# The  ABA



## north star (Mar 14, 2018)

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Greetings all !

I am looking for input on the Architectural Barriers Act ( ABA ).
Are these Standards "required" to be utilized, similar to
the `10 ADASAD, ...Ch. 11 in the IBC & the A117.1, or just
nice to have as another reference ?......Essentially, is this
Standard "legally required" to be enforced ?

Do any of you actually use these in your Plan Reviews,
and other ?

Thanks !

*< = =*


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## mark handler (Mar 14, 2018)

*Are you inspecting Federally Funded Projects? I did use the Stds when doing work for the DOD.*

Architectural Barriers Act (ABA) apply to facilities designed, built, altered, or leased with certain federal funds. Passed in 1968, the ABA is one of the first laws to address access to the built environment.  The law applies to federal buildings, including post offices, social security offices, federal courthouses and prisons, and national parks.  It also covers non-federal facilities, such as public housing units and mass transit systems, built or altered with federal grants or loans.  Coverage is limited to those funding programs that give the federal agency awarding grants or loans the authority to establish facility standards.


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## north star (Mar 14, 2018)

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Thanks ***Mark*** for your reply !

I am not inspecting anything......I am however reviewing some plans
for a renovation project at a military facility.......The facility does
receive Federal & State funding.

The RDP has listed the ABA as one of the applicable Standards, but
left out the A117.1 Standard.

So that I am clear, legal and justified with my Comments to everyone
involved, should I be "requiring" the listing & use of the ABA as an
applicable Standard on these military projects; as well as, the
`10 ADASAD, ...Ch. 11 in the IBC and the A117.1  ?........FWIW, some
of the plans I am reviewing are only State funded, but they are still
military facilities.

*< = =*


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## mark handler (Mar 14, 2018)

ANSI/ICC 117 is not one of the Referenced Standards in the Architectural Barriers Act (ABA).
It also refers to the International Building Code, 2000 Edition.
Check with your DOD liaison.
Or contact the 
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
(202) 272-0080 or (800) 872-2253


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## north star (Mar 14, 2018)

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I'm not sure I have a DoD liaison......That said, I reference the A117.1
from Ch. 11 in the IBC......As you and others already know, the A117.1
has requirements that the ADASAD and other Accessible Standards
do not.

*< = =*


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## ADAguy (Mar 15, 2018)

A117.1 is not an adopted standard by the Feds, it is only a safe harbor for some HUD projects.
Compliance with A117.1 is a not an alternative to ADASAD except where per local code it exceeds ADASAD.
If an existing facility is constructed to ABA then ABA may continue to be used as the standard. If you upgrade to a later standard then all future work must comply with that standard.  You also haven't mentioned UFAS?
You need to know the chronologic history of any post initial construction improvements to know if they were constructed to a later standard.


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## north star (Mar 15, 2018)

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ADAguy,

It is my intent to have the RDP's list all of the applicable
Accessibility Codes & Standards, on the projects I am
reviewing plans & Specs. for.

The A117.1 is "required" by the IBC.........That is one of
the three I have been listing.....Here is what the RDP's are
listing on their plans & in the Specs.......*(1)* Ch. 11 in the
IBC and *(2)* the `10 ADASAD.......Most are unawares of
the A117.1.

Now you are asking if I am aware of the UFAS......I haven't
been.........Is this a "required" Standard ?

FWIW, ...the current set of project plans that I reviewing
are all military.

*< = =*


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## Sleepy (Mar 15, 2018)

The ABA standards are the "required" accessibility standards for the US military.  A117.1 and IBC Chapter 11 are not required for the US military, except any portions that are referenced from the ABA Standards.  My understanding is that this is all because there is a separate law (the Architectural Barriers Act) that requires federal facilities to be accessible. The ABA pre-dates the ADA.  The UFAS is outdated and was a previous version of the ABA Standards and would only be relevant, as ADAguy says, if you are evaluating if an existing condition complies with a standard in effect at the time it was constructed.  For new construction and modifications the ABA Standards are required.  

See UFC 1-200-01, paragraph 2-11:
*2-11 CHAPTER 11 – ACCESSIBILITY. *
Do not use IBC Chapter 11. Use the _ABA Standards _and the special provisions of the Department of Defense Deputy Secretary of Defense Memorandum _Subject: Access for People with Disabilities_, October 31, 2008. Refer to Appendix A for a link to the _ABA Standards _and the DoD policy memorandum. Where the _ABA Standards _reference the previous versions of the IBC, the applicable requirements of the 2015 IBC are acceptable.​


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## north star (Mar 15, 2018)

*& * &*

Thanks ***Sleepy*** for the input !

The A117.1 is applicable if using the IBC.
Section 1101.2 Design "...shall be designed and constructed
to be accessible in accordance with this code *and* the ICC
A117.1".

*& * &*


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## Sleepy (Mar 15, 2018)

Hi North Star,  The trick, I think, is that Chapter 11 of IBC does not apply to US military facilities, they haven't adopted that specific chapter.  So there is no reference or requirement to comply with A117.1.  For what it is worth, the ABA Standards are very similar to the other accessibility codes.


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## north star (Dec 13, 2018)

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Hoping to resurrect this Topic...

In using the ABA & the `10 ADASAD,  I am trying to find
the language & sections that require existing facilities to
spend up to 20% of the "proposed" project cost.

Once gain, I am reviewing plans on an existing military
facility that is funded by state & federal funds......The
project is to make repairs, alterations, and upgrades
to the HVAC equipment, lighting, painting, install ATFP
rated windows & security screens, high security window
tinting, etc.

Presently, there are no ADA compliant Parking Spaces,
Signage, Accessible [ Entry ] Route, etc......It DOES appear
that the Restrooms are ADA compliant.

*QUESTION # 1:*  Is this project "required" to spend up to
20% of the project cost to upgrade the existing facility with
ADA elements ?

*QUESTION # 2:*  I am using the ABA, the `10 ADASAD &
the `15 I-Codes......If the answer to QUESTION # 1 above
is yes, ...what sections require the 20% funding ?

Any input is always GREATLY appreciated !.....Thanks ya'll !

*+ + +*


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## ADAguy (Dec 14, 2018)

Bag of worms you have opened "North". You can't mix apples with oranges.
Who is the AHJ on military projects? The Feds, not typically locals.
Who inspects these, The Feds, not typically locals.
As mentioned by others, the Feds set their own standards, often separate from IBC, CBC or others. 
Is this "renovation" to convert the facility to a local/non-military use (given that there are state funds involved)? If so that may be a game changer.


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## north star (Dec 14, 2018)

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ADAguy,

It's a complicated set up.

The AHJ on the project is the military.....I am reviewing
submitted documents on their behalf.

As far as inspecting, unfortunately, they are relying
on the RDP's to self inspect their own projects.  

The intent of the project is to update the military facility
to keep on using it as a military facility......These mililtary
facilities are funded by the state and the Feds.

Like I mentioned, it is complicated........My intent [  and
directives  ] is to generate Comments back to the AHJ
regarding the Codes & Standards that were used, or
should have been used to update the facility.......I would
like to be able to cite the applicable ADA Standards
accurately; as well as, the other applicable Codes &
Standards.

In my first review of the submitted plans, this particular
facility doesn't have any ADA Parking, Accessible Routes
in to the facility, Signage, etc........The interior looks
pretty much ADA compliant..........The listed cost on this
project is approx:  $950k.

Is there a "requirement" for them to spend up to 20% of
the $950k to update other non-ADA compliant elements
at this facility ?

*~ + ~ + ~*


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## Sleepy (Dec 14, 2018)

North Star,
I don't see the 20% thing in ABA either.  F202.3 and F202.4 contain pretty specific requirements for alterations or additions to existing buildings.  It uses words like "to the maximum extent feasible" which gives a little latitude, I suppose.  There is also a definition of "technically Infeasible" which may help.


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## north star (Dec 14, 2018)

*~ + ~ + ~*

Thanks ***Sleepy !***

*~ + ~ + ~*


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## Tim Mailloux (Dec 14, 2018)

north star said:


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This requirement is part of the IEBC. So if the project falls under the IEBC I would say they are required to make upgrades to the accessible route , which would start at the handicap parking spaces.


*IEBC 705.2 Alterations affecting an area containing a primary function. *
Where an alteration affects the accessibility to a, or contains an area of, primary function, the route to the primary function area shall be accessible. The accessible route to the primary function area shall include toilet facilities and drinking fountains serving the area of primary function.

*Exceptions:*

1. The costs of providing the accessible route are not required to exceed 20 percent of the costs of the alterations affecting the area of primary function.

2. This provision does not apply to alterations limited solely to windows, hardware, operating controls, electrical outlets and signs.

3. This provision does not apply to alterations limited solely to mechanical systems, electrical systems, installation or alteration of fire protection systems and abatement of hazardous materials.

4. This provision does not apply to alterations under-taken for the primary purpose of increasing the accessibility of a facility.

5. This provision does not apply to altered areas limited to Type B dwelling and sleeping units.


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## north star (Dec 14, 2018)

*$ ~ $ ~ $*

Thanks ***Tim Mailloux*** !.......That is what I was searching
for.

The `15 IEBC IS one of the applicable Codes.

*$ ~ $ ~ $*


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## Paul Sweet (Dec 14, 2018)

I believe that the 20% requirement is in Title III - ADA (private sector), but isn't part of Title II - ABA (government).  However, if the building code requires it and the military hasn't replaced the IBC & IEBC requirements with ABA then it applies.


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