Is Your University ADA Compliant
Postsecondary experiences offer people throughout the United States some of the best years of their lives. Meeting new friends, finding new interests, and most importantly obtaining an education that will empower them to start a career and meet life goals. It can also be an extremely intimidating time for some. Many leaving the comforts of home and family behind, learning to live on their own in a new city, or often times a new state. It is important for colleges and universities to make incoming freshmen feel as comfortable as possible and arming them with the right tools to strive in their postsecondary education experience.
Students with disabilities have particular challenges, no matter how minor. The civil rights laws that cover the postsecondary educational participation of students with disabilities help to ensure that their experiences are aligned with their peers and are presented in section 504 of the Rehabilitation Act and the Americans with Disabilities Act. With ADA complaints rising steadily every year, it is extremely important for colleges to arm themselves with a team to focus on the requirements of Section 504 of the Rehabilitation Act of 1973 and Title II of the Americans with Disabilities Act to ensure all their students have equal access to educational programs and related activities, and to reasonable accommodations. A solid plan to ensure your college or university is ADA complaint should include providing site access, accessible paths to buildings, accessible entrances to buildings, and accessibility to all programs and services.
Program accessibility is generally the most difficult part of the plan to implement and should be addressed first. The definition of program areas may include lecture halls, classrooms, laboratories, and studios. The Americans with Disabilities Act requires that flooring accessible to disabled persons be slip resistant, not just when the building is constructed, but throughout its lifetime. It is important to note that commenters recommended that the Department apply an ASTM Standard (with modifications) to assess whether a floor surface is “slip resistant” as required by section 302.1 of the 2010 Standards. The Department declines to accept this recommendation since, currently, there is no generally accepted test method for the slip resistance of all walking surfaces under all conditions. However, a good guideline to go off of is a standard walkway is required by Occupational Safety and Health Administration (OSHA) to have CoF 0.5. As determined by Architectural and Transportation Barriers and the Compliance Board (Access Board), persons with disabilities require a higher CoF. The Access Board recommends that a CoF of 0.6 be used for accessible pathways and CoF of 0.8 be used on ramps.
The CoF should apply to these areas:
- interior and exterior accessible routes, including walking surfaces, ramps, elevators, and lifts
- stairways that are part of a means of egress
- required clearances, including clear floor space, wheelchair seating spaces, turning space, and door maneuvering clearances
- accessible parking spaces, access aisles, and accessible passenger loading zones
Implementing a non-slip tape or slip resistant adhesive to these walking surfaces, adding wheelchair ramps that also have proper grip tape and railings, and reviewing the architecture and mechanical infrastructure should help to ensure your university is on its way to ADA compliance. In facilities with toilets or showers, proper handrails and handicap signs should be put into place, along with slip resistant adhesives to ensure your university ADA compliance. Program accessibility requirements also apply to facilities that are leased by the institution. These can include, but is not limited to: private recreational centers, gyms, performance halls, and outdoor park and picnic areas. In some instances, an institution may find it’s easier and less costly to relocate a program to a different facility rather than retrofit the existing one with proper non-slip adhesive, railings, ramps, etc.
Support service areas are the second part of a postsecondary education ADA compliance checklist. These areas include common use toilets, dining rooms, locker rooms, computer rooms, and lounges. Slip resistance in these areas is especially important due to their high traffic and commonly wet conditions, which can make them especially dangerous for those in wheelchairs, on crutches, or with other limited mobility. Even if carpet is in place, it is important to note that it shall be securely attached, have a firm cushion, pad, or backing or no cushion or pad, and not be of a high pile to prevent slips and falling in disabled people according to section 302.2. Stairs throughout the campus are advised to have non-slip stair treads and secured railings, while all wheelchair ramps are recommended to have a 1:12 slope, railings, and a slip resistant adhesive to prevent falls in those walking or slipping of wheels in wet conditions. The ADA Guideline Standards also states that, “all accessible surfaces must be slip resistant to minimize hazards to people with disabilities, especially those who are ambulatory or semi-ambulatory or who use canes, crutches, and other walking aids. Standard practices for minimizing floor or ground slipperiness will likely satisfy compliance with the standards as slip resistance is important not just for accessibility but for general safety as well.” This can include utilizing a non-slip tape, stair treads, or adhesive coating to prevent falls in the disabled. Cobblestones or bricked areas can be especially tricky to comply to this requirement, so often times a university will offer an alternate route that is smoothly paved and easily accessible for wheelchairs and those with walking aids that might get stuck within the stones. The law also states that such accessible features are consistently maintained, so those elements such as wheelchair ramps, non-slip tape, stair treads, and handicap signage will always be at the disposal of anyone who might benefit from their use. Your university or college is obligated by the ADA to provide such reasonable accommodations to help all students participate fully and discrimination against individuals with disabilities.
Residential housing is not under the ADA Accessibility Guidelines because dormitories are defined as transient lodging. However, they are covered under the Fair Housing Amendments Act (FHAA) which states that any building with four or more units must include certain features of accessible and adaptable design. With most universities and colleges having a range of residential buildings on campus, it is worth the additional investigation to determine the jurisdiction of each one before implementing accessibility modifications. It is a violation of the Fair Housing Act for any person to refuse to make a reasonable accommodation in rules, policies, practices, or services, when such accommodations may be necessary to afford a handicapped person equal opportunity to use and enjoy a dwelling unit, including public and common use areas. Some facilities may require accessible roll-in showers, which should have a shower adhesive or bathtub non-slip tape, along with grab bars. Another example would be if a disabled student has trouble walking and needs a closer parking space or the addition of stair safety products or anti-slip tape and railings throughout the common areas. Other requirements may include having a more usable kitchen and accessible routes throughout the unit, including the addition of wheelchair ramps, stair treads, or grab bars to prevent falls in disabled tenants.
By assembling a team within your college or university to be responsible for adhering to the ADA, you will be able to take proactive measures to improve your facilities for disabled students, alert the public of accessible facilities and routes, and address concerns and complaints in a timely manner regarding your university or colleges alignment with the American Disabilities Act. Once the programs and public services are accessible, a complete plan should address the other requirements of the Accessibility Guidelines. By understanding and complying to the ADA, Universities will improve the overall access for students, visitors, and employees. With 2,563,000 students reporting disabilities enrolled in the 2011 to 2012 postsecondary academic year, which accounted for 11.1% of all undergraduates enrolled nationwide, it is extremely important to provide proper support and services for this growing group of students. Also noteworthy, some state accessibility codes are stricter than the federal code and you may also have additional requirements if you are working with a college owned by faith-based organizations. With all postsecondary schools so vastly different from secondary school, it is invaluable to support the students in their efforts to take on more responsibility. It is important to remember as you review your university or college ADA compliance, that the purpose of the ADA is “to provide clear, strong, consistent, enforceable standards addressing discrimination against individuals with disabilities.” The purpose of the slip resistance requirement is to make accessible routes more usable and safer for individuals with disabilities using the routes under normal conditions. That means this requirement does not take into account all of the various conditions that could cause a fall, however it will undoubtedly help prevent slips and falls for other reasons.