ADA Requirements for Education Facilities
Photo of a School
This article will discuss the Americans with Disabilities Act (ADA) requirements for education facilities (schools). The graphic on the right is representative of a school.
The areas covered in this article include:
ADA Regulations applicable for schools
Covered Facilities
Site Arrival Points and Accessible Exterior Routes
Entrances
Interior Routes
Common Use Areas
Classrooms and Assembly Areas
Toilet & Bathing Facilities
Dormitories and Graduate/Faculty Housing
Recreation Facilities
ADA Regulations Applicable for Schools
Section 504 of the Rehabilitation Act of 1973 and the ADA of 1990 were intended to cover schools as well as other public and private facilities. Public Law 94-142, the Education for All Handicapped Children Act, passed in 1975, was the federal legislation that initially resulted in major changes in the way schools served children with disabilities. This law, now called the Individuals with Disabilities Education Act (IDEA), was accompanied by federal funds and was the focal point of schools in serving children with disabilities. IDEA requires public schools to make available to all eligible children with disabilities a free appropriate public education in the least restrictive environment appropriate to their individual needs. IDEA focuses on the academic process whereas Section 504 and the ADA laws do not. Section 504 and the ADA, which provided no funding, were initially considered less important for schools than IDEA.
Recently Section 504 and the ADA have been accepted by schools as applicable laws. There are several reasons Section 504 and the ADA have become more prominent in public schools, but the primary reason is that Section 504 and the ADA use a different definition of disability and a different approach to eligibility than does the IDEA, resulting in many children who are not eligible under IDEA being protected by Section 504 and the ADA. These requirements in IDEA, Section 504, and the ADA laws, apply to facilities at private and public education entities.
All public school districts, colleges, or universities must comply with Section 504 of the Rehabilitation Act of 1973 and Title II of the ADA because they receive some form of federal assistance. Section 504 and the ADA apply to all programs and facilities of a public school or college, not simply academics or academic facilities. These programs can include athletics, band, cheerleading, clubs, academic teams, etc., whether the program occurs on campus or off campus.
Neither Section 504 or the ADA requires that all buildings be made fully accessible to students or teachers with disabilities. Those buildings constructed after the Section 504 regulation was issued in 1977 must be fully accessible. Buildings constructed before Section 504 was issued and not altered after Section 504 was issued do not have to be made fully accessible but, the programs or activities in those buildings must be made accessible.
Private school entities, including those with religious affiliation, that receive federal funding are also required to comply with Section 504, but because they are private (not government) ADA Title III applies to them. Private entities that use their facilities in such a way that the public can have access to the facility, such as fund raisers, athletic events, concerts, plays, parents day, grandparents day, visitors day, etc., will also have to comply with the ADA Standards for those areas of the facilities that are open to the public.
In either type of education facility, public or private, there is always a requirement to provide public accommodations within the ADA. Public accommodation is not required if a particular aid or service would result in either fundamental alteration of the services offered by the facility or if the accommodation would impose an undue burden.
Covered Facilities
Education facilities that are required to comply with the ADA laws include:
Pre-Schools
Elementary Schools
Middle Schools
High Schools
Colleges and Universities
Trade Schools
Site Arrival Points and Exterior Routes (Standard 206)
Site arrival points can include bus stops, municipal walkways, adjacent sites, public streets, accessible parking, passenger loading zones, and public transit stops located on site. An accessible exterior route must connect site arrival points to each accessible entrance they serve. At least one accessible exterior route shall connect accessible buildings, accessible facilities, accessible elements, and accessible spaces that are on the same site. Accessible routes must coincide with or be in the same vicinity as general circulation paths. The graphic below is representative of site arrival points and exterior routes at a facility.
Site Arrival Points and Exterior Route
Where two or more similar site arrival points, such as bus stops, serve the same accessible entrance or entrances, both bus stops must be on accessible routes. In addition, the accessible routes must serve all of the accessible entrances on the site. A representative article about accessible site arrival points is available at ADA Done Right 1/8/19.
Parking (Standard 208)
Parking at schools is a site arrival point(s). The required amount of accessible parking spaces, including van accessible spaces, is calculated separately for each parking area on the site. Accessible parking spaces must be dispersed among accessible entrances and be located on the shortest accessible route to the entrances they serve. The graphic below is representative of accessible parking areas.
Accessible School Parking
An article with additional information about parking is available at ADA Accessible Vehicle Parking Scoping Requirements.
Passenger Loading/Unloading Zones (Standard 209)
School Bus Passenger Loading/Unloading Zone
Passenger loading and unloading zones at schools are site arrival points. At least 1 accessible passenger loading zone is recommended for every continuous 100 linear feet (or a fraction thereof) of passenger loading zone space. The graphic on the right is representative of a bus passenger loading/unloading zone at a school. An article with additional information is available at Passenger Loading Zones and the ADA.
Exterior Routes (Standard 206.2.2)
An accessible exterior pedestrian route from public streets and sidewalks must connect directly or indirectly to all accessible facilities and elements on a side. An accessible route must serve all accessible spaces and elements on a site, including those that are exterior, such as courtyards and drinking fountains. The graphic below is representative.
Exterior Routes at a School
An accessible route must connect site arrival points such as accessible parking spaces, passenger loading zones and transportation stops to each accessible facility they serve. An accessible route within the boundary of the site must connect each facility on the site, except those connected only by a vehicular way that does not provide pedestrian access. A representative article about accessible exterior routes is available at ADA Done Right 1/8/19.
Exterior Entry/Exit Entrances and Doors (Standard 206.4)
At least 60% of public pedestrian entrances (rounded UP) for facilities are required to comply with the ADA Standards. Entrances can include the door, signage, security installations, the route to the entrance, and a communication system. If there are two public entry/exit doors for a facility, 60% of 2 is 1.2, so both doors would have to comply. Requirements for accessible public entry/exit entrances are represented in the graphic below. The graphic below is representative of an accessible entrance for a facility.
Additional information about manual doors can be found at the article Manual Doors and the ADA.
Interior Routes (Standard 402)
An accessible route from the facility entrance is required to each accessible room, space and element [Standard 206.2.2]. Accessible routes must serve each level on a floor required to be accessible. Vertical access can be achieved by ramps, curb ramps, elevators, or where permitted platform lifts. The graphic below is representative of an interior route.
Representative Interior Route
Signage and protruding objects are two key issues with interior routes. Information about signage is available at ADA Compliant Building Signs. Information about protruding objects is available at Protruding Objects as Defined by the ADA.
Common Use Areas
Common use areas in schools include cafeterias, gymnasiums, auditoriums, libraries, laboratories, and employee work areas such as administration offices that are also open to the public. Installations found within these spaces include counters, dining and work surfaces, assembly seating, signage, storage, and drinking fountains. There is not a specific ADA Standard for “common use areas”. However, there are many ADA Standards that apply to the elements in common use areas.
Additional information about counters can be found at Counters Covered Under the ADA. The graphic below is representative of an accessible counter in a school.
Accessible Counter in a School
Schools can have a lot of shelving to store books and supplies and personal items. Libraries in particular have many aisles with books stored on shelves. The aisles for these shelves must be accessible which means mostly 36 inches wide and mostly flat. Self-service shelving is not required to comply with Standard 308 for reach ranges. However, there is always a requirement to provide reasonable accommodations for individuals with disabilities. Signage indicating help is available to reach items high up on a shelf is considered a reasonable accommodation.
Additional information regarding dining and work surfaces can be found at Dining Surfaces That Comply with ADA Laws. Dining and work surfaces are commonly covered together in the ADA laws. The photo below is a laboratory with multiple work stations.
Laboratory Work Stations
The photo on the right is representative of a school cafeteria where accessible dining surfaces, counters, self-service shelves, and routes throughout the space will be necessary. Even though much of this table arrangement may not be fixed to the floor or walls, it is still expected that adequate spaces for disabled individuals will be provided based on obligations for readily achievable barrier removal.
Additional information regarding assembly areas can be found at Accessible Assembly Area Scoping Requirements for ADA. The photo below is a typical college lecture assembly area.
College Lecture Assembly Area
Additional Information about signage is available at ADA Compliant Building Signs. There are usually a lot of signs in schools. Signs that are exempt from compliance with the ADA include temporary signs, building menus, directories, addresses, company names, and logos. Accessible signs can be tactile or visual. The photo below is representative of a tactile school sign.
Compliant Tactile Sign
Additional information about accessible drinking fountains can be found at Drinking Fountains and the ADA. There are different requirements for schools where the typical age of the students is 12 and under. The graphic below is representative of a drinking fountain installation in a school.
Typical Drinking Fountain Heights
Visual alarms should be located in toilet and bathing facilities, all public interior spaces, and all common use spaces [Standard 215].
Classrooms
There is no specific ADA Standard that applies to “classrooms”. However, there are many individual ADA Standards that apply to the elements in classrooms. Classrooms can be small or large, permanent or temporary, and indoors or outdoors. Regardless, classrooms are common use areas that must comply with the ADA Standards for entry/exit doors, accessible routes within the classroom, work surfaces, operable parts, sinks, alarms, and storage. Classrooms can also be assembly areas and must comply with the applicable ADA Standards. Each year the student body attending the school and classrooms will be different so reasonable accommodations are expected. Classroom acoustics and a requirement for assistive listening systems (ALS) may be necessary. Additional information regarding ALS is available at Assistive Listening Systems and the ADA. The graphic below is representative of a typical classroom.
Typical Classroom
The graphic below is representative of a university lecture hall (assembly area). Assembly areas were discussed above under Common Use Areas.
University Lecture Hall (Auditorium)
Additional information about accessible assembly areas is available at Accessible Assembly Areas as Defined by ADA.
Toilet & Bathing Facilities (Standard 213)
Toilet and bathing facilities can be found in many locations at schools. Toilet rooms can be found in hallways, classrooms, gymnasium locker rooms, faculty break rooms, dormitories, and residential dwelling units. With few exceptions, all toilet rooms should be ADA accessible. Bathing rooms are more likely found in gymnasiums, dormitories, and residential dwelling units. Toilet and bathing rooms can be single user, unisex, and multi-user. The rules for ADA compliance in these facilities vary based on the type of installation and location. Additional information about toilet rooms is available at Single User Toilet Rooms and Multi-User Toilet Rooms and Toilet and Bathing Rooms Locations and Counts. The graphic below is representative of an accessible single user toilet room.
Single User Toilet Room
Additional information about bathing rooms can be found at Accessible Bathing Rooms and Multi-User Bathing Rooms. The graphic below is representative of a multi-user bathing room.
Multi-User Toilet and Bathing Installation
Sinks are common in schools in many locations beyond toilet and bathing rooms. 2010 ADA Standard 212.3, Sinks, indicates that where sinks are provided, at least 5 percent, but no fewer than one, of each type provided in each accessible room or space shall comply with 2010 ADA Standard 606. Sinks typically require a forward approach with knee and toe clearance below the sink for individuals using a wheelchair. There are different rules for sinks used mostly be children at the age of 12 and under and at the age of 5 and under. The graphic below is representative of an accessible sink.
Accessible Sink with Knee and Toe Space
Additional information is available at Accessible Sinks and Mirrors as Defined by the ADA.
Toilets obviously are a key component of any toilet or bathing room. It is important to remember that there are different Standards for toilets intended for use by children at the age of 12 or under. The graphic below is representative of a toilet for children at the age of 12 or under.
Toilet Installation for Children 12 and Under
Dormitories and Graduate/Faculty Housing (Standards 224 and 809)
Housing at schools is mostly found in colleges and universities. However, there are some K-12 schools that have dormitories for students as well.
Transient lodging accessibility rules for dormitories in schools are found in Federal Regulations §35.151(f) and §36.406(e). An article with additional information can be found at Accessible Transient Lodging. The graphic below is representative of a dormitory.
School Dorm Room
Residential Dwelling Unit rules for graduate student and faculty housing are found in Federal Regulations §35.151(e) and §36.406(d). These rules apply to housing that is typically leased for a year and offers no programmed education within the unit. An article with additional information is available at Residential Dwelling Units and the ADA.
Recreational Facilities (Standard 1001.1)
Recreation facilities are common at all schools. From play areas for Pre-K to football stadiums at major universities, all recreational facilities must comply with the ADA Standards. The graphic below is representative of a play area.
Play Area
An excellent source of information about play areas is the Longitudinal Study on Playground Surfaces. See the graphic on the right. This document covers the 7 things every playground owner should know about the accessibility of their playground surfaces. Additional information is available at Playground Surfaces and the ADA.
The ADA Standards refer frequently to areas of sport activities. An area of sport activity is defined as “that portion of a room or space where the play or practice of a sport occurs.” An accessible route is required to each area of sport activity within a sport complex. The graphic below is representative.
Sport Complex with Accessible Routes to Areas of Sport Activities
Additional information is available at Area of Sport Activity Floor Surfaces. ADA Standards apply to recreational facility elements at schools such as exercise equipment, press boxes, locker rooms, benches in dressing rooms, and swimming pools. Chapter 10 of the ADA Standards covers Recreational Facilities.
SUMMARY
Education facilities [schools] must comply with the ADA Standards. These facilities are complicated and complex. Many sections of the ADA Standards apply to schools, whether they are public or private entities. Other regulations may apply such as Section 504 of the Rehabilitation Act, the Architectural Barriers Act, and regulations at the Department of Education. Where regulations overlap, the regulation with the most stringent requirements should be followed.
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