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ADA Requirements for Floor/Ground Surfaces - Technical

There are specific Americans with Disabilities Act (ADA) requirements for floor and ground surfaces. This article will present the technical requirements for ADA compliance of floor and ground surfaces. The 2010 ADA Standards that apply most to floor and ground surfaces are 302 and 303.

Wheelchair Individual on Accessible Surface

2010 ADA Standard 302.1, [Floor and Ground Surfaces] General, states, “Floor and ground surfaces shall be stable, firm, and slip resistant and shall comply with [Standard] 302.” The graphic on the right is representative where an individual using a wheel chair is maneuvering across a concrete surface. Note that grass is not considered stable, form, or slip resistant. The terms stable, firm and slip resistant are explained in the following Advisory.

Advisory 302.1, General, states, “A stable surface is one that remains unchanged by contaminants or applied force, so that when the contaminant or force is removed, the surface returns to its original condition. A firm surface resists deformation by either indentations or particles moving on its surface. A slip-resistant surface provides sufficient frictional counterforce to the forces exerted in walking to permit safe ambulation [walking].”

Slip Hazard Warning Sign

Note that the term slip-resistant is subjective because an acceptable level of slipperiness, such as a coefficient of friction, has not been defined within the 2010 ADA Standards. Standard practices for minimizing slipperiness often suffice, such as floor mats at the pedestrian entry/exit doors and where liquids are provided, such as at drinking fountains, drink dispensers, and sinks. Failure to take steps to minimize slippery conditions where these conditions are common could result in liability issues. The photo on the right is representative of a Slip Hazard warning sign.

Surfaces that are loose such as gravel, stone and grass surfaces do not comply as stable, firm and slip resistant. Gravel and stone surfaces would need to be compacted heavily and held in place by consolidants to comply. Gravel, stone and grass surfaces would require frequent inspections and maintenance to comply with the ADA Standards. The graphic below is representative of a gravel walking surface.

Loose Gravel Walking Surface

Surfaces with excessive or frequent changes in level are not addressed directly in the 2010 ADA Standards. An example of this type of surface would be a brick or cobblestone walkway as shown in the photo below.

Sloped Brick Walking Surface That Transitions to Exposed Aggregate

The 2010 ADA Standards that may be compromised in the installation above is Standard 303.2, [Changes in Level] Vertical, which states, “Changes in level of ¼ inch (6.4 mm) high maximum shall be permitted to be vertical.”, and Standard 303.3, [Changes in Level] Beveled, which states, “Changes in level between ¼ inch (6.4 mm) high minimum and ½ inch (13 mm) high maximum shall be beveled with a slope not steeper than 1:2.” The diagram below is representative of these Standards.

Standard 302.2 Standard 302.3

Note that changes in level greater than 1/2 inch must be ramped. 2010 ADA Standard 303.4, Ramps, states, “Changes in level greater than ½ inch (13 mm) high shall be ramped, and shall comply with [Standards] 405 or 406.”

So, looking back at the brick walkway above that may not exceed these Standards, a disabled person using a wheelchair or walker will tell you these rough surfaces with frequent changes in level are still very difficult and uncomfortable to use even if they comply with the ADA Standards. Also, a common location for compromise in the change in level to occur is where the surface material changes, such as concrete changing to asphalt.

Another issue that pertains to floor and ground surfaces is openings. 2010 ADA Standard 302.3 [Floor and Ground Surfaces] Openings, states, “Openings in floor or ground surfaces shall not allow passage of a sphere more than ½ inch (13 mm) diameter except as allowed in [Standards] 407.4.3, 409.4.3, 410.4, 810.5.3 and 810.10. Elongated openings shall be placed so that the long dimension is perpendicular to the dominant direction of travel.” The graphic below is representative of this Standard. Note that if there is no clear dominant direction of travel, the 1/2 inch rule applies in all directions.

Floor or Ground Openings Maximum

Expansion Joint Excessive Gap Distant View

Surface openings are often associated with surface grates as shown above. However, another common source of excessive surface opening is at the expansion joints for a concrete or asphalt walkway. See the photo on the left. At the initial construction these expansion joints are often filled with a composite or wood material to maintain the level surface across the expansion joint. Over time this fill material can deteriorate and may disappear altogether, leaving an excessive gap. This gap should then be repaired to eliminate the gap. The photo below shows a closeup of this gap to demonstrate how wide and deep the gap is.

Expansion Joint Excessive Gap Close-up View

Dominant Path of Travel Across Surface Grate

This issue of orientation along the dominant direction of travel is particularly important to disabled individuals using a wheel chair because the front casters can easily drop into openings greater than 1/2 inch in width or length as is represented on the right.

Carpeted walking surfaces also must comply with the ADA Standards. 2010 ADA Standard 302.2, [Floor or Ground Surfaces] Carpet, states, “Carpet or carpet tile shall be securely attached and shall have a firm cushion, pad, or backing or no cushion or pad. Carpet or carpet tile shall have a level loop, textured loop, level cut pile, or level cut/uncut pile texture. Pile height shall be ½ inch (13 mm) maximum. Exposed edges of carpet shall be fastened to floor surfaces and shall have trim on the entire length of the exposed edge. Carpet edge trim shall comply with [Standard] 303.” The diagram below is representative of the maximum carpet pile height.

Maximum Recommended Carpet Pile Height

So there is a lot to this. The following Advisory helps to understand.

Advisory 302.2, Carpet, states, “Carpets and permanently affixed mats can significantly increase the amount of force (roll resistance) needed to propel a wheelchair over a surface. The firmer the carpeting and backing, the lower the roll resistance. A pile thickness up to ½ inch (13 mm) (measured to the backing, cushion, or pad) is allowed, although a lower pile provides easier wheelchair maneuvering. If a backing, cushion or pad is used, it must be firm. Preferably, carpet pad should not be used because the soft padding increases roll resistance.” The main issues with carpet installations are loose carpet, carpet that is too thick, or raised edges of carpet that present a tripping hazard. The graphic below is representative of loose carpet that resists a wheel rolling across the carpet, such as a wheelchair caster.

Loose Carpet Providing Resistance to Rolling Wheels

To avoid the issues with carpet, it should have low pile installed tight over a firm pad or cushion (preferably none), and secured at the edges. The graphic below is the tool commonly used to install carpet.

Carpet Installation Tool

The graphic below is representative of carpet edge trim secured to the floor.

Carpet Edge Trim

The graphic below is representative of carpet secured to tile.

Carpet Secured to Tile Flooring

A few notes to complete the carpet discussion follow. First, carpeted ramps are very difficult for wheelchair or rollers due to resistance. The combination of slope and resistance to rolling is difficult for disabled individuals using mobility devices. Second, synthetic sports surfaces are treated the same as carpet. Whether it is interior or exterior installations, make sure synthetic sports surfaces are fully compliant as carpet.

Temporary floor mats as shown below are not considered carpet per the ADA Standards. The ADA Standards do not address temporary floor mats specifically. However, the rules for elevation change can apply to temporary floor mats if the edges become warped [curled] and raised. On the other hand, a hard surface material that has an excessive abrupt elevation change can me mitigated by placing a temporary floor mat over the elevation change to “smooth” the surface with the mat.

Floor Mat in Grocery Store at Bagged Ice Dispenser

Every facility owner, operator, and/or tenant has a responsibility to maintain their facility in a safe and accessible condition. One of the primary responsibilities is flooring that is slip resistant. Temporary floor mats at the pedestrian entry/exit doors and where liquids are provided, such as at drinking fountains, drink dispensers, and sinks, can minimize slippery conditions where these conditions are common. Temporary floor mats that have a tight fibrous covering over a heavy composite base can provide a source of containment for moisture, dirt and sand that can accumulate in high traffic areas. As is the case for all elements in a facility, these mats must be maintained in good working order to include the condition of the fibrous covering and the edges of the mats.

In summary, floor and ground surfaces must comply with the ADA Standards. These surfaces should be stable, firm, and slip resistant. Slip resistant is not clearly defined by the 2010 ADA Standards so it is best to be extremely careful to maintain floor and ground surface conditions as slip resistant as possible.

If you observe a facility that is not ADA compliant and you would like to know how to proceed, please see the link at What To Do When A Building Is Not ADA Compliant or Accessible.

ADA Inspections Nationwide, LLC, offers ADA/ABA/FHA accessibility compliance inspections for buildings and facilities, as applicable to the different laws, and expert witness services with respect to ADA/ABA/FHA laws for building owners, tenants and managers. Also, ADAIN offers consulting for home modifications as a CAPS consultant for people wishing to age in place in their homes. For a complete list of services please see ADAIN Services.

Thank you.