the finish floor (see Fig. 23(a) and (b)).
Fig. 23 Car Controls.
Fig. 23(a) Panel Detail. The diagram illustrates the

symbols used for the following control buttons: main entry floor,
door closed, door open, emergency alarm, and emergency stop.
The diagram further states that the octagon symbol for the
emergency stop shall be raised but the X (inside the octagon) is
not.
(4) Location. Controls shall be located on a front wall if cars

have center opening doors, and at the side wall or at the front wall
next to the door if cars have side opening doors (see Fig. 23(c) and
(d)).
[296-81-320 Car controls. At least one set of controls shall be
readily accessible from a wheelchair upon entering an elevator.
The centerline of the alarm button and emergency stop switch

shall be at nominal (35) inches and the highest floor buttons no
higher than (54) inches from the floor where side approach is
provided. (48) inches maximum where forward approach is
required. Floor registration buttons, exclusive of border, shall be a
minimum of (3/4) inch in size, raised or flush. Visual indication
shall be provided to show each call registered and extinguished
when call is answered. Depth of flush buttons when operated
shall not exceed (3/8) inch.
Markings shall be adjacent to the controls on a contrasting color

background to the left of the controls. Letters or numbers shall be
a minimum of (5/8) inch high and raised (.030) inch. All control
buttons shall be designated by Braille. Applied plates permanently
attached shall be acceptable. Emergency controls shall be grouped
together at the bottom of the control panel. Symbols as indicated
shall be used to assist in readily identifying essential controls (see
ANSI A17.1, page 114, Rule 211.1). Controls not essential to the
operation of the elevator may be located as convenient.]
[Amendment: E. Although the ADA requires all panels to

be at wheelchair-accessible height and WAC only requires
1, having several control panels at different heights can
serve more people (higher panels help people who have
difficulty bending). As long as all panels are accessible to
people with visual impairments, this is alright.]
NE

01-03865
4.10.13* Car Position Indicators. In elevator cars, a visual car

position indicator shall be provided above the car control panel or
over the door to show the position of the elevator in the hoistway.
As the car passes or stops at a floor served by the elevators, the
corresponding numerals shall illuminate, and an audible signal shall
sound. Numerals shall be a minimum of « in (13 mm) high. The
audible signal shall be no less than 20 decibels with a frequency no
higher than 1500 Hz. An automatic verbal announcement of the
floor number at which a car stops or which a car passes may be
substituted for the audible signal.
4.10.14* Emergency Communications. If provided, emergency

two-way communication systems between the elevator and a point
outside the hoistway shall comply with ASME A17.1-1990. The
highest operable part of a two-way communication system shall be
a maximum of 48 in (1220 mm) from the floor of the car. It shall
be identified by a raised symbol and lettering complying with 4.30
and located adjacent to the device. If the system uses a handset
then the length of the cord from the panel to the handset shall be
at least 29 in (735 mm). If the system is located in a closed
compartment the compartment door hardware shall conform to
4.27. Controls and Operating Mechanisms. The emergency
intercommunication system shall not require voice communication.
[296-81-325 Car position indicator signal. A visual car position

indicator shall be provided above the car control panel or above the
door.
(1) As the car passes or stops at a floor, the corresponding

numbers shall illuminate and an audible signal shall sound.
(2) Numerals shall be a minimum (1/2) inch high.
(3) Audible signal shall be no less than (20) decibels with
frequency no higher than 1500 Hz.
(4) An automatic verbal announcement of the floor number may be
substituted for the audible signal.]
[296-81-330 Telephone or intercommunicating system. An

emergency two-way communication system shall be provided
between the elevator and a point outside the hoistway that shall
comply with ASME/ANSI A17.1-1990, and the following:
(1) Highest operable part of system shall be maximum (48) inches
from the floor.
(2) System shall be identified by raised symbol and lettering
located adjacent to the device. Characters shall be (5/8) inch to
(2) inches high, raised (1/32) inch, upper case, sans serif or simple
serif type, and shall be accompanied by Grade 2 Braille.
(3) If system uses a handset, minimum cord length shall be (29)
inches.
(4) If located in a closed compartment, door shall be operable with
one hand, shall not require tight grasping, pinching, or twisting of
the wrist, and shall require a maximum force of (5) lbf.
(5) The emergency communication system shall not require voice
communication. (Voice only system is inaccessible to persons
with speech or hearing impairments.)]
[296-81-340 Handrails. A handrail shall be provided on all walls of

the car that are not used for normal exits. There shall be a space
of one and one-half inches between the wall and the rail. The rail
shall be at a nominal height of between thirty-two and thirty-five
inches from the floor. The hand grip portion of handrails shall be
not less than one and one-quarter inches or more than two inches
in width, shall be basically oval or round in cross-section, and shall
have smooth surfaces with no sharp corners. Handrails that
approach each other or a blank car wall in the interior corners of
the car need not be returned to the wall. If the end of the handrail
presents an abrupt end on the closing jamb wall to persons
entering a car that has a single-slide or two-speed entrance, the
handrail end shall be returned to the wall.]
[Amendment: E.]
[Amendment: E.]

01-03866
4.11 Platform Lifts (Wheelchair Lifts).
4.11.1 Location. Platform lifts (wheelchair lifts) permitted by 4.1

shall comply with the requirements of 4.11.
4.11.2* Other Requirements. If platform lifts (wheelchair lifts) are

used, they shall comply with 4.2.4, 4.5, 4.27, and ASME A17.1
Safety Code for Elevators and Escalators, Section XX, 1990.
4.11.3 Entrance. If platform lifts are used then they shall facilitate
unassisted entry, operation, and exit from the lift in compliance
with 4.11.2.
See below.
51-20-3105 (c) 3. All platform lifts used in lieu of an elevator

shall be capable of independent operation and shall comply with
Chapter 296-81 of the Washington Administrative Code.
[296-81-007. National Elevator Code Adopted. ... (5) The

American National Standard Safety Code for Elevators,
Dumbwaiters, Escalators, and Moving Walks, ANSI A17.1, 1990
Edition is adopted as the standard for elevators, dumbwaiters,
escalators, and moving walks installed on or after July 1, 1992,
with the exceptions of ANSI A17.1, Part XIX, and ANSI A17.1,
Part V, Section 513, which is replaced by chapter 296-94 WAC.]
[Amendment: E.]
01-03867
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.
Fig. 25 Maneuvering Clearances at Doors. NOTE: All doors in

alcoves shall comply with the clearances for front approaches.
Diagram (a) Front Approaches--Swinging Doors. Front

approaches to pull side of swinging doors shall have maneuvering
space that extends 18 in (455 mm) minimum beyond the latch side
of the door and 60 in (1525 mm) minimum perpendicular to the
doorway.
Front approaches to push side of swinging doors, equipped

with both closer and latch, shall have maneuvering space that
extends 12 in (305 mm) minimum beyond the latch side of the
door and 48 in (1220 mm) minimum perpendicular to the doorway.
Front approaches to push side of swinging doors, not

equipped with latch and closer, shall have maneuvering space that
is the same width as door opening and extends 48 in (1220 mm).
minimum perpendicular to the doorway.
Diagram (b) Hinge Side Approaches. Hinge-side approaches

to pull side of swinging doors shall have maneuvering space that
extends 36 in (915 mm) minimum beyond the latch side of the
door if 60 in (1525 mm) minimum is provided perpendicular to the
doorway or maneuvering space that extends 42 in (1065 mm)
minimum beyond the latch side of the door shall be provided if 54
in (1370 mm) minimum is provided perpendicular to the doorway.
Hinge-side approaches to push side of swinging doors, not

equipped with both latch and closer, shall have a maneuveringspace of 54 in
(1370 mm) minimum, parallel to the doorway and
42 in (1065 mm) minimum, perpendicular to the doorway.
51-20-3106 (j) 3. Maneuvering Clearances at Doors. Except as

provided in Section 3106 (aa) (3106 (aa) is dwelling units), all
doors shall have minimum maneuvering clearances as follows:
A. Where a door must be pulled to be opened, an unobstructed

floor space shall extend at least 18 inches beyond the strike jamb.
B. Where a door must be pushed to be opened and is equipped

with a closer and a latch, an unobstructed floor space shall extend
at least 12 inches beyond the strike jamb.
[...
D. Where a door must be pulled to be opened, an unobstructed
floor space shall be provided that extends 60 inches, perpendicular
to the doorway.
E. Where a door must be pushed to be opened an unobstructed
floor space shall extend 48 inches perpendicular to the doorway.]
NE Provisions do not contain enough detail to ensure

access at doors. For example, ADAAG Fig. 25 requires
maneuvering clearances that range in size from 60 inches
by 52 inches to 48 inches by 32 inches, depending on
door swing, approach, etc. Although provisions in sections
51-20-3304 (i) and (j) compensate in some ways, the
provisions are still inadequate.
01-03868
Hinge side approaches to push side of swinging doors,
equipped with both latch and closer, shall have maneuvering space
of 54 in (1370 mm) minimum, parallel to the doorway, 48 in (1220
mm) minimum perpendicular to the doorway.
Diagram (c) Latch Side Approaches--Swinging Doors.

Latch-side approaches to pull side of swinging doors, with closers,
shall have maneuvering space that extends 24 in (610 mm)
minimum beyond the latch side of the door and 54 in (1370 mm)
minimum perpendicular to the doorway.
Latch-side approaches to pull side of swinging doors, not

equipped with closers, shall have maneuvering space that extends
24 in (610 mm) minimum beyond the latch side of the door and 48
in (1220 mm) minimum perpendicular to
EXCEPTION: Entry doors to acute care hospital bedrooms for

in-patients shall be exempted from the requirement for space at the
latch side of the door (see dimension "x" in Fig. 25) if the door is
at least 44 in (1120 mm) wide.
51-20-3304 (i) Floor Level at Doors. Regardless of the occupant

load, there shall be a floor or landing on each side of a door.
When access for persons with disabilities is required by Chapter
31, the floor or landing shall not be more than 1/2 inch lower than
the threshold of the doorway. When such access is not required,
such dimension shall not exceed 1 inch. Landings shall be level
except for exterior landings, which may have a slope not to exceed
1/4 inch per foot.
51-20-3304 (j) Landings at Doors. Landings shall have a width

not less than the width of the stairway or the width of the door,
whichever is the greater. Doors in the fully open position shall not
reduce a required dimension by more than 7 inches. when a
landing serves an occupant load of 50 or more, doors in any
position shall not reduce the landing dimension to less than one-
half its required width. Landings shall have a length measured in
the direction of travel of not less than 44 inches.
Comment: Issue 48. The provisions of Section 3106(j)3 were

amended in November 1992 to provide clear areas measured
perpendicular to the door. (See page 604e of the Published Code.)
In developing the Washington regulations, it was felt that the 11
different approach requirements were confusing and unnecessary.
Most doors are hinged swing doors. Few manually operated doors
are slide opening doors. With the 1992 amendments, we believe
that the maneuvering clearance standards are comparable.
The Washington Code simplifies the doors and maneuvering
clearances from the variety in ADA. This simplifies compliance
and enforcement and is more likely to result in accessible
construction of doorways. The ADA and ANSI standards are still
available as alternate designs which can be approved by the
building official.
NE See above.
[N.E. WAC fails to address hinge-side approaches and

latch-side approaches. WAC still does not address
sliding/folding doors.]
01-03869
3/23/94 letter from Washington State Building Code Council Issue

48 - In order to simplify the Washington regulations, the
maneuvering clearance requirements were condensed into three
basic requirements contained in Section 3106(j). These three are
the forward approach to a door where the door swings toward the
user, a forward approach to a door where the door swings away
from the user, and two doors in series. As stated in our response
of August 20, 1993, our regulations simplify compliance and
enforcement and is more likely to result in accessible construction
of doorways. We have recently issued a specific interpretation,
number 94-02, that allows the use of ANSI A117.1-1992 door
clearances as alternatives to the three standards in the code.
Maneuvering clearances at doors must be looked at in
conjunction with other requirements of the State Building Code
which are provided in Chapter 33 on Exiting (egress). The primary
provisions which will affect maneuvering clearances are the
requirements for minimum corridor widths (Sec. 3305). Most
corridors must be a minimum of 44 inches in width, unless the
occupant load is less than 49 persons. In addition, the code
prohibits doors in any position from reducing the width of a
corridor by more than half of the required width. We assume that
you understand that if a door is in the wall of a room, that
adequate maneuvering clearances will always be present unless
the door is in a corner. We have therefore focused our comparison
on where maneuvering clearances might be most restricted and
that is where a door is located on a corridor wall.
Figure 25 of the ADAAG illustrates 9 different maneuvering
clearances for doors. We have compared the effect of the
Washington State Code in comparison to the ADAAG diagrams
and provide the following analysis. It should be noted that the
footnote in Figure 25 states that doors in alcoves must comply
with clearances for a front approach. The ADAAG does not define
an alcove. The Washington Code presumes a forward approach in
all situations, in which case it is completely consistent with the
ADAAG.
01-03870
A. Front Approaches - Swinging Doors: The front approaches as

diagrammed in Figure 25(a) are reflected specifically in the
Washington language in Section 3106(j).
B. Hinge Side Approaches - Swinging Doors: Two basic

conditions are noted: 1. Doors swing into the approach. Please
refer to attached Diagram A. Under the Washington code this
would be treated as a forward approach door and the required
maneuvering clearance is shown in black. In this case ADA would
require additional clearance on the latch side of the door. If the
design of the building is such that this door was at the end of a
corridor, the additional clearance would be missing. If the corridor
continues, then only the crosshatched area labeled A would not be
provided. It should be noted that the maneuvering clearance
required for this door when approached in a forward approach is
deemed adequate with only 18 inches on the latch side, but if the
approach is from behind the door 18 inches is not sufficient, even
though a person would have to turn and essentially make a
forward approach to this door. While it appears that the
Washington code is not identical to the ADAAG, there is no loss in
maneuverability.
2. Doors swing away from approach: Two conditions are noted

in Figure 25(b), doors with, or without, closers. For doors without
both a closer and a latch, a smaller maneuvering clearance is
shown in ADAAG. See Diagram B. Again the Washington
regulations for this door are shown in black, the comparable
ADAAG design is shown in red. In this instance, the overall
maneuvering space required by the Washington Code is greater
than ADAAG. If the approaching corridor is only 36 inches in
width, a small area shown crosshatched (A) would not be present,
but the area labeled (B) would be present which is substantially
greater.
Where a door in this condition has both a closer and a latch, a

greater width is required. Again, as illustrated in Diagram C, the
potentially lost space (A) is more than compensated by the
Washington required maneuvering space (B).
[#B.1. N.E. ADA Standards require a space 60" by 72"

for a hinge side parallel approach. Washington only
requires 60" by 54". There is a loss of maneuverability
because the person does not make simply a front
approach, as Washington assumes, but rather, the person
has to continue beyond the door before attempting to
maneuver into a forward approach position. The cross-
hatched area is an essential part of the minimum
maneuvering space because it allows the person room to
move from the side of the door into the forward approach
position.
#B.2. N.E. For a hinge side parallel approach on the

push side of a door, the ADA Standards require a space
48" by 54". Also, the ADA requires the 54" dimension to
begin at the latch side of the door. The Washington
requirement overlaps the ADA requirement only partially
because it does not require the 54" dimension to begin at
the latch side. Therefore, Washington allows the
maneuvering space to be in a different place than the ADA
requires.
Washington assumes that the size of the maneuvering

space is all that matters. In fact, the size, the shape, and
the position of the maneuvering space all matter and
different sizes, shapes and positions are needed depending
on the direction of approach to the door.]
01-03871
C. Latch Side Approaches - Swinging Doors: 1. Doors swing into

approach: Two conditions are noted in the left hand portion of
Figure 25(c), doors with, or without, closers. For doors without a
closer a smaller maneuvering clearance is shown in ADAAG. See
Diagram D. Where the approaching corridor is only 36 or 44
inches wide, a minor portion of maneuvering space would not be
present as shown in the crosshatched area (A), however a
substantially greater area of maneuvering space is provided in the
area shown as (B).
Where the door has a closer, See Diagram E, the potentially

missing space (A) is slightly larger than noted in the preceding
case, but it is still compensated by a significant increase in
maneuvering space at (B).
2. Doors swing away from approach: Again two conditions are

noted depending on whether or not a closer is present. Where a
door does not have a closer, (See Diagram F) a small area of
ADAAG maneuvering clearance (A) would not be present where a
corridor is only 36 inches in width, which would be compensated
for by the additional area (B) which results from compliance with
the Washington requirements.
Where the door does have a closer a minor amount of space may
not be provided as shown by the crosshatched area A in Diagram
G.
D. Sliding Doors: 1. Forward approach. The maneuvering space

will be adequate in all cases since the minimum corridor widths of
36 or 44 inches are equal to or greater than the width of shown in
the ADAAG Figure 25(d). The depth will be provided, or else this
would not be a forward approach of someone traveling down a
corridor or across a room to this door.
2. Slide or latch side approaches. For doors located on a typical

corridor of 44 inches, the maneuvering space shown in ADAAG
Figures 25(e) and 25(f) will be present, or the corridor will not be
in compliance with other provisions of our code.
01-03872
4.13.7 Two Doors in Series. The minimum space between two

hinged or pivoted doors in series shall be 48 in (1220 mm) plus the
width of any door swinging into the space. Doors in series shall
swing either in the same direction or away from the space between
the doors (see Fig. 26).
4.13.8* Thresholds at Doorways. Thresholds at doorways shall

not exceed 3/4 in (19 mm) in height for exterior sliding doors or
1/2 in (13 mm) for other types of doors. Raised thresholds and
floor level changes at accessible doorways shall be beveled with a
slope no greater than 1:2 (see 4.5.2).
Interpretation No. 94-02. Question: Do the requirements for door

clearances as defined in this section apply to all approaches
including parallel, or are they applicable only to a forward
approach?
Answer: In order to simplify all potential options into a concise

format, the door standards were written for the most stringent
conditions with the reasoning that if doors always met these
standards full compliance would also be met.
Section 3101(d) allows the approval of alternate methods of
construction, design, or technologies provided that they supply
equivalent or greater accessibility. The CABO/ANSI A117.1-1992
Section 4.13 provides description and diagramming of suitable
alternate standards for all types of door operations. It was not the
intent of the code to prohibit the use of these alternatives.
51-20-3106 (j) 3.C. Where two doors are in a series, the

minimum distance between two hinged or pivoted doors shall be
48 inches in addition to any needed for door swing. [Doors in
series shall swing either in the same direction or away from the
space between the doors.]
Comment: Issue 49. Section 3106(j)3C was amended to add the

following sentence: "Doors in series shall swing either in the same
direction, or away from the space between the doors." (See page
604e of the Published Code.) With this addition the provisions are
equivalent to the ADAAG.
51-20-3106 (j) 4. Thresholds at Doors. Thresholds at doors shall

comply with Section 3106.

meeting the requirements of 3106 (h) [ a curb ramp meeting the
requirements of Section 3106(d)7, or an elevator or platform lift
meeting the requirements of Section 3105(d)]. For Type B
dwelling units, see also Section 3106(aa).
Comment: Issue 50. Section 3106(j)4 was amended to simplify

the reference to Section 3106. See page 604e of the Published
Code.
[N.E. Front approach is not the "most stringent." It is

only different from the requirements for the other
approaches.]
[Amendment: E.]
[Amendment: E.]
01-03873
4.15.3 Spout Location. The spouts of drinking fountains and

water coolers shall be at the front of the unit and shall direct the
water flow in a trajectory that is parallel or nearly parallel to the
front of the unit. The spout shall provide a flow of water at least 4
in (100 mm) high so as to allow the insertion of a cup or glass
under the flow of water. On an accessible drinking fountain with a
round or oval bowl, the spout must be positioned so the flow of
water is within 3 in (75 mm) of the front edge of the fountain.
51-20-3106 (m) 3. ...Spouts shall be located in the front of the

unit and shall direct a water flow not less than 4 inches in height,
in a trajectory parallel to the front of the unit. [Recessed units
shall be installed such that the spout is not recessed beyond the
plane of the wall.]
Comment: Issue 51: There is a typographical error in the side by

side analysis and the text in ADAAG and WSR regulations is the
same that the spout must be "at" the front of the unit. To clarify
the application to round or oval bowls, the Council has issued

Question: For water fountains with round or oval bowls, how far
back can the spout be located and still be considered "at the front"
of the unit?
Answer: The intent of the Code, as provided in Sec. 3101(a), is
to provide standards equivalent to the ADA Accessibility Guideline.
On round or oval bowls, the spout must be positioned so the flow
of water is within three (3) inches of the front edge of the
fountain.
[Amendment: E.]
[E.]
01-03874
4.15.5 Clearances.
(1) Wall- and post-mounted cantilevered units shall have a clear

knee space between the bottom of the apron and the floor or
ground at least 27 in (685 mm) high, 30 in (760 mm) wide, and 17
in to 19 in.
(430 mm to 485 mm) deep (see Fig. 27(a) and (b)). Such units
shall also have a minimum clear floor space 30 in by 48 in (760
mm by 1220 mm) to allow a person in a wheelchair to approach
the unit facing forward.
(2) Free-standing or built-in units not having a clear space under

them shall have a clear floor space at least 30 in by 48 in (760 mm
by 1220 mm) that allows a person in a wheelchair to make a
parallel approach to the unit (see Fig. 27(c) and (d)). This clear
floor space shall comply with 4.2.4.
51-20-3106 (m) Water Fountains. 1. Clear Floor Space. Wall-
and post-mounted cantilevered units shall have a minimum clear
floor space in front of the units 30 inches in width by 48 inches in
depth to allow a forward approach.
Free-standing or built-in units not having a clear space under them

shall have a clear floor space at least 30 inches in depth by 48
inches in width in order to allow a person in a wheelchair to make
a parallel approach to the unit.
2. Knee space. Wall- and post-mounted cantilevered units shall

have knee space in accordance with Section 3106(b) 2. B. The
knee space shall be not less than 19 inches in depth.
51-20-3106 (m) 5. Water Fountains in Alcoves. Where a unit is

installed in an alcove greater than 3 inches in depth, the alcove
shall be not less than 48 inches in width. A minimum 24 inches of
clear space shall be provided from the spout to the nearest side
wall of the alcove.
[Moved to
3106(m)3.]
Comment: Issue 52. This reference in Sec. 3106(m)2 was

corrected to a reference to Sec. 3106(b)4C. See page 604k of the
Published Code.
[P.E. but 3106(b)4C addresses when knee clearance can

be included in clear floor space. 3106(m) is addressing
what knee/toe clearance is required at water fountains.
The connection is not entirely clear but the specifications
are equivalent.]
01-03875
4.16.2 Clear Floor Space. Clear floor space for water closets not
in stalls shall comply with Fig. 28. Clear floor space may be
arranged to allow either a left-handed or right-handed approach.
Fig. 28 Clear Floor Space at Water Closets.
For a front transfer to the water closet, the minimum clear

floor space at the water closet is a minimum 48 inches (1220 mm)
in width by a minimum of 66 inches (1675 mm) in length. For a
diagonal transfer to the water closet, the minimum clear floor
space is a minimum of 48 inches (1220 mm) in width by a
minimum of 56 inches (1420 mm) in length. For a side transfer to
the water closet, the minimum clear floor space is a minimum of
60 inches (1525 mm) in width by a minimum of 56 inches (1420
mm) in length. (4.16.2, A4.22.3)
51-20-3106 (k) 5.A. Clear Floor Space. The lateral distance from
the center line of the water closet to the nearest obstruction
[excluding] grab bars, shall be 18 inches on
one side and [not less than 42] inches on the other side. In
other than stalls, a clear floor space not less than 32 inches
measured perpendicular to the wall on which the water closet is
mounted, shall be provided in front of the water closet.
EXCEPTION: A lavatory may be located within the clear floor

space required for a water closet provided that knee and toe
clearances for the lavatory comply with subsection 7 below and:
A. In Type B dwelling units the edge of the lavatory shall be
located not less than 15 inches from the centerline of the water
closet; or
B. In all other occupancies the edge of the lavatory shall be
located not less than 18 inches from the centerline of the water
closet.
Comment: Issue 53. Section 3106(k)3A provides the dimension

requirements for Wheelchair Accessible Toilet Stalls. This section
requires such stalls to be at least 60 inches in width. This
provision must also be complied with in addition to the clear floor
space requirements for the water closet which happens to be in
the toilet stall. Therefore if a lavatory were to be installed in the
clear floor space of a water closet in a toilet stall, the toilet stall
would not comply with the minimum width of 60 inches.
PNE A clarification is needed as to where the lavatory is

allowed to be in clear floor area. The ADA does not allow
a lavatory in the clear floor area in stalls.
[N.E. The stall would still be 60 inches wide, it would just

have a lavatory in it. That lavatory will inhibit a side
transfer to the water closet, even if there is knee space
under it. The problem raised has not been addressed. In
addition, 32" in front of the water closet will not make a
total of 66" depth of clear space, as required by ADA (it
will only be 61-62").]
01-03876
4.16.4* Grab Bars. Grab bars for water closets not located in
stalls shall comply with 4.26 and Fig. 29. The grab bar behind the
water closet shall be 36 in (915 mm) minimum.
Fig. 29(a) Back Wall. A 36 inch (915 mm) minimum

length grab bar is required behind the water closet mounted at a
height between 33 and 36 inches (840-915 mm). The grab bar
must extend a minimum of 12 inches (305) beyond the center of
the water closet toward the side wall and a minimum of 24 inches
(610 mm) toward the open side for either a left or right side
approach.
Fig. 29(b) Side Wall. A 42 inch (1065 mm) minimum

length grab bar is required to the side of the water closet spaced
12 inches (305 mm) maximum from the back wall and extending a
minimum of 54 inches (1370 mm) from the back wall at a height
between 33 and 36 inches (840-915 mm). The toilet paper
dispenser shall be mounted at a minimum height of 19 inches (485
mm). (4.16.3, 4.16.4, 4.16.6)
4.16.5* Flush Controls. Flush controls shall be hand operated or

automatic and shall comply with 4.27.4. Controls for flush valves
shall be mounted on the wide side of toilet areas no more than 44
in (1120 mm) above the floor.
4.16.6 Dispensers. Toilet paper dispensers shall be installed within

reach, as shown in Fig. 29(b). Dispensers that control delivery, or
that do not permit continuous paper flow, shall not be used.
Fig. 29(b)...The toilet paper dispenser shall be mounted at a

minimum height of 19 inches (485 mm). (4.16.3, 4.16.4, 4.16.6)
51-20-3106 (k) 5. C. Grab Bars. Grab bars shall be installed at

one side and the back of the water closet. The top of grab bars
shall be not less than 33 inches and not more than 36 inches
above and parallel to the floor. Grab bars located at the side shall
be a minimum 42 inches in length with the front end positioned
not less than 18 inches in front of the water closet.
Grab bars located at the back shall be a minimum of 36 inches in
length. Grab bars shall be mounted not more than 9 inches behind
the water closet seat. See also Section 3106(k)11.
51-20-3106 (k) 5. D. Flush Controls. Flush controls shall be

mounted for use from the wide side of the water closet area and
not more than 44 inches above the floor. [Flush valves shall
comply with Section 3106(c).]
51-20-3106 (k) 5. E. Dispensers and Receptacles. Toilet paper

and other dispensers or receptacles shall be installed within easy
reach of the water closet, and shall not interfere with
[unobstructed floor space] grab bar utilization.
Comment: Issue 54. While the WSR standards limit the location
of toilet paper dispenser, the actual design of those dispensers is
considered to be outside the scope of equipment regulated by the
building code. The WSR standards do prohibit placement of
dispensers so as to preclude interference with use of the grab
bars.
[Amendment: N.E. The requirements for placement of the
side grab bar are insufficient. WAC's requirement that the
front of the bar be 18" in front of the water closet would
make the bar extend only 48" from the back wall, whereas
ADA requires it to extend 54" from the back wall. This
extra extension is needed by people who need to reach
forward to pull to a standing position. Also, WAC does
not specify placement of the back grab bar in relation to
the side wall. The ADA's placement requirements ensure
that a diagonal transfer will be possible if needed.]
[Amendment: E.]
[E.]
01-03877
4.17.6 Grab Bars. Grab bars complying with the length and
positioning shown in Fig. 30(a), (b), (c), and (d) shall be provided.
Grab bars may be mounted with any desired method as long as
they have a gripping surface at the locations shown and do not
obstruct the required clear floor area. Grab bars shall comply with
4.26.
4.19.3 Clear Floor Space. A clear floor space 30 in by 48 in (760
mm by 1220 mm) complying with 4.2.4 shall be provided in front
of a lavatory to allow forward approach. Such clear floor space
shall adjoin or overlap an accessible route and shall extend a
maximum of 19 in (485 mm) underneath the lavatory (see Fig. 32).
Fig. 32 Clear Floor Space at Lavatories.
The minimum depth of the lavatory is 17 inches (430 mm).

(4.19.3, 4.24.5)
4.19.5 Faucets. Faucets shall comply with 4.27.4.

Lever-operated, push-type, and electronically controlled
mechanisms are examples of acceptable designs. If self-closing
valves are used the faucet shall remain open for at least 10
seconds.
4.20 Bathtubs.
4.20.1 General. Accessible bathtubs shall comply with 4.20.
51-20-3106 (k) 5. C. Grab Bars. Grab bars shall be installed at

one side and the back of the water closet. The top of grab bars
shall be not less than 33 inches and not more than 36 inches
above and parallel to the floor. Grab bars located at the side shall
be a minimum 42 inches in length with the front end positioned
not less than 18 inches in front of the water closet.
Grab bars located at the back shall be a minimum of 36 inches in
length. Grab bars shall be mounted not more than 9 inches behind
the water closet seat. See also Section 3106 (k) 11.
51-20-3106 (k) 7. A. Clear Floor Space. A clear floor space not

less than 30 inches (in width) by 48 inches (in depth) shall be
provided in front of lavatories and sinks. [The clear floor space
may include knee and toe clearances not to exceed 19 inches
extending under the lavatory or sink.]
51-20-3106(k) 7. E. Faucets. Faucet control handles shall be

located not more than 17 inches from the front edge of the
lavatory, sink or counter, and shall comply with Section 3105 (c).
Self-closing valves shall remain open for at least 10 seconds per
operation.
51-20-3106 (c) Controls and Hardware 1. Operation. Handles,

pulls, latches, locks and other operating devices on doors,
windows, cabinets, plumbing fixtures and storage facilities shall
have a lever or other shape which will permit operation by wrist or
arm pressure and does not require tight grasping, pinching or
twisting to operate. Doors shall comply with Section 3304.
[The force to activate controls on lavatories and water fountains
and flush valves on water closets and urinals shall not be greater
than 5 pounds.]
51-20-3106 (k) 9. Bathtubs.
[Amendment: See above.]
[Amendment: E.]
[Amendment: E.]
PNE See below.
01-03878
4.20.2 Floor Space. Clear floor space in front of bathtubs shall be

as shown in Fig. 33.
Fig. 33 Clear Floor Space at Bathtubs. (4.20.2, 4.20.3, 4.20.4)
Fig. 33(a) With Seat in Tub. If the approach is parallel to

the bathtub, a 30 inch (760mm) minimum width by 60 inch (1525
mm) minimum length clear space is required alongside the bathtub.
If the approach is perpendicular to the bathtub, a 48 inch (1220
mm) minimum width by 60 inch (1525 mm) minimum length clear
space is required.
Fig. 33(b) With Seat at Head of Tub. If the approach is

parallel to the bathtub, a 30 inch (760 mm) minimum width by 75
inch (1905 mm) minimum length clear space is required alongside
the bathtub. The seat width must be 15 inches (380 mm) and
must extend the full width of the bathtub.
51-20-3106 (k) 9. A. Clear Floor Space. A clear floor space not

less than 60 inches in length shall be provided along the tub.
Where the required seat is located at the end of the tub, the clear
floor space shall be not less than 75 inches in length. The clear
floor space shall be not less than 30 inches in width where access
to the space is parallel to the tub and not less than 48 inches in
width where access to the space is at right angles to the tub. A
lavatory which complies with Subsection 5, above, may be located
in the clear floor space of the tub.
PNE This appears to be generally equivalent in intent but

language must be more precise. As written, the lavatory
could be located anywhere within the clear floor area,
where as ADAAG only allows a complying lavatory at the
end of the tub where the controls are located.
01-03879
Comment: Issue 55. Section 3102 defines clear floor space as

unobstructed ground or floor space. Section 3106(b)4A requires a
minimum clear floor space of 30 by 48 inches. In addition, the
Washington regulations provide standards clarifying that which is
unobstructed floor space in Section 3106(b)3. This last provision
clarifies that a space can be clear and unobstructed even where
fixtures such as counters or lavatories project into the clear floor
space at minimum heights above the floor.
The provisions in Sections 3106(k)9A and (k)10B which allow
lavatory complying with Section 3106(k)7 to be located in the
clear floor space of an accessible bathtub or roll-in shower is
limited by the provisions of 3106(k)7 and those sections cited in
the preceding paragraph. If a lavatory was located in the clear floor
space of a tub or shower in such a way to eliminate the
unobstructed floor space, the net result would be that the required
floor space would not be provided. The combinations of provisions
forces the lavatory to the end of the clear floor space. Further if
the lavatory was positioned in a manner that obstructed access to
the grab bars and/or the controls, one purpose of the clear floor
space would again be defeated.
Finally, it should be noted again, that the lavatory allowed by the
Washington regulations must be an accessible lavatory, one which
provided knee and toe clearances. The ADAAG has no such limit
on the lavatory, and it could easily obstruct access to grab bars
and controls.
[N.E. The problem is that WAC allows the lavatory to be

at either end of the tub. The ADA requires it to be at the
foot end of the tub, because if it were at the head end of
the tub, it would obstruct transfer onto the seat.]
01-03880
4.20.5 Controls. Faucets and other controls complying with

4.27.4 shall be located as shown in Fig. 34.
Fig. 34 Grab Bars at Bathtubs. (4.20.3, 4.20.4, 4.20.5)
Fig. 34(a) With Seat in Tub. At the foot of the tub, the
grab bar shall be 24 inches (610 mm) minimum in length measured
from the outer edge of the tub. On the back wall, two grab bars
are required. The grab bars mounted on the back (long) wall shall
be a minimum 24 inches (610 mm) in length located 12 inches
(305 mm) maximum from the foot of the tub and 24 inches (610
mm) maximum from the head of the tub. One grab bar shall be
located 9 inches (230 mm) above the rim of the tub. The others
shall be 33 to 36 inches (840 mm to 910 mm) above the
bathroom floor. At the head of the tub, the grab bar shall be a
minimum of 12 inches (305 mm) in length measured from the
outer edge of the tub.
Fig. 34(b) With Seat at Head of Tub. At the foot of the

tub, the grab bar shall be a minimum of 24 inches (610 mm) in
length measured from the outer edge of the tub. On the back wall,
two grab bars are required. The grab bars mounted on the back
wall shall be a minimum of 48 inches (1220 mm) in length located
a maximum of 12 inches (305 mm) from the foot of the tub and a
maximum of 15 inches (380 mm) from the head of the tub.
Heights of grab bars are as described above.
Figure 34 Grab Bars at Bathtubs. (a) and (b) require controls to be

"offset," located in an area between the open edge and the
midpoint of the tub.
51-20-3106 (c) Controls and Hardware 1. Operation. Handles,

pulls, latches, locks and other operating devices on doors,
windows, cabinets, plumbing fixtures and storage facilities shall
have a lever or other shape which will permit operation by wrist or
arm pressure and does not require tight grasping, pinching or
twisting to operate. ...[The force to activate controls on
lavatories and water fountains and flush valves on water closets
and urinals shall not be greater than 5 pounds.]
51-20-3106 (k) 9. D. Controls and Fixtures. Faucets and other

controls shall be located above the tub rim and below the grab
bars, shall be not more than 24 inches laterally from the clear floor
space and shall comply with Section 3105 (c).
Comment: Issue 56. The intent of the WSR provisions was to

provide equivalent facilitation to that of the ADA. The allowed
distance is within the reach ranges specified in Sec. 4.2 of the
ADA. In addition, under the Washington Code, any lavatory
installed next to the controls must meet accessibility standards
and have knee and toe clearance underneath, these controls will
be reachable, whereas under ADAAG which does not require the
provision of knee and toe clearance, the controls will not be as
accessible as those provided in compliance with the Washington
Code.
NE ADA drawing requires controls to be offset between

the open edge of the tub and the centerline.
[N.E. The 24 inch measurement to the controls is not

equivalent. ADA requires the controls to be offset
between the midpoint of the tub and the outer edge of the
tub, so they can be reached from a wheelchair at the outer
edge of the tub. 24 inches is too far into the tub. The
midpoint of the tub is likely to be 15-16 inches from the
edge.]
01-03881
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.
Fig. 35 Shower Size and Clearances.
Fig. 35(a) 36 inches by 36 inches (915 mm by 915 mm)

Stall (Transfer Shower). The clear floor space shall be a minimum
of 48 inches (1220 mm) in length by a minimum of 36 inches (915
mm) in width and allow for a parallel approach. The clear floor
space shall extend 1 foot beyond the shower wall on which the
seat is mounted.
Fig. 35(b) 30 inches by 60 inches (760 mm by 1525 mm)

Stall (Roll-in Shower). The clear floor space alongside the shower
shall be a minimum of 60 inches (1220 mm) in length by a
minimum of 36 inches (915 mm) in width.
51-20-3106 (k) 10. A. Configuration. Shower stalls shall

have one of the following configurations.
(i) Transfer shower stalls shall be 36 inches by 36 inches,

nominal, and shall have a seat; or,
(ii) Roll-in shower stalls shall be not less than 30 inches in

depth by 60 inches in length.
51-20-3106 (k) 10 B. Clear Floor Space. A clear floor space

not less than 48 inches in length shall be provided adjacent to
shower stalls. For roll-in shower stalls, the clear floor space
shall be not less than (60) inches in [length]. [A
clear floor space shall not be less than 36 inches in width.] A
lavatory which complies with Subsection [7] above, may be
located in the clear floor space of a roll-in shower.
01-03882
4.21.3 Seat. A seat shall be provided in shower stalls 36 in by 36

in (915 mm by 915 mm) and shall be as shown in Fig. 36. The
seat shall be mounted 17 in to 19 in (430 mm to 485 mm) from the
bathroom floor and shall extend the full depth of the stall. In a 36
in by 36 in (915 mm by 915 mm) shower stall, the seat shall be on
the wall opposite the controls. Where a fixed seat is provided in a
30 in by 60 in minimum (760 mm by 1525 mm) shower stall, it
shall be a folding type and shall be mounted on the wall adjacent to
the controls as shown in Fig. 57. The structural strength of seats
and their attachments shall comply with 4.26.3.
Fig. 36 Shower Seat Design.

The diagram illustrates an L-shaped shower seat extending
the full depth of the stall. The seat shall be located 1-1/2 inches
(38 mm) maximum from the wall. The front of the seat (nearest to
the opening) shall extend a maximum 16 inches (330 mm) from the
wall. The back of the seat (against the back wall shall extend a
maximum of 23 inches (582 mm) from the side wall and shall be a
maximum of 15 inches (305 mm) deep.
Comment: Issue 57. The printing of Section 3106(k) 10B in

the side by side analysis is incomplete, thus the analysis is in
error. The complete section reads as follows: [see above].
See also comment on Issue No. 55, above.
51-20-3106 (k) 10 C. Seats. In transfer shower stalls, a seat

shall be mounted not less than 17 inches and not more than
19 inches above the floor, and shall extend the full depth of
the stall. The seat shall be located on the wall opposite the
controls and shall be mounted not more than 1-1/2 inches
from the shower walls. The seat shall be not more than 16
inches in width.
EXCEPTION: A section of the seat not more than 15 inches in

length and adjacent to the wall opposite the clear space, may
be not more than 23 inches in width.
In roll-in shower stalls, a fold down seat complying with the

dimensional requirements of this subsection, may be installed.
Comment: Issue 58. Clarification of seat and control location
in showers as regulated by the WSR in Sec. 3106(k)10 has
been clarified by Council Interpretation No. 93-36.
[N.E. For transfer shower, the clear floor space must be

configured so that it extends 12 inches beyond the seat wall.]
[N.E. WAC does not require that the seat be L-shaped. The
seat needs to be L-shaped so that people can sit in the corner
and use the two walls for support.]

01-03883
4.21.5 Controls. Faucets and other controls complying with 4.27.4

shall be located as shown in Fig. 37. In shower stalls 36 in by 36
in (915 mm by 915 mm), all controls, faucets, and the shower unit
shall be mounted on the side wall opposite the seat.
Fig. 37 Grab Bars at Shower Stalls.

Fig. 37(a) 36 inches by 36 inches (915 mm by 915 mm) Stall.
The diagram illustrates an L-shaped grab bar that is located along
the full depth of the control wall (opposite the seat) and halfway
along the back wall. The grab bar shall be mounted between 33 to
36 inches (840-915 mm) above the shower floor. The bottom of
the control area shall be a maximum of 38 inches (965 mm) high
and the top of the control area shall be a maximum of 48 inches
(1220 mm) high. The controls and spray unit shall be within 18
inches (455 mm) of the front of the shower.
Fig. 37(b) 30 inches by 60 inches (760 mm by 1525 mm) Stall.

The diagram illustrates a U-shaped grab bar that wraps around the
stall. The grab bar shall be between 33 to 36 inches (840-915
mm) high. The controls are placed in an area between 38 inches
and 48 inches (965 mm and 1220 mm) above the floor. If the
controls are located on the back (long) wall they shall be located 27
inches (685 mm) from the side wall. The shower head and control
area may be located on either side wall.

Question: Can the controls of a shower be located on any
wall of the enclosure of an accessible shower? What is the
relationship between the controls and the seat installed in a
shower?
Guideline.
In a transfer shower stall, the seat must be located along a
side wall. The controls must be located on the other side wall
opposite to the seat.
For a roll-in shower stall, the controls must be located on the
back, or long, wall opposite the clear floor area and located to
one side or the other of the midpoint of the wall. Where a
seat is installed in a roll-in shower, it must be located along
the end wall closest to the controls.
51-20-3106 (k) 10 E. Controls and Fixtures. Faucets and

other controls shall be located on the same wall as the shower
spray unit, and shall be installed not less than 38 inches or
more than 48 inches above the shower floor and shall comply
with Section 3106(c)...
NE Language should be more precise here to ensure that

controls are useable. ADAAG is very specific about location of
controls when placed on back wall and location of controls
adjacent to a fold down seat in a roll-in/transfer shower.
01-03884
4.22.6 Lavatories and Mirrors. If lavatories and mirrors are

provided, then at least one of each shall comply with 4.19.
Comment: Issue 59. Clarification of seat and control location

in showers as regulated by the WSR in Sec. 3106(k) 10 has
been clarified by Council Interpretation No. 93-36.

Question: Can the controls of a shower be located on any
wall of the enclosure of an accessible shower? What is the
relationship between the controls and the seat installed in a
shower?
Guideline.
In a transfer shower stall, the seat must be located along a
side wall. The controls must be located on the other side wall
opposite to the seat.
For a roll-in shower stall, the controls must be located on the
back, or long, wall opposite the clear floor area and located to
one side or the other of the midpoint of the wall. Where a
seat is installed in a roll-in shower, it must be located along
the end wall closest to the controls.
51-20-3105 (b) 3. Lavatories, Mirrors and Towel Fixtures. At

least one accessible lavatory shall be provided within any toilet
facility. Where mirrors, towel fixtures and other toilet and
bathroom accessories are provided, at least one of each shall
be accessible.
51-20-3106 (k) 7. Lavatories and Sinks. A. Clear Floor

Space. A clear floor space not less than 30 inches [in width]
by 48 inches [in depth] shall be provided in front of lavatories
and sinks [to allow a forward approach. The clear floor space
extending under the lavatory or sink].
51-20-3106 (k) 8. Mirrors, Dispensers and Other Fixtures.

Mirrors or shelves shall be installed so that the bottom of the
mirror or the top of the shelf is within 40 inches of the floor...
[N.E. This interpretation does not provide specifications for

placement of controls in relation to side wall/front of shower
(i.e. 18 in for transfer: 27 in for roll-in.) Merely offsetting
them may not put them close enough to the seat. This is a real
problem because the accessibility requirements provide only
minimum dimensions. If someone were to build a roll-in
shower with a back wall 84 inches long and simply offset the
controls at 40 inches from the seat wall, the controls would
not be reachable from the seat.]
[Amendment: E.]
01-03885
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.
4.24.5 Clear Floor Space. A clear floor space at least 30 in by 48

in (760 mm by 1220 mm) complying with 4.2.4 shall be provided in
front of a sink to allow forward approach. The clear floor space
shall be on an accessible route and shall extend a maximum of 19
in (485 mm) underneath the sink (see Fig. 32).
4.26.3 (5) Grab bars shall not rotate within their fittings.
51-20-3105 (b) 2. Toilet Facilities. ...In each toilet facility

in other occupancies, at least one wheelchair accessible toilet
stall with an accessible water closet shall be provided. In
addition, when there are 6 or more water closets within a
toilet facility, at least one other accessible toilet stall
complying with Section 3106 (k) 4. also shall be installed.
51-20-3106 (k) 3. Wheelchair Accessible Toilet Stalls. A.

Dimensions. Wheelchair accessible toilet stalls shall be at
least 60 inches in width. Where wall-hung water closets are
installed, the depth of the stall shall be not less than 56
inches. Where floor-mounted water closets are installed, the
depth of the stall shall be not less than 59 inches. Entry to
the compartment shall have a clear width of 32 inches. Toilet
stall doors shall not swing into the clear floor space required
for any fixture. Except for door swing, a clear unobstructed
access not less than 48 inches in width shall be provided to
toilet stalls.
EXCEPTION: [Moved to B]
[Partitions may
project not more than one inch, in the aggregate, into the
required width of the stall]
51-20-3106 (k) 4. Ambulatory Accessible Toilet Stalls.
ambulatory accessible toilet stalls shall be at least 36 inches in
width, with an outward swinging, self-closing door. Grab bars
shall be installed on each side of the toilet stall and shall
comply with Sections 3106 (k) 4. C. and 3106 (k) 9.
51-20-3106 (k) 7. Lavatories and Sinks. A. Clear Floor

Space. A clear floor space not less than 30 inches [in width]
by 48 inches [in depth] shall be provided in front of lavatories
and sinks [to allow a forward approach. The clear floor space
extending under the lavatory or sink].
Comment: Issue 60. In order for grab bars to meet the

loading requirement, rotation in the fittings is not feasible
because it is physically impossible for grab bars to rotate and
still meet the structural standards in Sec. 3106(k)11.
[Amendment: E.]
[Amendment: E.]
[E.]
01-03886
4.27.4 Operation. Controls and operating mechanisms shall be

operable with one hand and shall not require tight grasping,
pinching, or twisting of the wrist. The force required to activate
controls shall be no greater than 5 lbf (22.2 N).
4.28.2* Audible Alarms. If provided, audible emergency alarms

shall produce a sound that exceeds the prevailing equivalent sound
level in the room or space by at least 15 dbA or exceeds any
maximum sound level with a duration of 60 seconds by 5 dbA,
whichever is louder. Sound levels for alarm signals shall not exceed
120 dbA.
51-20-3106 (c) 1. Operation. Handles, pulls, latches, locks

and other operating devices on doors, windows, cabinets,
plumbing fixtures and storage facilities, shall have a lever or
other shape which will permit operation by wrist or arm
pressure and does not require tight grasping, pinching or
twisting to operate.
[The force to activate controls on lavatories and water
fountains and flush valves on water closets and urinals shall
not be greater than 5 pounds.]
51-20-3106 (o) Alarms. 1. Audible Alarms. Audible alarms

shall produce a sound in accordance with
[the Fire Code].
Appendix. Chapter 31 Division IV. 51-20-92118 (b) Audible

Alarms. Audible alarms shall exceed the prevailing equivalent
sound level in the room or space by at least 15 decibels, or
shall exceed any maximum sound level with a duration of 30
seconds by 5 decibels, whichever is louder. Sound levels for
alarm signals shall not exceed 120 decibels.
[Uniform Fire Code, Article 14, S 14.103(b). System Design.

Fire alarm systems, automatic fire detectors, emergency voice
alarm communication systems and notification devices shall be
designed, installed and maintained in accordance with U.F.C.
Standards Nos. 14-1 and 14-2 and other nationally recognized
standards.
U.F.C. Appendix S A-2-8-4. To ensure that audible evacuation
signals are clearly heard, it is recommended that their sound
level be at least 15 dBA above the equivalent sound level or 5
dBA above the maximum sound level having a duration of at
least 60 seconds (whichever is greater) measured 5 ft (1.5 m)
above the floor in the occupiable area.]
[Amendment: E:]
01-03887
Comment: Issue 61. The provision has been amended to

read: "Audible alarms shall produce a sound in accordance
with the Fire Code."
The Uniform Fire Code and the Uniform Fire Code Standards
are part of the adoption of the Washington State Building
Code. They are not appendix provisions which local
jurisdictions have an option to enforce. These regulations are
enforced on an equal basis with all other construction codes in
the state. The audible standards in the Fire Code are
equivalent to the ADA standards. Attached is a copy of the
adopting action which was taken concurrently with the
original adoption of WAC 51-20. The Fire Code was a
referenced document and part of the overall hearing process
for these regulations.
It should be noted that the Fire Code gives the Fire official
authority to regularly inspect buildings and if a system is not
meeting a performance standard, the official can require the
system to be changed. In this case if the building is occupied
by a use which is noisier than anticipated, or ambient sound
levels change over time, the fire official can have the sound
level of the audible alarms raised to be above the ambient
levels.
[The sound level provisions are only in an Appendix in the Fire

Code. They are merely a "recommendation" and, therefore,
unenforceable. However, these are "non-code" items and
such omissions are not covered by the certification
determination. 28 C.F.R. S 36.607(a)(1).]
01-03888
4.28.3* Visual Alarms. Visual alarm signal appliances shall be

integrated into the building or facility alarm system. If single station
audible alarms are provided then single station visual alarm signals
shall be provided. Visual alarm signals shall have the following
minimum photometric and location features:
(1) The lamp shall be a xenon strobe type or equivalent.

(2) The color shall be clear or nominal white (i.e., unfiltered or
clear filtered white light).
(3) The maximum pulse duration shall be two-tenths of one
second (0.2 sec) with a maximum duty cycle of 40 percent. The
pulse duration is defined as the time interval between initial and
final points of 10 percent of maximum signal.
(4) The intensity shall be a minimum of 75 candela.
(5) The flash rate shall be a minimum of 1 Hz and a maximum of
3 Hz.
(6) The appliance shall be placed 80 in (2030 mm) above the
highest floor level within the space or 6 in (152 mm) below the
ceiling, whichever is lower.
(7) In general, no place in any room or space required to have a
visual signal appliance shall be more than 50 ft (15 m) from the
signal (in the horizontal plane). In large rooms and spaces
exceeding 100 ft (30 m) across, without obstructions 6 ft (2 m)
above the finish floor, such as auditoriums, devices may be placed
around the perimeter, spaced a maximum 100 ft (30 m) apart, in
lieu of suspending appliances from the ceiling.
(8) No place in common corridors or hallways in which visual
alarm signalling appliances are required shall be more than 50 ft (15
m) from the signal.
51-20-3106(o) 2. Visible Alarms. Visible alarms shall be

located not less than 80 inches above floor level, or 6 inches
below the ceiling, whichever is lower, and at an interval of not
less than 50 feet horizontal, in rooms, corridors and hallways.
In rooms or spaces exceeding 100 feet in horizontal
dimension, with no obstructions exceeding 6 feet in height
above the finished floor, visible alarms may be placed around
the perimeter at intervals not to exceed 100 feet horizontally.
01-03889
4.28.4* Auxiliary-Alarms. Units and sleeping accommodations shall
have a visual alarm connected to the building emergency alarm
system or shall have a standard 110-volt electrical receptacle into
which such an alarm can be connected and a means by which a
signal from the building emergency alarm system can trigger such
an auxiliary alarm. When visual alarms are in place the signal shall
be visible in all areas of the unit or room. Instructions for use of the
auxiliary alarm or receptacle shall be provided.
[Visible alarm signals shall comply with the following criteria:

[A]. The lamp shall be a xenon strobe type [or equivalent].
[B]. The color shall be clear [or] unfiltered
white light.
[C]. The maximum pulse duration shall be two-tenths of one
second (0.2 sec) with a maximum duty cycle of 40 percent.
The pulse duration is defined as the time interval between
initial and final point of 10 percent of maximum signal.]
[D]. The intensity shall be a minimum of 75 candela
4[E]. The flash rate shall be a minimum of 1 Hz and a
maximum of 3 Hz.
Comment: Issue 62. The performance standards for visible

alarms have been moved from the appendix to the main body
of the code at Section 3106(o) as part of the amendments of
November 1992. See page 6041 of the Published Code.
51-20-3105 (d) 9. Alarms. [Where provided] Alarm systems

shall include both audible and visible alarms.
[Visible] alarm devices shall be located in all [assembly
areas;] common-use areas
including toilet rooms and bathing facilities[;] hallways, and
lobbies [; and hotel guest rooms as required by Section
3103(a)8C.
EXCEPTIONS: 1. Alarm systems in Group I, Division 1.1 and
1.2 Occupancies may be modified to suit standard health care
design practice 2. Visible alarms are not required in Group R,
Division 1 apartment buildings].
[Amendment: E.]
[Amendment: E.]
01-03890
4.29.3 Detectable Warnings on Doors To Hazardous Areas.
(Reserved).
4.29.5 Detectable Warnings at Hazardous Vehicular Areas. If a

walk crosses or adjoins vehicular way, and the walking surfaces
are not separated by curbs, railings, or other elements between the
pedestrian areas and vehicular areas, the boundary between the
areas shall be defined by a continuous detectable warning which is
36 in (915 mm) wide, complying with 4.29.2.
4.29.6 Detectable Warnings at Reflecting Pools. The edges of

reflecting pools shall be protected by railings, walls, curbs, or
detectable warnings complying with 4.29.2.
51-20-3106 (d) [8]. Vehicular Areas. Where an accessible

route of travel crosses or adjoins a vehicular way, and where
there are no curbs, railings or other elements [which separate
the pedestrian and vehicular areas, and which are] detectable
by a person who has severe vision impairment
the boundary between the
areas shall be defined by a continuous detectable warning not
less than 36 inches wide, complying with Section 3106 (
[o]).
Comment: Issue 63. The reference has been corrected to

3106(q) in the November 1992 amendments.
[Amendment: E.]
[Amendment: E.]
[Amendment: E. because ADA requirement has been

suspended until July 26, 1996.]
01-03891
4.30.4* Raised and Brailled Characters and Pictorial Symbol Signs
(Pictograms). Letters and numerals shall be raised 1/32 in, upper
case, sans serif or simple serif type and shall be accompanied with
Grade 2 Braille. Raised characters shall be at least 5/8 in (16 mm)
high, but no higher than 2 in (50 mm). Pictograms shall be
accompanied by the equivalent verbal description placed directly
below the pictogram. The border dimension of the pictogram shall
be 6 in (152 mm) minimum in height.
51-20-3106 (p) 5. Raised and Brailled Characters and Pictorial

Symbol Signs (Pictograms).
[Characters and symbols on tactile signs shall be raised at

least 1/32 inch. Raised characters and symbols shall be upper
case characters. Raised characters and symbols shall be
between 5/8 inch and 2 inches in height. Raised characters
shall be accompanied by Braille in accordance with this
section.
B. Braille. Braille shall be separated from the corresponding
raised characters or symbols. Braille shall be Grade 2.
C. Pictograms. Where provided, pictograms shall be
accompanied by the equivalent verbal description placed
directly below the pictogram. The border dimension of the
pictogram shall be not less than 6 inches in height.]
[Amendment: N.E. No longer requires simple typeface.]
01-03892
4.30.7* Symbols of Accessibility.
(1) Facilities and elements required to be identified as accessible

by 4.1 shall use the international symbol of accessibility. The
symbol shall be displayed as shown in Fig. 43(a) and (b).
Fig. 43 International Symbols.
Fig. 43(a) Proportions, International Symbol of Accessibility.

The diagram illustrates the International Symbol of Accessibility on
a grid background.
Fig. 43(b) Display Conditions, International Symbol of

Accessibility. The symbol contrast shall be light on dark, or dark on
light.
(2) Volume Control Telephones. Telephones required to have a

volume control by 4.1.3(17)(b) shall be identified by a sign
containing a depiction of a telephone handset with radiating sound
waves.
(3) Text Telephones. Text telephones required by 4.1.3(17)(c).

shall be identified by the international TDD symbol (Fig 43(c)). In
addition, if a facility has a public text telephone, directional signage
indicating the location of the nearest text telephone shall be placed
adjacent to all banks of telephones which do not contain a text
telephone. Such directional signage shall include the international
TDD symbol. If a facility has no banks of telephones, the
directional signage shall be provided at the entrance (e.g., in a
building directory).
(4) Assistive Listening Systems. In assembly areas where

permanently installed assistive listening systems are required by
4.1.3(19)(b) the availability of such systems shall be identified with
signage that includes the international symbol of access for hearing
loss (Fig 43(d)).
51-20-3103 (b) 4. Signs. A. International Symbol of Access.

1. International Symbol of Access. A. General. The
International Symbol of Access shall be as shown below.
(Note: picture of International Access Symbol.)[This is now
3106(p) 1 A]
51-20-3106 (p) 1. B. Text Telephones. Text Telephones
required by Section 3105 (d) 2. shall be identified by the
International Text Telephone symbol as shown below: (Note
International TDD Symbol pictured.)
51-20-3106 (p) 1. C. Assistive Listening Systems.

Permanently installed assistive listening systems that are
required by Section 3103 (a) 2. B. shall be identified by the
International Symbol of Access for Hearing Loss as shown
below: (Note: International Symbol of Access for Hearing
Loss pictured.)
51-20-3106 (p) 1. D. Volume Control Telephones.
Telephones required by Section 3105 (d) 2. to have volume
controls shall be identified by a handset with radiating sound
waves.
Comment: Issue 64. To clarify the application of the WSR,
the Council has issued Interpretation No. 93-37.
01-03893
4.31.3 Mounting Height. The highest operable part of the

telephone shall be within the reach ranges specified in 4.2.5 or
4.2.6.
4.31.7 Telephone Books. Telephone books, if provided, shall be

located in a position that complies with the reach ranges specified
in 4.2.5 and 4.2.6.
4.32.3 Knee Clearances. If seating for people in wheelchairs is

provided at tables or counters, knee spaces at least 27 in (685 mm)
high 30 in (760 mm) wide, and 19 in (485 mm) deep shall be
provided (see Fig. 45).

Question: If public telephones are provided in more than one
location in a building, or at a building and its site, and Sec.
3105(d)2 requires the provision of a text telephone (TDD), is
any signage required to indicate the location of the text
telephone?
Accessibility Guideline. Directional signage indicating the
location of the nearest text telephone shall be placed next to
all banks of public telephone which do not include a text
telephone. If there are no banks of telephones (i.e., only
single telephone), this directional signage must be posted at
the entrance.
51-20-3106 (n) 2. Height. The highest operable part of a

telephone shall be within the reach ranges specified in
Sections 3106 (b) 2.D. or 3106 (b) 2.E.
Comment: Issue 65. The references in Sec. 3106(n)2 have

been changed to Sec. 3106(b)4 in the November 1992
amendments. See page 604k of the Published Code.
Comment: Issue 66. Since telephone books are neither

building construction or equipment, their location is not
included in the Washington State Building Code.
51-20-3106 (s) 2. Knee Clearances. Knee space at tables,

counters, and sinks shall be provided in accordance with
Section 3106 (b) 2. B. No projection which might obstruct
the arm of a wheelchair may intrude into this clearance height,
within 24 inches horizontally from the table edge.
Comment: Issue 67. The reference has been changed to Sec.

3106(b)4C in the November 1992 amendments. See Section
3106(s)2 on page 604o of the Published Code.
[E. as interpreted.]
[Amendment: E.]
[Such omissions of non-code items are not covered by the

certification determination.]
[N.E. WAC fails to require 19 inch minimum depth. (Also,

3106(b)4C addresses when knee clearance can be treated as
part of clear space. It doesn't address knee clearance
requirements generally.)]
01-03894
4.33.3 Placement of Wheelchair Locations. Wheelchair areas shall

be an integral part of any fixed seating plan and shall be provided so
as to provide people with physical disabilities a choice of admission
prices and lines of sight comparable to those for members of the
general public. They shall adjoin an accessible route that also
serves as a means of egress in case of emergency. At least one
companion fixed seat shall be provided next to each wheelchair
seating area. When the seating capacity exceeds 300, wheelchair
spaces shall be provided in more than one location. Readily
removable seats may be installed in wheelchair spaces when the
spaces are not required to accommodate wheelchair users.
EXCEPTION: Accessible viewing positions may be clustered for
bleachers, balconies, and other areas having sight lines that require
slopes of greater than 5 percent. Equivalent accessible viewing
positions may be located on levels having accessible egress.
4.33.5 Access to Performing Areas. An accessible route shall

connect wheelchair seating locations with performing areas,
including stages, arena floors, dressing rooms, locker rooms, and
other spaces used by performers.
4.34 Automated Teller Machines.
4.34.1 General. Each automated teller machine required to be

accessible by 4.1.3 shall be on an accessible route and shall comply
with 4.34.
4.34.2 Clear Floor Space. The automated teller machine shall be

located so that clear floor space complying with 4.2.4 is provided
to allow a person using a wheelchair to make a forward approach, a
parallel approach or both, to the machine.
51-20-3106 (u) 1. A. Location. Wheelchair spaces shall be an

integral part of any fixed seating plan and shall be dispersed
throughout the seating area. Spaces shall adjoin an accessible
route of travel that also serves as a means of egress and shall
be located to provide lines of sight comparable to those for all
viewing areas.
EXCEPTION: Accessible viewing positions may be clustered

for bleachers, balconies, and other areas having sight lines
that require slopes of greater than 5 percent. Equivalent
accessible viewing positions may be located on levels having
accessible egress.
Comment: Issue 68. The intent of the WSR provision is for

wheelchair spaces to be "an integral part of any fixed seating
plan" and has to be adjacent to companion seating in order to
be considered integral.
Appendix 51-20-93120. See below.
Appendix 51-20-93120(c) Clearance and Reach Range. Free

standing or built-in units not having a clear floor space under
them shall comply with Sections 3106(c)2 and 3, and provide
for parallel approach and both a forward and side reach to the
unit allowing a person with a wheelchair to access the
controls.
PNE No specific provision for companion seating adjacent to

accessible wheelchair locations.
[N.E. It is not clear that "integral" means wheelchair seats

must have adjacent companion seats.]
[Still no scoping. However, as discussed above, the fact that

an item is not addressed in a submitted code means it is not
considered for purposes of certification.]
[E.]
01-03895
01-03896
4.34.3 Reach Ranges.
(1) Forward Approach Only. If only a forward approach is

possible, operable parts of all controls shall be placed within the
forward reach range specified in 4.2.5.
(2) Parallel Approach Only. If only a parallel approach is possible,

operable parts of controls shall be placed as follows:
(a) Reach Depth Not More Than 10 in (255 mm). Where the
reach depth to the operable parts of all controls as measured from
the vertical plane perpendicular to the edge of the unobstructed
clear floor space at the farthest protrusion of the automated teller
machine or surround is not more than 10 in (255 mm), the
maximum height above the finished floor or grade shall be 54 in
(1370 mm).
(b) Reach Depth More Than 10 in (255 mm). Where the reach
depth to the operable parts of any control as measured from thevertical plane
perpendicular to the edge of the unobstructed clear
floor space at the farthest protrusion of the automated teller
machine or surround is more than 10 in (255 mm), the maximum
height above the finished floor or grade shall be as follows:
Reach Depth Maximum Height

In Mm In Mm
10 255 54 1370
11 280 53 1/2 1360
12 305 53 1345
13 330 52 1/2 1335
14 355 51 1/2 1310
15 380 51 1295
16 405 50 1/2 1285
17 430 50 1270
18 455 49 1/2 1255
19 485 49 1245
20 510 48 1/2 1230
21 535 47 1/2 1205
22 560 47 1195
23 585 46 1/2 1180
24 610 46 1170
Appendix 51-20-93120(c) Clearance and Reach Range. Free

standing or built-in units not having a clear floor space under
them shall comply with Sections 3106(c)2 and 3, and provide
for parallel approach and both a forward and side reach to the
unit allowing a person with a wheelchair to access the
controls.
[WAC should adopt the new language.]

01-03897
4.34.3 (3) Forward and Parallel Approach. If both a forward and

parallel approach are possible, operable parts of controls shall be
placed within at least one of the reach ranges in paragraphs (1) or
(2) of this section.
(4) Bins. Where bins are provided for envelopes, waste paper, or
other purposes, at least one of each type provided shall comply
with the applicable reach ranges in paragraph (1), (2), or (3) of this
section.
EXCEPTION: Where a function can be performed in a substantially

equivalent manner by using an alternate control, only one of the
controls needed to perform that function is required to comply with
this section. If the controls are identified by tactile markings, such
markings shall be provided on both controls.
4.34.4 Controls. Controls for user activation shall comply with

4.27.4.
4.34.4 5 Equipment for Persons with Vision

Impairments. Instructions and all information for use shall be made
accessible to and independently usable by persons with vision
impairments.
5.3 Access Aisles. All accessible fixed tables shall be accessible by

means of an access aisle at least 36 in (915 mm) clear between
parallel edges of tables or between a wall and the table edges.
Appendix 51-20-93120(b) Controls. Controls for user

activation shall comply with Section 3106(c).
Appendix 51-20-93120(d) Equipment for Persons with Vision
Impairments. Instructions and all information for use shall be
made accessible to and independently usable by persons with
vision impairments.
51-20-3106(v) 1. Restaurants and Cafeterias. 1. Aisles.

Aisles to fixed tables required to be accessible shall comply
with 3106 (s).
51-20-3106 (t) Aisles. All aisles [required to be accessible].

including check out aisles, food service lines and aisles
between fixed tables, shall be not less than 36 inches in
width.
Comment: Issue 70. The reference has been changed to Sec.

3106(t) in the November 1992 amendments. See page 604o
of the Published Code (Sec. 3106(v)).
[See above.]
[See above.]
[Amendment: E.]
01-03898
5.5 Food Service Lines. Food service lines shall have a minimum
clear width of 36 in (915 mm), with a preferred clear width of 42 in
(1065 mm) to allow passage around a person using a wheelchair.
Tray slides shall be mounted no higher than 34 in (865 mm) above
the floor (see Fig. 53). If self-service shelves are provided, at least
50 percent of each type must be within reach ranges specified in
4.2.5 and 4.2.6.
51-20-3106 (v) 2. Food Service Lines A. Clear Floor Space.

Food service lines shall comply with Section 3106 (t) (3106 (t)
requires 36 inch aisle width).
51-20-3106 (v) 2. B. Height. Tray slides shall be mounted

not more than 34 inches in height above the floor.
51-20-3105 (d) 6. Storage.

[Facilities]. In other than Group R, Division 1 apartment
buildings, where fixed or built-in storage facilities such as
cabinets, shelves, closets and drawers are provided in
accessible spaces, at least one of each type provided shall
contain storage space complying with Section 3106 (r).
Comment: Issue 71. To clarify these provisions the Council

has issued Interpretations No. 93-38 and 93-42.

Question: How many shelves must be in reach ranges where
the code states "Not all self-service shelves and display units
need be located within reach ranges required by Sec.
3106(b)4?" In Sec. 3106(v)2D, is the reference to Sec.
3106(s) correct in establishing the location of shelves and
dispensing devices for tableware, dishware, food, beverages,
and condiments in restaurants and cafeterias?
Guidelines. Where self-service shelves are provided in
restaurants and cafeterias, at least 50 percent of each type
shall be within the reach ranges of Sec. 3106(b). The proper
reference in Section 3106(v)2D is to Sec. 3106(r).
NE ADAAG requires 50% of self service shelves in food

service lines to be accessible. WSR has no specific provision,
only a general provision (see 3105 (d) 6).
[N.E. The code says 1 has to be accessible. When an

interpretation contradicts the code, the code will be given
priority.]
[Amendment: The removal of the requirement that self-service
shelves be on an accessible route seems to be a problem. The
interpretation helps, but is not sufficient.]
01-03899
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).
Fig. 54 Tableware Areas.
The maximum height is 54 inches (1370 mm).

Question: Self-service shelving and display units in retail
occupancies are required to be located on an accessible route.
See also wording of 3106(r)2.
1. Does this mean each and every clothing rack at
Nordstroms or Target must be on an accessible route or just
the area where racks may be installed?
2. The Section is unclear as to how many of the shelves in
these self-service areas, must be within the reach ranges.
Answer: 1. Access is required between permanent fixtures or
furniture which are shown on the plans and to the area where
portable racks may be located.
2. Except in restaurant and cafeterias, the number of
shelves which are in reach ranges is not limited. Some must
be, but there is no set minimum percentage. For restaurants
and cafeterias, see interpretation No. 93-38.
51-20-3106 (v) 2. D. Tableware and Condiment Areas. Self-

service shelves and dispensing devices for tableware,
dishware, condiments, food and beverages shall be installed to
comply with Section 3106 (s).
Comment: Issue 72. The intent was to refer to Section

3106(r). To correct this reference the Council has issued

Question: How many shelves must be in reach ranges where
the code states "Not all self-service shelves and display units
need be located within reach ranges required by Sec.
3106(b)4?" In Sec. 3106(v)2D, is the reference to Sec.
3106(s) correct in establishing the location of shelves and
dispensing devices for tableware, dishware, food, beverages,
and condiments in restaurants and cafeterias?
Guidelines. Where self-service shelves are provided in
restaurants and cafeterias, at least 50 percent of each type
shall be within the reach ranges of Sec. 3106(b). The proper
reference in Section 3106(v)2D is to Sec. 3106(r).
PNE Clarification needed. 3106 (s) is not correct section.
[N.E. It is not sufficient to correct an error in the code by

issuing an interpretation.]
01-03900
5.8 Vending Machines and Other Equipment. Spaces for vending

machines and other equipment shall comply with 4.2 and shall be
located on an accessible route.
6. MEDICAL CARE FACILITIES.
6.1 General. Medical care facilities included in this section are

those in which people receive physical or medical treatment or care
and where persons may need assistance in responding to an
emergency and where the period of stay may exceed twenty-four
hours. In addition to the requirements of 4.1 through 4.35, medical
care facilities and buildings shall comply with 6.
(1) Hospitals - general purpose hospitals, psychiatric

facilities, detoxification facilities - At least 10 percent of patient
bedrooms and toilets, and all public use and common use areas are
required to be designed and constructed to be accessible.
(2) Hospitals and rehabilitation facilities that specialize in

treating conditions that affect mobility, or units within either that
specialize in treating conditions that affect mobility - All patient
bedrooms and toilets, and all public use and common use areas are
required to be designed and constructed to be accessible.
(3) Long term care facilities, nursing homes - At least 50

percent of patient bedrooms and toilets, and all public use and
common use areas are required to be designed and constructed to
be accessible.
Comment: Issue 73. ADAAG does not specifically regulate

the vending machines, only the spaces in which they are
located. The machines themselves and their location and
installation are viewed as beyond the scope of building code
regulation. Since the Washington code requires universal
accessibility in all spaces regardless of function, and does not
allow spaces to be inaccessible, the locations available for
vending machine installation are accessible on accessible
routes.
51-20-3103 (a) 6. Group I Occupancies. All Group I

Occupancies shall be accessible in all public use, common use
and employee use areas, and shall have accessible patient
rooms, cells and treatment or examination rooms as follows:
51-20-3103(a) 6. A. In Group I Division 1.1 hospitals which
specialize in treating conditions that affect mobility, all patient
rooms in each nursing unit, including associated toilet rooms
and bathrooms.
51-20-3103 (a) 6. B. In Group I, Division 1.1 hospitals which
do not specialize in treating conditions that affect mobility, at
least 1 in every 10 patient rooms in each nursing unit,
including associated toilet rooms and bathrooms.
51-20-3103 (a) 6. C. In Group I, Division 1.1 and Division 2
nursing homes and long-term care facilities, at least 1 in every
2 patient rooms, including associated toilet rooms and
bathrooms.
51-20-3103 (a) 6. D. In Group I, Division 3, mental health
Occupancies, at least 1 in every 10 patient rooms, including
associated toilet rooms and bathrooms.
Comment: Issue 74. Section 3103(a)6 has been amended to

add a new Section F which reads: "In Group I Occupancies,
all treatment and examination rooms shall be accessible." See
page 600 of the Published Code.
[Amendment: E.]
01-03901
7.4 Security Bollards. Any device used to prevent the removal of

shopping carts from store premises shall not prevent access or
egress to people in wheelchairs. An alternate entry that is equally
convenient to that provided for the ambulatory population is
acceptable.
8.5 Stacks. Minimum clear aisle width between stacks shall

comply with 4.3, with a minimum clear aisle width of 42 in (1065
mm) preferred where possible. Shelf height in stack areas is
unrestricted (see Fig. 56).
Comment: Issue 75. The Washington State Regulations did

not include specific regulation of security bollards because it
was believed that special attention was not necessary. Such
bollards are simply one item which could interfere with an
accessible route or accessible route of egress and would be
prohibited.
See 51-20-3106 (x) 3. Above.
Comment: Issue 76. Section 3106(y)3 was amended in

November 1992 to delete the word "reference" so that the
accessible aisle requirements apply to all stacks. See page
604q of the Published Code.
[E.]
[E.]
01-03902
9.1 Hotels, Motels, Inns, Boarding Houses, Dormitories, Resorts and

Other Similar Places of Transient Lodging.
9.1.1 General. All public use and common use areas are required to
be designed and constructed to comply with section 4 (Accessible
Elements and Spaces: Scope and Technical Requirements).
EXCEPTION: Sections 9.1 through 9.4 do not apply to an

establishment located within a building that contains not more than
five rooms for rent or hire and that is actually occupied by the
proprietor of such establishment as the residence of such
proprietor.
51-20-3103(a) 8. Group R. Occupancies. A. General. All
chapter. Public-and common use areas and facilities such as
B. Number of Dwelling Units. In all Group R, Division 1
apartment buildings the total number of Type A dwelling units
shall be as required by Table No. 31-B. All other dwelling
units shall be designed and constructed to the requirements
for Type B units as defined in this chapter.
EXCEPTIONS: 1. Group R Occupancies containing [no more

than] three dwelling units....
51-20-3103 (a)8.C. Hotels and Lodging Houses. In all
hotels and lodging houses, accessible guest rooms, including
associated bathing, shower and toilet facilities, shall be
provided in accordance with Table No. 31-C....
....In addition public-use and common-use areas of all hotels

and lodging houses shall be accessible.
EXCEPTION: Group R, Division 3 lodging houses that are
occupied by the owner or proprietor of the lodging house.
51-20-3103 (a) 8. E. Congregate Residences. In congregate

residences with multi-bed rooms or spaces, a percentage equal
to the minimum number of accessible rooms required by Table
No. 31-C shall be accessible in accordance with Section 3106
(z).
EXCEPTION: Congregate residences with 10 or fewer

occupants need not be accessible.
Comment: Issue 77. Congregate residences as intended by

the UBC definition have non transient residents. The
exemption in WSR has no effect on equivalency with the
ADA. See also Council Interpretation No. 93-39.

01-03903
condominium complexes be classified where some or all of the
units are rented to short term quests.
Guidelines.

reviewed on a case be case basis. While these uses are
more appropriate. Some may need to be classified either in an
I (Institutional) or B (Business) category. If services are
transient.


01-03904
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).
Fig. 57 Roll-in Shower with Folding Seat.

Diagram (a): Where a fixed seat is provided in a 30 inch
minimum by 60 inch (716 mm by 1220 mm) minimum shower stall,
the controls and spray unit on the back (long) wall shall be located
a maximum of 27 inches (685 mm) from the side wall where the
seat is attached. (4.21.2, 9.1.2)
Diagram (b): An alternate 36 inch minimum by 60 inch

(915 mm by 1220 mm) minimum shower stall is illustrated. The
width of the stall opening stall shall be a minimum of 36 inches
(915 mm) clear located on a long wall at the opposite end of the
shower from the controls. The shower seat shall be 24 inches (610
mm) minimum in length by 16 inches (330 mm) minimum in width
and may be rectangular in shape. The seat shall be located next to
the opening to the shower and adjacent to the end wall containing
the shower head and controls. (4.21.2, 9.1.2, A4.23.3)
Number of Rooms Accessible Rooms Rooms with Roll-in
Showers
1 to 25 1
26 to 50 2
51 to 75 3 1
76 to 100 4 1
101 to 150 5 2
151 to 200 6 2
201 to 300 7 3
301 to 400 8 4
401 to 500 9 4, plus one for each
additional 100 over 400
501 to 1000 2% of total
1001 and over 20 plus 1 for each
100 over 1000
51-20-3103 (a) 8:C. Hotels and Lodging Houses. In all

provided in accordance with Table No. 31-C...
...In addition public-use and common-use areas of all hotels

and lodging houses shall be accessible.
EXCEPTION: Group R, Division 3 lodging houses that are

occupied by the owner or proprietor of the lodging house.
Table No. 31-C-Number of

Accessible Rooms and Roll-in Showers
Total Number Minimum Required Rooms With

of Rooms1 Accessible Rooms1 Roll-in Showers
1 to 25 1
26 to 50 2
51 to 75 3 1
76 to 100 4 1
101 to 150 5 2
151 to 200 6 2
201 to 300 7 3
301 to 400 8 4
401 to 500 9 4, plus 1 for every
100 rooms or
fraction thereof,
over 400.
501 to 1000 2% of total
Over 1000 20 plus 1 for every 100
rooms or fraction
thereof, over 1000
1 For congregate residences the numbers in these columns shall

apply to beds rather than rooms.

01-03905
9.2 Requirements for Accessible Units, Sleeping Rooms and Suites.
9.2.1 General. Units, sleeping rooms, and suites required to be

accessible by 9.1 shall comply with 9.2.
Comment: Issue 78. The Council has issued Interpretation

No. 93-40 to clarify the requirements for the three accessible
rooms standards.

Question: The code seems to require three different types of
accessible rooms: an accessible room with roll-in type
showers: an accessible room with another type of bathing
facility; and rooms with features to assist persons with
hearing impairments. Must the three categories be satisfied
independently, or can the various requirements be combined in
the same room?
Guidelines. Each requirement for the three categories of
rooms must be complied with independently of the other
requirements. For example, in a 100 guest room motel, four
(4) rooms must be wheelchair accessible, one (1) more room
must be wheelchair accessible and provide a roll-in shower,
and four (4) more rooms must provide equipment for persons
with hearing impairments. In addition, the five wheelchair
accessible rooms must also provide the equipment for persons
with hearing impairments.
51-20-3106 (z) [H]otels and Congregate Residences. See

below.
Comment: Issue 79. The DOJ analysis contains a

typographical error in translating the provisions of WSR
Section 3106(z), the correct title is "Hotels and Congregate
Residences." See the comment on to Issue No. 19, above.
[E.]
[E.]
01-03906
9.2.2(6) Where provided as part of an accessible unit, sleeping

room, or suite, the following spaces shall be accessible and shall be
on an accessible route:
(a) the living area.

(b) the dining area.
(c) at least one sleeping area.
(d) patios, terraces, or balconies.
EXCEPTION: The requirements of 4.13.8 and 4.3.8 do

not apply where it is necessary to utilize a higher door threshold or
a change in level to protect the integrity of the unit from
wind/water damage. Where this exception results in patios,
terraces or balconies that are not at an accessible level, equivalent
facilitation shall be provided. (e.g., Equivalent facilitation at a hotel
patio or balcony might consist of providing raised decking or a ramp
to provide accessibility).
(e) at least one full bathroom (i.e., one with a water closet,
a lavatory, and a bathtub or shower).
(f) if only half baths are provided, at least one half bath.
(g) carports, garages or parking spaces.
51-20-3103 (a) 8. C. Hotels and Lodging Houses. In all

provided in accordance with Table No. 31-C. Where provided
in accessible guest rooms the following facilities shall be
accessible: dining areas; kitchens; kitchenettes, wet bars;
patios; balconies; terraces; or similar facilities.
EXCEPTION: Kitchens in Type B dwelling units need not

comply with Section 3106 (1) 1.
51-20-3106 (z) 2. Accessible Route of Travel. An accessible

route complying with Section 3103 (b) 2. shall connect all
accessible spaces and elements including telephones, patios,
terraces, balconies, carports, garages or parking spaces with
all accessible sleeping rooms.
Comment: Issue 80. See the comment on Issue No. 19,

above. Also, Section 3103(a)BA requires all public and
common use areas of a Group R occupancy to be accessible.
The definition of hotel contained in Section 409 of the UBC
should also be noted.
PNE Although carports, parking garages, or parking spaces

must be connected by an accessible route to the unit, it
doesn't specifically state they must be accessible.
Interpretation needed.
[E.]

01-03907
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 sleeping room or suite.
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.
Comment: Issue 81. Section 3107 states the parking

requirement. If the parking is provided in garages or carports
(a B-1 or B-3 or M-1 occupancy) then that occupancy must
also be accessible per section 3103(a). Like ADAAG, the
WSR do not require parking to be provided, but where
provided, it must be accessible according to Section 3107.
Sec. 3107(a)6 states that accessible parking must be the
closest to the accessible entrance and where there are
multiple accessible entrances, the accessible parking must be
distributed at the various entrances. As a result, if a hotel
design includes parking located at individual units, those units
which are required to be accessible will have to have
accessible entrances and the parking nearest those entrances
will need to be the location of accessible parking.
51-20-3106 (z) 3. Doors. Doors within all sleeping rooms,

suites or other covered units shall comply with Section 3106
(j).
Comment: Issue 83. The intent of the WSR regulations is to

apply to all the doors of the guest rooms - including entry to
the room - not just those "within" the room. To clarify the
application of the WSR the Council has issued Interpretation
No. 93-41.

Question: What doors are covered by this requirement
[Section 51-20-3106(z)3]?
Guideline. All doors which enter a guest room from common
corridors or spaces and doors within the guest room providing
access to other rooms in the guest room unit, or to adjacent
units, must meet the standards for accessible doors. This
requirement applies to all of the guest rooms in a hotel, not
just those which must meet other accessibility standards.
[N.E. S3103(a)7 requires accessibility of M-1 occupancies

only if they are "private garages and carports which contain
accessible parking serving Type A dwelling units." Accessible
hotel rooms are not Type A dwelling units. The ADA would
require a carport that was designated for an accessible hotel
room to be accessible. WAC would not.]
[E.]
[E.]
01-03908
9.5 Transient Lodging in Homeless Shelters, Halfway Houses,

Transient Group Homes, and Other Social Service Establishments.
9.5.1 New Construction. In new construction all public use and

common use areas are required to be designed and constructed to
comply with section 4. At least one of each type of amenity (such
as washers, dryers and similar equipment installed for the use of
occupants) in each common area shall be accessible and shall be
located on an accessible route to any accessible unit or sleeping
accommodation.
EXCEPTION: Where elevators are not provided as allowed in

4.1.3(5), accessible amenities are not required on inaccessible
floors as long as one of each type is provided in common areas on
accessible floors.
51-20-3108 (a) 8. Group Occupancies. A. General. All

chapter. Public- and common-use areas and facilities such as

(z).


01-03909
9.5.2 Alterations.
(1) Social service establishments which are not homeless
shelters:
(a) The provisions of 9.5.3 and 9.1.5 shall apply to

sleeping rooms and beds.
(b) Alteration of other areas shall be consistent with the

new construction provisions of 9.5.1.
(2) Homeless shelters. If the following elements are altered,

the following requirements apply:
(a) at least one public entrance shall allow a person with

mobility impairments to approach, enter and exit including a
minimum clear door width of 32 in (815 mm).
(b) sleeping space for homeless persons as provided in the

scoping provisions of 9.1.2 shall include doors to the sleeping area
with a minimum clear width of 32 in (815 mm) and maneuvering
space around the beds for persons with mobility impairments
complying with 9.2.2(1).
(c) at least one toilet room for each gender or one unisex
toilet room shall have a minimum clear door width of 32 in (815
mm), minimum turning space complying with 4.2.3, one water
closet complying with 4.16, one lavatory complying with 4.19 and
the door shall have a privacy latch; and, if provided, at least one tub
or shower shall comply with 4.20 or 4.21, respectively.
(d) at least one common area which a person with mobility

impairments can approach, enter and exit including a minimum clear
door width of 32 in (815 mm).
(e) at least one route connecting elements (a), (b), (c) and
(d) which a person with mobility impairments can use including
minimum clear width of 36 in (915 mm), passing space complying
with 4.3.4, turning space complying with 4.2.3 and changes in
levels complying with 4.3.8.
(f) homeless shelters can comply with the provisions of

(a)-(e) by providing the above elements on one accessible floor.
See comments above.

01-03910
condominium complexes be classified where some or all of the
units are rented to short term guests.
Guidelines.

reviewed on a case be case basis. While these uses are
more appropriate. Some may need to be classified either in an
I (Institutional) or B (Business) category. If services are
transient.

[E.]

01-03911
9.5.3. Accessible Sleeping Accommodations in New Construction.

Accessible sleeping rooms shall be provided in conformance with
the table in 9.1.2 and shall comply with 9.2 Accessible Units,
Sleeping Rooms and Suites (where the items are provided).
Additional sleeping rooms that comply with 9.3 Sleeping
Accommodations for Persons with Hearing Impairments shall be
provided in conformance with the table provided in 9.1.3.
In facilities with multi-bed rooms or spaces, a percentage of the

beds equal to the table provided in 9.1.2 shall comply with
9.2.2(1).
10. TRANSPORTATION FACILITIES.
10.1 General. Every station, bus stop, bus stop pad, terminal,
building or other transportation facility, shall comply with the
applicable provisions of 4.1 through 4.35, sections 5 through 9,
and the applicable provisions of this section. The exceptions for
elevators in 4.1.3(5) exception 1 and 4.1.6(1)(k) do not apply to a
terminal, depot, or other station used for specified public
transportation, or an airport passenger terminal, or facilities subject
to Title II.
51-20-3103 (a) 8. C. Hotels and Lodging Houses. In all

provided in accordance with Table No. 31-C. In addition,
sleeping rooms or suites for persons with hearing impairments
shall be provided in accordance with Table No. 31-D.
In addition, public-use and common-use areas of all hotels and
lodging houses shall be accessible.

(z).

[E. See Interpretation 93-39.]
[Washington does not address transportation facilities

separately.]

01-03912
10.2 Bus Stops and Terminals.

10.2.1 New Construction.
(1) Where new bus stop pads are constructed at bus stops, bays
or other areas where a lift or ramp is to be deployed, they shall
have a firm, stable surface; a minimum clear length of 96 inches
(measured from the curb or vehicle roadway edge) and a minimum
clear width of 60 inches (measured parallel to the vehicle roadway)
to the maximum extent allowed by legal or site constraints; and
shall be connected to streets, sidewalks or pedestrian paths by an
accessible route complying with 4.3 and 4.4. The slope of the pad
parallel to the roadway shall, to the extent practicable, be the same
as the roadway. For water drainage, a maximum slope of 1:50
(2%) perpendicular to the roadway is allowed.
(2) Where provided, new or replaced bus shelters shall be installed

or positioned so as to permit a wheelchair or mobility aid user to
enter from the public way and to reach a location, having a
minimum clear floor area of 30 inches by 48 inches, entirely within
the perimeter of the shelter. Such shelters shall be connected by an
accessible route to the boarding area provided under paragraph (1)
of this section.
(3) Where provided, all new bus route identification signs shall
comply with 4.30.5. In addition, to the maximum extent
practicable, all new bus route identification signs shall comply with
4.30.2 and 4.30.3. Signs that are sized to the maximum
dimensions permitted under legitimate local, state or federal
regulations or ordinances shall be considered in compliance with
4.30.2 and 4.30.3 for purposes of this section.
EXCEPTION: Bus schedules, timetables, or maps that are posted at

the bus stop or bus bay are not required to comply with this
provision.
(Not addressed.)

01-03913
10.2.2 Bus Stop Siting and Alterations.
(1) Bus stop sites shall be chosen such that, to the maximum
extent practicable, the areas where lifts or ramps are to be deployed
comply with section 10.2.1(1) and (2).
(2) When new bus route identification signs are installed or old
signs are replaced, they shall comply with the requirements of
10.2.1(3).
(Not addressed.)

01-03914
10.3 Fixed Facilities and Stations.
10.3.1 New Construction. New stations in rapid rail, light rail,

commuter rail, intercity bus, intercity rail, high speed rail, and other
fixed guideway systems (e.g., automated guideway transit,
monorails, etc.) shall comply with the following provisions, as
applicable.
(1) Elements such as ramps, elevators or other circulation devices,

fare vending or other ticketing areas, and fare collection areas shall
be placed to minimize the distance which wheelchair users and
other persons who cannot negotiate steps may have to travel
compared to the general public. The circulation path, including an
accessible entrance and an accessible route, for persons with
the circulation path for the general public. Where the circulation
path is different, signage complying with 4.30.1, 4.30.2, 4.30.3,
4.30.5, and 4.30.7(1) shall be provided to indicate direction to and
identify the accessible entrance and accessible route.
(2) In lieu of compliance with 4.1.3(8), at least one entrance to

each station shall comply with 4.14, Entrances. If different
entrances to a station serve different transportation fixed routes or
groups of fixed routes, at least one entrance serving each group or
route shall comply with 4.14, Entrances. All accessible entrance
shall, to the maximum extent practicable, coincide with those used
by the majority of the general public.
(3) Direct connections to commercial, retail, or residential facilities

shall have an accessible route complying with 4.3 from the point of
connection to boarding platforms and all transportation system
elements used by the public. Any elements provided to facilitate
future direct connections shall be on an accessible route connecting
boarding platforms and all transportation system elements used by
the public.
(4) Where signs are provided at entrances to stations identifying

the station or the entrance, or both, at least one sign at each
entrance shall comply with 4.30.4 and 4.30.6. Such signs shall be
placed in uniform locations at entrances within the transit to the
maximum extent practicable.
EXCEPTION: Where the station has no defined entrance, but

signage is provided, then the accessible signage shall be placed in a
central location.
51-20-3101 (a) General. Buildings or portions of buildings

shall be accessible to persons with disabilities as required by
this chapter.
51-20-3101 (a) 1. General. Accessibility to temporary or

permanent buildings or portions thereof shall be provided for
all occupancy classifications except as modified by this
chapter.
(P.E. to the extent transportation stations are buildings.

WAC does not address minimizing distance. WAC does not
address accessible entrances for different fixed routes. WAC
does not address accessible direct connections.)

01-03915
(5) Stations covered by this section shall have identification signs

complying with 4.30.1, 4.30.2, 4.30.3, and 4.30.5. Signs shall be
placed at frequent intervals and shall be clearly visible from within
the vehicle on both sides when not obstructed by another train.
When station identification signs are placed close to vehicle
windows (i.e., on the side opposite from boarding) each shall have
the top of the highest letter or symbol below the top of the vehicle
window and the bottom of the lowest letter or symbol above the
horizontal mid-line of the vehicle window.
(6) Lists of stations, routes, or destinations served by the station

and located on boarding areas, platforms, or mezzanines shall
comply with 4.30.1, 4.30.2, 4.30.3, and 4.30.5. A minimum of
one sign identifying the specific station and complying with 4.30.4
and 4.30.6 shall be provided on each platform or boarding area. All
signs referenced in this paragraph shall, to the maximum extent
practicable, be placed in uniform locations within the transit
system.
(7)* Automatic fare vending, collection and adjustment (e.g., add-
fare) systems shall comply with 4.34.2, 4.34.3, 4.34.4, and
4.34.5. At each accessible entrance such devices shall be located
on an accessible route. If self-service fare collection devices are
provided for the use of the general public, at least one accessible
device for entering, and at least one for exiting, unless one device
serves both functions, shall be provided at each accessible point of
entry or exit. Accessible fare collection devices shall have a
minimum clear opening width of 32 inches; shall permit passage of
a wheelchair; and, where provided, coin or card slots and controls
necessary for operation shall comply with 4.27. Gates which must
be pushed open by wheelchair or mobility aid users shall have a
smooth continuous surface extending from 2 inches above the floor
to 27 inches above the floor and shall comply with 4.13. Where
the circulation path does not coincide with that used by the general
public, accessible fare collection systems shall be located at or
adjacent to the accessible point of entry or exit.
(8) Platform edges bordering a drop-off and not protected by

platform screens or guard rails shall have a detectable warning.
Such detectable warnings shall comply with 4.29.2 and shall be 24
inches wide running the full length of the platform drop-off.

01-03916
(9) In stations covered by this section, rail-to-platform height in

new stations shall be coordinated with the floor height of new
vehicles so that the vertical difference, measured when the vehicle
is at rest, is within plus or minus 5/8 inch under normal passenger
load conditions. For rapid rail, light rail, commuter rail, high speed
rail, and intercity rail systems in new stations, the horizontal gap,
measured when the new vehicle is at rest, shall be no greater than
3 inches. For slow moving automated guideway "people mover"
transit systems, the horizontal gap in new stations shall be no
greater than 1 inch.
EXCEPTION 1: Existing vehicles operating in new stations may

have a vertical difference with respect to the new platform within
plus or minus 1-1/2 inches.
EXCEPTION 2: In light rail, commuter rail and intercity rail

systems where it is not operationally or structurally feasible to meet
the horizontal gap or vertical difference requirements, mini-high
platforms, car-borne or platform-mounted lifts, ramps or bridge
plates, or similar manually deployed devices, meeting the applicable
requirements of 36 C.F.R. part 1192, or 49 C.F.R. part 38 shall
suffice.
(10) Stations shall not be designed or constructed so as to require

persons with disabilities to board or alight from a vehicle at a
location other than one used by the general public.
(11) Illumination levels in the areas where signage is located shall

be uniform and shall minimize glare on signs. Lighting along
circulation routes shall be of a type and configuration to provide
uniform illumination.
[Not addressed.]

01-03917
(12) Text Telephones: The following shall be provided in

accordance with 4.31.9:
(a) If an interior public pay telephone is provided in a transit

facility (as defined by the Department of Transportation) at least
one interior public text telephone shall be provided in the station.
(b) Where four or more public pay telephones serve a
particular entrance to a rail station and at least one is in an interior
location, at least one interior public text telephone shall be provided
to serve that entrance. Compliance with this section constitutes
compliance with section 4.1.3(17)(c).
(13) Where it is necessary to cross tracks to reach boarding

platforms, the route surface shall be level and flush with the rail top
at the outer edge and between rails, except for a maximum 2-1/2
inch gap on the inner edge of each rail to permit passage of wheel
flanges. Such crossings shall comply with 4.29.5. Where gap
reduction is not practicable, an above-grade or below-grade
accessible route shall be provided.
(14) Where public address systems are provided to convey

information to the public in terminals, stations, or other fixed
facilities, a means of conveying the same or equivalent information
to persons with hearing loss or who are deaf shall be provided.
(15) Where clocks are provided for use by the general public, the
clock face shall be uncluttered so that its elements are clearly
visible. Hands, numerals, and/or digits shall contrast with the
background either light-on-dark or dark-on-light. Where clocks are
mounted overhead, numerals and/or digits shall comply with
4.30.3. Clocks shall be placed in uniform locations throughout the
facility and system to the maximum extent practicable.
(16) Where provided in below grade stations, escalators shall have

a minimum clear width of 32 inches. At the top and bottom of
each escalator run, at least two contiguous treads shall be level
beyond the comb plate before the risers begin to form. All
escalator treads shall be marked by a strip of clearly contrasting
color, 2 inches in width, placed parallel to and on the nose of each
step. The strip shall be of a material that is at least as slip resistant
as the remainder of the tread. The edge of the tread shall be
apparent from both ascending and descending directions.
51-20-3105 (d) 2. Telephones. ...Where four or more

public telephones are provided at a building site, and at least
one is in an interior location, at least one interior telephone
shall be a text telephone in accordance with Section 3106 (n).
Where interior public pay phones are provided in transportation
facilities ... at least one interior text telephone shall be
provided.
[E.]
[Not addressed.]
[Not addressed.]
[Not addressed.]
[Not addressed.]

01-03918
(17) Where provided, elevators shall be glazed or have transparent

panels to allow an unobstructed view both in to and out of the car.
Elevators shall comply with 4.10.
EXCEPTION: Elevator cars with a clear floor area in which a 60

inch diameter circle can be inscribed may be substituted for the
minimum car dimensions of 4.10, Fig. 22.
(18) Where provided, ticketing areas shall permit persons with
disabilities to obtain a ticket and check baggage and shall comply
with 7.2.
(19) Where provided, baggage check-in and retrieval systems shall

be on an accessible route complying with 4.3, and shall have space
immediately adjacent complying with 4.2. If unattended security
barriers are provided, at least one gate shall comply with 4.13.
Gates which must be pushed open by wheelchair or mobility aid
users shall have a smooth continuous surface extending from 2
inches above the floor to 27 inches above the floor.
10.3.2 Existing Facilities: Key Stations.

Not reproduced because key stations are covered by title II of the
ADA only and, therefore, section 10.3.2 is inapplicable to title III
entities.
10.3.3 Existing Facilities: Alterations.
(1) For the purpose of complying with 4.1.6(2) Alterations to an

Area Containing a Primary Function, an area of primary function
shall be as defined by applicable provisions of 49 C.F.R. 37.43(c)
(Department of Transportation's ADA Rule) or 28 C.F.R. 36.403
(Department of Justice's ADA Rule).
51-20-3105 (d) 7. C. Counters and Windows. Where

customer sales and service counters or windows are provided,
a portion of the counter, or at least one window, shall be
accessible in accordance with Section 3106 (x) 2.
[Not addressed.]
[P.E.]
[Not addressed.]
[See above discussion of path of travel at Standard 4.1.6 (2).]

01-03919
10.4 Airports.
10.4.1 New Construction.

(1) Elements such as ramps, elevators or other vertical circulation
devices, ticketing areas, security checkpoints, or passenger waiting
areas shall be placed to minimize the distance which wheelchair
users and other persons who cannot negotiate steps may have to
travel compared to the general public.
(2) The circulation path, including an accessible entrance and an

accessible route, for persons with disabilities shall, to the maximum
extent practicable, coincide with the circulation path for the general
public. Where the circulation path is different, directional signage
complying with 4.30.1, 4.30.2, 4.30.3 and 4.30.5 shall be
provided which indicates the location of the nearest accessible
entrance and its accessible route.
(3) Ticketing areas shall permit persons with disabilities to obtain a

ticket and check baggage and shall comply with 7.2.
(4) Where public pay telephones are provided, and at least one is
at an interior location, a public text telephone shall be provided in
compliance with 4.31.9. Additionally, if four or more public pay
telephones are located in any of the following locations, at least one
public text telephone shall also be provided in that location:
(a) a main terminal outside the security areas;
(b) a concourse within the security areas; or
(c) a baggage claim area in a terminal.
Compliance with this section constitutes compliance with section
4.1.3(17)(c).
(5) Baggage check-in and retrieval systems shall be on an

accessible route complying with 4.3, and shall have space
immediately adjacent complying with 4.2.4. If unattended security
barriers are provided, at least one gate shall comply with 4.13.
Gates which must be pushed open by wheelchair or mobility aid
users shall have a smooth continuous surface extending from 2
inches above the floor to 27 inches above the floor.
51-20-3103 (a) 1. General. Accessibility to temporary or
permanent buildings or portions thereof shall be provided for
all occupancy classifications except as modified by this
chapter.
51-20-3105 (d) 7. C. Counter and Windows. Where

customer sales and service counters or windows are provided
a portion of the counter or at least one window, shall be
accessible in accordance with Section 3106 (x) 2.
51-20-3105 (d) 2. Telephones. ...Where four or more
public telephones are provided at a building site, and at least
one is in an interior location, at least one interior telephone
shall be a text telephone in accordance with Section 3106 (h).
Where interior public pay phones are provided in
transportation facilities ... at least one interior text
telephones shall be provided.
[Washington does not specifically address airports.]
[P.E. if airports are considered buildings.]
[Does not address minimizing distance.]
[P.E.]
[E.]
[Not addressed.]

01-03920
(6) Terminal information systems which broadcast information to

the general public through a public address system shall provide a
means to provide the same or equivalent information to persons
with a hearing loss or who are deaf. Such methods may include,
but are not limited to, visual paging systems using video monitors
and computer technology. For persons with certain types of
hearing loss such methods may include, but are not limited to, an
assistive listening system complying with 4.33.7.
(7) Where clocks are provided for use by the general public the
clock face shall be uncluttered so that its elements are clearly
visible. Hands, numerals, and/or digits shall contrast with their
background either light-on-dark or dark-on-light. Where clocks are
mounted overhead, numerals and/or digits shall comply with
4.30.3. Clocks shall be placed in uniform locations throughout the
facility to the maximum extent practicable.
(8) Security Systems. (Reserved).
10.5 Boat and Ferry Docks.
(Reserved).
[Not addressed.]
[Not addressed.]

01-03921

US Department of Justice Civil Rights Division - Letter - Tal529

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US Department of Justice Civil Rights Division - Letter - Tal529

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JUL 22 1994

Mr. Gene Colin

Dear Mr. Colin:

Thank you for your supplemental submissions of August 20,

We are still awaiting written confirmation from your staff

Our analysis of the material you have submitted is discussed

cc: Records; Chrono; Wodatch; Blizard; Hill; FOIA

Based on this analysis, we have determined that in only a

The remaining areas of nonequivalency are discussed below

A number of items that do not necessarily pose obstacles to

1) A number of items that are addressed by the ADA

2) The certification determination will be limited to the

interpretations should be made public and published together with

3) The certification determination will not apply to

4) The WSR relies on building classifications that differ

5) The Appendix to the WSR contains the "U.S.

6) The WSR does not address transportation facilities.

The following issues need to be corrected before a

1) Maneuvering clearances at doors (Standard 4.13.6, p.

2) Grab bars (Standard 4.16.4, p. 86). The WSR does not

3) Food service shelves (Standard 5.5, p. 108). The WSR

4) Tableware and condiment areas (Standard 5.6, p. 109).

a) Shower seats (Standard 4.21.3, p. 92). The WSR

b) Shower controls (Standard 4.21.5, p. 93). The WSR

d) Clear floor space (Standard 4.21.2, p. 91). The

6) Parking at medical care facilities (Standard 4.1.2(5),

The WSR requires provision of 10% accessible spaces at

7) Elevator exception (Standard 4.1.3(5), p. 28; see also

8) Alterations. Because the WSR requires all routes in

a) Protruding objects (Standard 4.1.2(3), p. 25;

b) Self-service shelves (Standard 5.5, p. 108). The

9) Unisex toilet rooms (Standard 4.1.6(3)(e), p. 48). The

10) Companion seating (Standard 4.33.3, p. 104). The WSR

a) Water closets (Standard 4.16.2, p. 85). The WSR

b) Bathtubs (Standard 4.20.2, p. 88). The WSR fails

12) Diagonal curb ramps (Standard 4.7.10, p. 63). The ADA

13) Tactile signage (Standard 4.30.4, p. 101). The WSR

14) Knee clearance at tables (Standard 4.32.3, p. 103).

15) Transient lodging (Standard 9.2.2(6), p. 116). The WSR

We understand from your letter of March 23, 1994, that the

Our offices have worked diligently together over a long

cc: Mr. Lawrence W. Roffee

1. Purpose. This document sets guidelines for accessibility to

The technical specifications 4.2 through 4.35 of these guidelines

The illustrations and text of ANSI A117.1 are reproduced with

Washington State Regulations

51-20-002 Purpose. The purpose of these rules is to

Strike through = material deleted since prior DOJ review

ADA/Washington State July 12, 1994

Pursuant to RCW 19.27.040, Chapter 31 and requirements

In case of conflict with other provisions of this code, chapter

51-20-3101 Scope. (a) General. Buildings or portions of

Reference is made to appendix Chapter 31 for FFHA and ADA

(b) Design. The design and construction of accessible

51-20-3102 Person with Disability is an individual who has

2 ADA/Washington State July 12, 1994

Comment: Issue 1. It is acknowledged that the purpose of

The Washington Barrier-free facilities regulations are only

The Washington regulations were written to incorporate the

[E. Section 3102 does seem to include all disabilities that

3 ADA/Washington State July 12, 1994

Assembly Area. A room or space accommodating a group of

Chapter 4 Definitions and Abbreviations Section 402.