What do you mean?                             May 2008

There are several areas in the Texas Accessibility Standards that are open to interpretation.  These are very frustrating especially when we interpret it one way, and the inspector might interpret things differently.  In this month's newsletter I will try to make clear a few vague concepts in the code:

Permanent Signage


According to TAS 4.1.3(16) Building signage which designates "permanent" rooms and spaces shall comply with Section 4.30 (meaning that they are required to have accessibility symbols and Braille under names or pictograms). 


But they never define the word "permanent".


A room is considered permanent if it is designated by a Room name, Room number or both.  If the room is designated by a person's name, then it is not considered permanent.

wall signage

In This Issue
Permanent Signage
Common Use Spaces
Places of Religious Rituals
Inspector's corner
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Common Use Spaces

TAS states in several places that certain elements must be accessible if they are found in "common use" spaces.  For example, visual alarms must be placed in common use spaces, sinks in common use spaces must have a knee space, common use toilet facilities must be accessible, etc.

The definition of "common use" according to TAS 3.5.21 states

"Refers to those interior and exterior rooms, spaces, or elements that are made available for the use of a restricted group of people (for example, occupant of a homeless shelter, the occupants of an office building, or the guests of such occupants)"


This definition is not too clear and it leaves the words open to interpretation.  Aren't all spaces essentially "made available"? 

TDLR interprets this to mean that any space that is used by more than one person is "common use".  A private office and janitor's closets,  for example, is not considered "common" since they assume that only one person will be using the space (i.e. only one Janitor is in charge of the room and in essence it is his private office).  But a storage closet and break room are common spaces because more than one person can access them.

        break room 
Places of Religious Rituals

TDLR's administrative rule 68.30(8) exempted places used primarily for religious rituals.  The exemption does not list examples of the spaces, and they leave it up to the Owner to designate the spaces as such.  Some examples that I've encountered are restrooms and dressing rooms associated with a Baptismal pool or a Jewish ritual immersion pool.  Another example would be a washing station for a mosque or synagogue where washing their hands is part of the ritual of prayer.  And if the church has a Sunday school, and the classrooms are only used for religious education, then those would also be exempted.

But the exemption also states that "common use" areas are not part of the exemption.  So parking, public restrooms, offices, eating areas etc. in a religious organization will have to comply.

Something else that the rule does not tell you is that if you put a chair lift inside an exempted space (i.e. a chair lift to the stage in a sanctuary), you must file for a variance.  This is because a chair lift is regulated not only by TDLR's Architectural Barriers Department, but TDLR's Elevator Department.  



Baptismal pool
Inspector's Corner

We are so used to a typical lavatory detail where you follow the exact lines of  Fig. 31: the 8" straight horizontal at the 29" vertical clearance at the knee space, the angled panel to cover the pipes, the 6" of toe clearance.  But I inspected a project with an accessible lavatory that was unique in its shape, but still met all the requirements.  This is an example of an accessible design that does not have to be an eye sore.

Fig. 31Mezzo Lav

If you have any questions on these or any other topics relating to accessibilty, feel free to contact me anytime.
Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714