# ADA Turning Space Room Requirements



## fj80 (Dec 22, 2016)

Does the ADA specify what types of rooms require a turning space? I've always assumed any rooms with a single entrance/exit requires a turning space, but I'd like to know if that's specifically addressed in the ADA.

I ask because an interior designer with whom I'm coordinating my work, has proposed a small work room/print room (about 70sf), with one door, that just barely has room for a 60" turning space, but is showing a printer overlapping the turning space.

I know the printer is not allowed to overlap the turning space, but I also want to confirm whether or not the turning space is required. I believe it is, but would like to point the interior designer to which part of the ADA says so.


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## mark handler (Dec 22, 2016)

203, 206 and 215 Employee Work Areas

Common Use Circulation Paths in Employee Work Areas. The 1991 Standards at section 4.1.1(3), and the 2010 Standards at section 203.9, require employee work areas in new construction and alterations only to be designed and constructed so that individuals with disabilities can approach, enter, and exit the areas. Section 206.2.8 of the 2010 Standards requires accessible common use circulation paths within employee work areas unless they are subject to exceptions in sections 206.2.8, 403.5, 405.5, and 405.8. The ADA, 42 U.S.C. 12112 (b)(5)(A) and (B), requires employers to make reasonable accommodations in the workplace for individuals with disabilities, which may include modifications to work areas when needed. Providing increased access in the facility at the time of construction or alteration will simplify the process of providing reasonable accommodations when they are needed.

Several exceptions to section 206.2.8 of the 2010 Standards exempt common use circulation paths in employee work areas from the requirements of section 402 where it may be difficult to comply with the technical requirements for accessible routes due to the size or function of the area:

Employee work areas, or portions of employee work areas, that are less than 300 square feet and are elevated 7 inches or more above the ground or finish floor, where elevation is essential to the function of the space, are exempt.
Common use circulation paths within employee work areas that are less than 1,000 square feet and are defined by permanently installed partitions, counters, casework, or furnishings are exempt. Kitchens in quick service restaurants, cocktail bars, and the employee side of service counters are frequently covered by this exception.
Common use circulation paths within employee work areas that are an integral component of equipment are exempt. Common use circulation paths within large pieces of equipment in factories, electric power plants, and amusement rides are covered by this exception.
Common use circulation paths within exterior employee work areas that are fully exposed to the weather are exempt. Farms, ranches, and outdoor maintenance facilities are covered by this exception

Individual employee work stations, such as a grocery checkout counter or an automobile service bay designed for use by one person, do not contain common use circulation paths and are not required to comply. Other work areas, such as stockrooms that typically have narrow pathways between shelves, would be required to design only one accessible circulation path into the stockroom. It would not be necessary to make each circulation path in the room accessible. In alterations it may be technically infeasible to provide accessible common use circulation paths in some employee work areas. For example, in a stock room of a department store significant existing physical constraints, such as having to move walls to avoid the loss of space to store inventory, may mean that it is technically infeasible (see section 106.5 "Defined Terms" of the 2010 Standards) to make even the primary common use circulation path in that stock room wide enough to be accessible. In addition, the 2010 Standards include exceptions for common use circulation paths in employee work areas where it may be difficult to comply with the technical requirements for accessible routes due to the size or function of the areas. The Department believes that these exceptions will provide the flexibility necessary to ensure that this requirement does not interfere with legitimate business operations.


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## ADAguy (Dec 23, 2016)

Though as Mark points out there are "some" exceptions, consideration should be given to the possible future hiring of an individual requiring workplace accommodations per Title I of the ADA.
I believe there is a possible exception for employers of less than 10 people (Mark?).


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## fj80 (Dec 23, 2016)

This is very helpful, thank you. I'm going to direct them to these sections of the ADA and recommend they make room for the turning space since it's reasonable to do so in my opinion.


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