ADA/ADAAG in Commercial Buildings
Q: What are the height rules for mounting keypads or annunciators to meet ADA (Americans with Disabilities Act) or ADAAG (ADA Accessibility Guidelines)? Are they different for commercial buildings than they are for residential buildings? We have adopted the ICC (International Code Council) guidelines.
A: New apartments and condominiums must have a certain number of accessible units by International Building Code (IBC) rule 1109.13. Any controls in these rooms must be accessible to the occupants living there. However, a keypad can be installed up to 54 inches (to the top row of keys) where there is side-reach available from a wheelchair. If you can’t parallel park next to it, then install one up to 48 inches. All measurements should be from the floor to the top row of touch-keys.
Commercial buildings are not required to lower the height of their security or fire alarm keypads unless they hire a handicapped (wheel chaired) employee whose job it will be to use that keypad. In which case, ADA Title I might apply. (Also see 1103.2.3 of the IBC). In researching the ADA rule numbers that would apply, there is no specific passage that spoke to security controls or fire alarm annunciators. However, the sum of the other rules conclude they are exempt. For example, part of an occupant’s job duties (work) may be to arm and disarm the security alarm, or otherwise operate it as needed. This now makes the space directly in front of the arming station a “work area.” Work areas are exempt per 4.1.1 (3) of the ADAAG.
Generally, security keypads are exempt by 4.1.1 (5) of the ADAAG. These devices are intended to be installed where they can be readable and usable by those responsible for doing so.
Furthermore, the IBC distinguishes between “occupants” and “other personnel.” Therefore, these keypads are not to be used by the “occupants” but fall into the same category as the other controls intended to be used only “by service or maintenance personnel” and as so, specifically exempted by exception #1 in 1109.13: “Operable parts that are intended for use only by service or maintenance personnel shall not be required to be accessible.” Simply stating this intention by the building owners should be enough to exempt these security “operable parts.”
Rule 1103.2.9 of the IBC specifically exempts “equipment spaces” used “by personnel for…monitoring of equipment….” If the space doesn’t have to be accessible, then neither does the equipment located there.
The section of ADAAG that exempts work areas used by employees is under ADAAG 4.1.1 Application: Areas Used Only by Employees as Work Areas. Areas that are used only as work areas shall be designed and constructed so that individuals with disabilities can approach, enter and exit the areas. These guidelines do not require that any areas used only as work areas be constructed to permit maneuvering within the work area or be constructed or equipped (i.e., with racks or shelves) to be accessible.
Greg Kessinger, SET, CFPS, president of an alarm installing company since 1981, teaches NICET training classes to fire alarm system designers and installers and continuing education seminars for Ohio’s fire alarm inspectors. You can reach him at 888-910-2272; e-mail: [email protected]; or visit his website at www.FireAlarm.org.
