This article provides a history of the updating process for the ADA Accessibility Guidelines, the status of the revision process, and a summary of some of the major differences between the plumbing provisions in the current guidelines and the proposed revisions.

Issue: 3/03

The ADA Accessibility Guidelines (ADAAG) have not been updated since they were initially published by the U.S. Architectural and Transportation Barriers Compliance Board (Access Board) in 1990. The technical provisions of the current ADAAG are based on the 1980 edition of ANSI A117.1, which is now 23 years old. The long overdue updating of ADAAG is finally nearing completion. This article provides a brief history of the updating process that is ongoing, the status of the Access Board's rulemaking process to revise the guidelines, and a summary of some of the major differences between the plumbing provisions in the current guidelines and the proposed revisions for the new ADAAG.

Rulemaking Background

The Access Board began the process to update the ADAAG in 1994. An advisory committee was created by the board to conduct a complete review of the ADAAG and recommend changes. The ADAAG Review Advisory Committee consisted of 22 members, representing the design and construction industry, the building code community, state and local governments entities, and people with disabilities. The committee was charged with reviewing the ADAAG in its entirety and making recommendations for updating it so that it remains consistent with technological developments, changes in model codes and national standards, and continues to meet the needs of people with disabilities. The committee developed a comprehensive set of recommendations that addresses substantive changes to ADAAG scoping provisions and technical requirements, as well as its format and numbering system.

Next Steps

The Access Board's rulemaking process has not been completed at the time of this writing. The Access Board must next submit the final guidelines to the Office of Management and Budget (OMB) for review and clearance. The OMB requires that a regulatory assessment be submitted along with the final guidelines. The regulatory assessment, which includes a comprehensive analysis of the cost impact of the new guidelines, is still being prepared. Once completed and submitted, OMB has 90 days for its review. Once cleared by OMB, the guidelines will be published in final form. While it cannot be stated with absolute certainty, the final rule is expected to be published in late spring of 2003.

It also bears mentioning that other federal agencies responsible for the standards used to enforce the ADA, such as the U.S. Department of Justice (DOJ), must then similarly modify their standards so that they are consistent with the updated guidelines. Until then, the current guidelines remain in effect. The DOJ has not given any indication of its plans or timeframe for adoption of the new guidelines.

Differences Between the Current ADAAG and the New ADAAG

The Access Board approved the content of the final rule to revise the ADAAG in September of 2002. In the federal rulemaking process, the content of a rule cannot be disclosed to the public until the final rule is published. A draft of the final rule was "placed in the docket" by the Access Board in April 2002. This was a procedural maneuver that enabled the content of the draft final rule to be made available for consideration in the development process for the 2003 edition of the ICC International Building Code and the 2003 edition of ANSI A117.1. Consequently, this article can only discuss the content of the draft final rule. There are some differences between the draft final rule and the final rule that was approved but not yet published. While the content of the final rule cannot be disclosed here, the differences, if any, between the draft final rule and the published final rule in the plumbing provisions are not expected to be substantive.


The format and numbering system for the new ADAAG have been completely revised. There are three key differences. First, the scoping provisions (where required, how many are required) have been separated from the technical provisions (how to make an element accessible). Scoping provisions for new construction in the current ADAAG may appear to all be located in Section 4.1.3, but in fact, there is scoping scattered throughout the current guidelines. The new format should greatly improve the ease of use and application of the guidelines. The scoping provisions in the new ADAAG are all contained in Chapter 2. Plumbing-related scoping is addressed in Sections 211 through 214.

Second, the format of the technical provisions very closely matches the arrangement and numbering of ANSI A117.1. This will make it much easier to compare and understand any differences between the ADAAG and the 1998 and 2003 editions of ANSI A117.1. The technical provisions for plumbing are all contained in Chapter 6. The section numbers referred to in the following discussion of differences between the current and proposed ADAAG are those of the draft final rule.

Third, the current guidelines in many cases refer to figures for specific requirements. The new ADAAG will continue to include figures, but they are only provided for informational purposes to illustrate specific requirements. All requirements are spelled out in the text of the guidelines (104.3). One need no longer refer to figures to determine what is required by the guidelines. In fact, while care was taken to ensure that the figures do not show anything that is not stated in the text, if there is any question as to what is required, one must now refer to the text and not the figures to determine the requirements.

Reach Ranges

A significant change that can affect the design and arrangement of toilet and bathing rooms occurs in reach ranges. The height for an unobstructed high side reach has been reduced from 54 inches to 48 inches maximum (308.3.1). This change was adopted in response to data provided by the Little People of America and is intended to improve access for people of short stature. This change may affect the customary location of many controls, operation mechanisms and elements such as waste receptacles, coat hooks, dispensers, hand dryers, storage shelves and other such elements in toilet and bathing rooms.

Children's Facilities

The draft final rule includes the various scoping and technical provisions for children's facilities that were developed and adopted by the Access Board in a separate rulemaking process (102). The provisions for children's facilities typically appear as exceptions to the general requirements that would otherwise be based on adult anthropometrics, although water closet requirements and toilet compartment requirements for children's facilities are contained in their own dedicated subsection (604.9).

Drinking Fountains

The scoping provisions for drinking fountains have been editorially and substantially revised in several ways for clarity (211). Reference to water coolers has been removed, primarily because the guidelines do not cover elements that are not fixed or plumbed. The current guidelines are interpreted to apply to drinking fountains provided on a site as well as on a floor of a building, but lacks specificity with regard to exterior locations. The draft final rule explicitly states applicability to drinking fountains that are provided on a site and within a building (211.1).

The draft final rule no longer makes reference to "hi-lo" drinking fountains but clearly states that no fewer than two drinking fountains are to be provided (211.2). Fifty percent of the total number of drinking fountains provided must be wheelchair accessible, and 50% must accommodate people who have difficulty bending or stooping. An exception specifically allows a single unit that provides both types of access in lieu of a multiple fixture installation. When the 50% rule results in an odd number of fixtures, the draft final rule allows the resulting number to be rounded up or down.

Wheelchair accessible drinking fountains must now provide knee and toe clearance for a forward approach (602.2). A parallel (side) approach is no longer permitted for free standing and built-in units. Side approach will be allowed at certain drinking fountains for children's use.

The details for water flow height and location are spelled out in more detail and no longer refer to being able insert a cup under the water flow (602.6).

The minimum height above the floor for drinking fountains for standing persons has been lowered from 39 inches to 38 inches (602.7). The maximum height of 43 inches is unchanged.

Water Closets

The draft final rule changes the distance from the sidewall or partition to the centerline of the water closet from an absolute dimension of 18 inches to a range of 16-18 inches (604.2). This should resolve what has been a difficult enforcement issue that has heretofore been based on the non-uniform interpretation of unstated allowable tolerances for water closet installation.

Figure 28 of the current ADAAG infers that a lavatory is allowed to project into the clear floor space for a toilet, but the text is not specific either way. The draft final rule is now specific as to which elements, such as grab bars, dispensers and the like, are allowed to project into the clear floor space. Lavatories are not included in the list and are therefore not allowed to project into the required clear floor space at a water closet (604.3.2).


On the subject of tolerances, the draft final rule will no longer allow tolerances for dimensions that are stated as a specific minimum and maximum range (104.1.1). For example, the water closet location discussed above is stated as a specific range of 16-18 inches from the sidewall. Because a specific range of dimensions provides more flexibility than an absolute dimension, designers and installers will be expected to strategically detail construction plans and specifications, and provide an installation that falls within the specified range. There will be no tolerance allowed outside the specified range.


The revision process for the guidelines revealed significant disagreement over the need for accessible urinals. Anecdotal evidence suggests that most wheelchair users will not use a urinal, opting for the privacy of a toilet compartment. This raised the question as to whether the requirement for accessible urinals is justified. Comments received by the Access Board indicated that there are some wheelchair users who use urinals, prompting the board to continue to require accessible urinals, but only where two or more urinals are provided (213.3.3).

Current guidelines require flush controls for urinals to be mounted 44 inches maximum above the floor. The draft final rule provides somewhat more flexibility by requiring controls to be within any of the allowable general reach range dimensions without specifying a particular dimension (605.4).

Current guidelines require an accessible urinal to have an elongated rim but do not provide any guidance as to what constitutes an acceptable elongation. The draft final rule replaces that statement with a specific minimum dimension of 13 1/2 inches measured from the outer face of the rim to the back of the fixture.

Grab Bars

Current guidelines only allow grab bar diameters of 1 1/4 inches to 1 1/2 inches. The draft final rule increases the maximum grab bar diameter to 2 inches and also provides more guidance on criteria for acceptable dimensions of non-circular grab bar shapes (609.2).

Clustered Toilet Rooms

Current guidelines require all toilet rooms to be accessible. In occupancies such as clinics and doctors' offices, several single-user toilet rooms may be provided and clustered at a single location for procedures such as collecting specimens or other similar purposes. In that situation, requiring all clustered toilet rooms to be accessible is not necessary. The draft final rule will require 50% of clustered toilet rooms to be accessible (213.2, exception 4). This provision received a lot of attention during the ADAAG revision process because the initial proposed rule to revise the guidelines set the scoping at 5% to be consistent with other scoping provisions, such as that for clustered portable toilet facilities. Many commenters felt that the reduction from 100% to 5% was too drastic, and the Access Board resolved the issue by compromising at 50%.

Unisex Toilet Rooms

The current guidelines do not address unisex toilet facilities in new construction. The draft final rule has provisions for unisex toilet rooms (213.2.1 and 603). However, the International Building Code establishes where and when unisex toilet facilities are required. The 2000 and 2003 editions of the IBC require unisex toilet facilities in assembly and mercantile occupancies that are required by the plumbing code to have an aggregate of six or more water closets in male and female toilet rooms. The draft final rule will defer to the IBC for scoping of unisex toilet facilities.

Toilet Room Door Swing

Current guidelines indicate that the room door cannot swing into the clear floor space required at any fixture but are silent with respect to the turning space that is required within the room. The draft final rule will continue to prohibit the door swing into the clear space at fixtures but specifically allows the door to swing into the required turning space (603.2.3).

Lavatories in Toilet Compartments

Current guidelines are silent on whether lavatories may be located in a toilet compartment. This is an arrangement that has previously been allowed in some parts of the country. The draft final rule specifically prohibits the required accessible lavatory from being located in a toilet compartment (213.3.4). Note that throughout the new guidelines (and ANSI A117.1), the term "compartment" is used in place of "stalls." The late Pat Higgins is credited with this new editorial paradigm, having consistently reminded us that stalls are for horses.

Roll-in Shower Compartments

Current guidelines prohibit curbs at roll-in shower compartments. The draft final rule allows a maximum 1/2-inch beveled threshold (608.7). A new exception will allow up to a 2-inch curb for transfer showers in existing facilities where compliance with the 1/2-inch maximum requirement would necessitate altering the structural reinforcement of a floor slab. This should make the installation of transfer-type showers in existing hotels more feasible, which, in turn, would make more types of bathing facilities available to people with disabilities who might need or prefer that option.

Kitchens, Kitchenettes, Wet Bars and Sinks

Current guidelines only address kitchens, kitchenettes and wet bars in the section on transient lodging. There is a technical section on sinks, but it is unclear as to when accessible sinks are required and how many are required to be accessible. The draft final rule clearly scopes kitchens and kitchenettes wherever they are provided, whether in transient lodging, an office building or any other occupancy (212.1.1). Five percent of sinks must be accessible where sinks are provided in a room or space that is required to be accessible (212.1.2). Mop sinks and service sinks are exempt. With kitchenettes and sinks adequately scoped, reference to "wet bars" is no longer needed and has been removed completely.


This article does not address all the differences between the current and new ADAAG, but rather is intended to highlight the major changes. Once the Access Board's final rule is published, interested parties are encouraged to review the new guidelines to familiarize themselves not only with the new format and substantive revisions, but also with the various other editorial improvements and clarifications that have been made. Overall, the new guidelines will be substantially more consistent with the new editions of the International Building Code and ANSI A117.1, which should make everyone's lives that much easier.