# Accessibility for zipline tour/amusement ride



## righter101 (Oct 13, 2010)

Our jurisdication has a "zip line tour" going in.  classified as an A5 (amusement ride). consists of 8 or so line segements.  riders are harnessed in, ride the line, get out at a ground or tower termination then move on to the next line.  some of the transitions from the end of one and beginning of the next are via the same platform in a tree, while others involve a short walk across uneven ground or rocks.

Question: using the scoping provisions of the IBC Ch. 11, what would you require to be accessible.  I have a no brainer of the parking, accessible restrooms at the parking lot, accessible path to the start of the ride... beyond that??

would one reasonably consdier the ride to be a single entity, provide access to the start?

should the paths within the course be required to meet accessibity requirements???

any input is appreciated.

thanks.


----------



## brudgers (Oct 13, 2010)

What code provisions do you believe require the measures you are suggesting?


----------



## mark handler (Oct 13, 2010)

righter101 said:
			
		

> beyond that??
> 
> \


http://www.access-board.gov/recreation/guides/amuse.htm


----------



## Rick18071 (Oct 14, 2010)

I would call this occupancy "U". No accessibilty needed.


----------



## Coug Dad (Oct 14, 2010)

Rick highlights one of the major traps within the accessibility codes.  While a building official might determine that the amusement device is Group U occupancy and not subject to the IBC accessibility rules, that is not a safe harbor for the owner from future lawsuits based upon DoJ's application of the Civil Rights legislation.


----------



## mark handler (Oct 14, 2010)

You may not care but all Recreational facilities, including amusement park rides, are among the facilities required to comply with the ADA.


----------



## righter101 (Oct 14, 2010)

brudgers said:
			
		

> What code provisions do you believe require the measures you are suggesting?


Brudgers, I am using 2006 IBC

1103.1 Where required. Sites, buildings, structures, facilities,

elements and spaces, temporary or permanent, shall be accessible

to persons with physical disabilities.

1104.1 Site arrival points. Accessible routes within the site

shall be provided from public transportation stops; accessible

parking; accessible passenger loading zones; and public streets

or sidewalks to the accessible building entrance served.

1104.2 Within a site. At least one accessible route shall connect

accessible buildings, accessible facilities, accessible elements

and accessible spaces that are on the same site.

This is a for profit, guided tour.  I have classed it as an A5, amusement ride, which is defined under some of our Washington State Laws.  the state actually licenses them but doesn't touch the accessibility, leaving it to us.

I am just trying to determine if i need them only to provide access to the start of the "tour", or if any of the "elements" with in need to be accessible as well.  if it was one continious line, its a no brainer, but there are multiple lines and when you get off one, you may need to walk, hike, climb rocks, etc, to get to the next portion.

thanks for your advice and opinion.


----------



## righter101 (Oct 14, 2010)

No, I do care.  I am just wondering to what extent it needs to be accessible.  My initial plan review called for providing accessible paths between the platforms where you terminate one segement and start another.  The applicant is arguing that this would involve bulldozing massive amounts of forest to provide the required level walking surface, and due to the nature of the ride, certain people will not be allowed to ride it.

Similar to a rock climbing wall.  We provide access to it, but some people will be unable to use it.

Just looking for opinions.  I have erred on the side of making it entirely accessible and now am being asked to reconsider.

thanks to all for advice and opinions.


----------



## mark handler (Oct 14, 2010)

Let me know where it is and we will send our disabled access friends form DOJ over to file federal lawsuits

By the way, they do go after designers, for designing non-accessible structures.

http://www.ada.gov/


----------



## brudgers (Oct 15, 2010)

> 1103.1 Where required.


That's the crux of my question.

What specifically requires the zipline to be accessible?

I'm not saying there isn't something.

But until you can put your finger on the specific requirement, you cannot legitimately require accessibility.

In other words, until the zipline must be accessible, no accessible route to it is required...all the way back to transit stops etc.

Other elements of the site may  require accessibility, but that does not mean that the ride itself requires it.

You can't ride some roller coasters if you're less than 48" tall.


----------



## righter101 (Oct 15, 2010)

Using 1103.1

1103.1 Where required. Sites, buildings, structures, facilities,

elements and spaces, temporary or permanent, shall be accessible

to persons with physical disabilities.

My reading of the commentary further explains this as "this section establishes the principle that all buildings, structures, and their associated sites and facilities are required to be accessible to persons with disabiltites..."

I read the "access board" link that Mark Handler sent, giving plan english language of amusement rides.  here is a cut and paste of the highlights: (italicized)

_all newly designed, constructed and altered recreation facilities covered by the ADA will be required to comply._

_The recreation facility guidelines cover the following facilities and elements:_

_Amusement rides _

_Emphasis is placed on ensuring that individuals with disabilities are generally able to access the amusement ride and use a variety of elements. Designers and operators are encouraged to exceed the guidelines where possible to provide increased accessibility and opportunities. Incorporating accessibility into the design of an amusement ride should begin early in the planning process with careful consideration to accessible routes and providing access to rides._

_An "amusement ride" is defined by the guidelines as a system that moves people through a fixed course within a defined area for the purpose of amusement._

_Exceptions_

_There are four types of rides that are not covered by the guidelines. However, other ADA requirements still apply. The four types are:_

_·         Rides that do not have seats must only provide an accessible route to the load and unload areas and a turning space in the load and unload area._

This is the first one I have permitted in our jurisdiction and I was looking to see how other jurisdictions have treated them.


----------



## brudgers (Oct 15, 2010)

righter101 said:
			
		

> This is the first one I have permitted in our jurisdiction and I was looking to see how other jurisdictions have treated them.


Do you approve stuff because, "They allow it in the next town over?"

The simple comment for the plan review is "Amusement ride load and unload areas not designated."


----------



## righter101 (Oct 15, 2010)

I don't approve things because they do in other jurisdictions.  I am trying to gather info and opinions because I don't want to unnecessarily regulate something I shouldn't or allow something that should be prohibited.

I initially told these folks that they needed to provide an accessible path to the indiviual landing and takeoff points on the tour.  They are trying to make a case that they dont, that the "ride" has one start and end point and the stuff along the route doesn't need to be accessible.

It seems like a grey area and I am trying to navigate it best I can and make a proper decision.

thanks.


----------



## Yankee (Oct 15, 2010)

righter101 said:
			
		

> I don't approve things because they do in other jurisdictions.  I am trying to gather info and opinions because I don't want to unnecessarily regulate something I shouldn't or allow something that should be prohibited.I initially told these folks that they needed to provide an accessible path to the indiviual landing and takeoff points on the tour.  They are trying to make a case that they dont, that the "ride" has one start and end point and the stuff along the route doesn't need to be accessible.
> 
> It seems like a grey area and I am trying to navigate it best I can and make a proper decision.
> 
> thanks.


Seems like if the start is accessible, there is an invitation to start the ride. At that point, are you going to leave someone stranded in the middle of the ride without any ability to get from one landing to the next takeoff?

No.

The middle sections have to be as accessible as the start and the finish.


----------



## brudgers (Oct 16, 2010)

righter101 said:
			
		

> I don't approve things because they do in other jurisdictions.  I am trying to gather info and opinions because I don't want to unnecessarily regulate something I shouldn't or allow something that should be prohibited.I initially told these folks that they needed to provide an accessible path to the indiviual landing and takeoff points on the tour.  They are trying to make a case that they dont, that the "ride" has one start and end point and the stuff along the route doesn't need to be accessible.
> 
> It seems like a grey area and I am trying to navigate it best I can and make a proper decision.
> 
> thanks.


Does the ride have seats?

If so, are you stretching the definition of "seats?"

I'm just playing the devil's advocate to help you reach that decision.


----------



## Yankee (Oct 16, 2010)

brudgers said:
			
		

> Does the ride have seats?If so, are you stretching the definition of "seats?"
> 
> I'm just playing the devil's advocate to help you reach that decision.


I thought that meant if the ride had seats, an accessible seat would be required. If the ride didn't have seats, an accessible seat would not be required.  However, if a disabled person is capable of riding in the "attachment", then there should be an accessible route to and from (and all along) the ride. It is too easy to get caught up in thinking of a person in a wheelchair, when actually there are other disabilities to consider (like sight impaired) that could easily enjoy rides.


----------



## brudgers (Oct 16, 2010)

Based on the information posted, accessibility between loading and unloading points is only required if the ride has seats.


----------



## righter101 (Oct 18, 2010)

brudgers said:
			
		

> Based on the information posted, accessibility between loading and unloading points is only required if the ride has seats.


In reading the access-board.gov info for amusement rides, I found this language,

Exceptions

There are four types of rides that are not covered by the guidelines. However, other ADA requirements still apply. The four types are:

1,2,3 omitted by me...

#4=

Rides that do not have seats must only provide an accessible route to the load and unload areas and a turning space in the load and unload area.

So, using this as a guide, i would consider the zip tour to not have seats, thus requiring accessible route to the load and unload areas as the requirement.  in this case, there happens to be multiple points, which is the bone of contention from the owners.

I think I was initially correct, but they are asking to have the decision reconsidered.  I just wanted to get all the information I could and make the correct decision.

Thanks for all the input from you guys.  I appreciate this forum and being able to get pov's from those quite well versed in the building codes.


----------



## brudgers (Oct 18, 2010)

On what basis are you determining that the zipline is several rides rather than one?

Can a person normally start at a middle station rather than the first?

Can a person normally exit at a middle station rather than the last?

Is accessboard.gov incorporated into your local code by reference?


----------



## righter101 (Oct 18, 2010)

brudgers said:
			
		

> On what basis are you determining that the zipline is several rides rather than one?Can a person normally start at a middle station rather than the first?
> 
> Can a person normally exit at a middle station rather than the last?
> 
> Is accessboard.gov incorporated into your local code by reference?


The several rides vs. 1 is the crux of the issue and I am still working to make that determination.  You would not be allowed to come to the tour and say just go on line 4.  You could exit at a middle station rather than the last one.

Our local codes have not adopted specifically the accessboard.gov.  I am using that to gain information and insight in to this situation.

Setting aside the accessboard guidance, I still can revert back to IBC 1103.1

1103.1 Where required. Sites, buildings, structures, facilities,

elements and spaces, temporary or permanent, shall be accessible

to persons with physical disabilities.

In which case they would need to make the entire setup accessible.  The accessboard gave some specific guidance not found in the building code as it pertains to amusement rides.  However, the listed building code exceptions do not cover this.  That is why I have put this question out for comment.

The question of if this is a single "facility" or "element", or if it is multiple "elements" is a gray area that could be succesfully argued by either side.

Continued input is appreciated.


----------



## Yankee (Oct 18, 2010)

If you make the beginning and the end accessible, you have to make the whole thing accessible. If it is common to get off at a stop in-between then you also need an accessible route to leave the ride and go back to the base. They do not want a handicap person trying to find their way over a rugged path from one section to the next section.


----------



## brudgers (Oct 18, 2010)

righter101 said:
			
		

> The several rides vs. 1 is the crux of the issue and I am still working to make that determination.  You would not be allowed to come to the tour and say just go on line 4.  You could exit at a middle station rather than the last one.Our local codes have not adopted specifically the accessboard.gov.  I am using that to gain information and insight in to this situation.
> 
> Setting aside the accessboard guidance, I still can revert back to IBC 1103.1
> 
> ...


If you can't point specifically to something in the code that requires it, then it's not required.


----------



## JBI (Oct 18, 2010)

I believe, based on the indicated site constraints, that a strong case could be made for _technically infeasable_ in this instance. If the site would require that much physical alteration it would also be an environmental review nightmare to make it accessible.

As far as a Code Section, it has been quoted.

1103.1 Where required. *Sites*, buildings, structures, facilities,

*elements* and spaces, temporary or permanent, *shall be accessible*

to persons with physical disabilities.

1104.2 Within a site. *At least one accessible route shall connect*

accessible buildings, accessible facilities, *accessible elements*

and accessible spaces that are on the same site.

IMHO, in regard to the quandry, there is a zipline element, followed by an overland element, followed by a zipline element, etc.

How would the wheelchair get from one end to the other?


----------



## brudgers (Oct 18, 2010)

JBI said:
			
		

> How would the wheelchair get from one end to the other?


Or how do you hook the wheelchair to the zipline safely?


----------



## Yankee (Oct 19, 2010)

brudgers said:
			
		

> Or how do you hook the wheelchair to the zipline safely?


Again, there are many disabilities and don't constrain yourself to thinking only of wheelchairs. A legally blind person could ride a zip line with no equipment to haul around and need to navigate the intermediate elements, and probably lots of other disabilities that I can't think of also.


----------



## righter101 (Oct 19, 2010)

JBI said:
			
		

> I believe, based on the indicated site constraints, that a strong case could be made for _technically infeasable_ in this instance. If the site would require that much physical alteration it would also be an environmental review nightmare to make it accessible. As far as a Code Section, it has been quoted.
> 
> 1103.1 Where required. *Sites*, buildings, structures, facilities,
> 
> ...


Those are the code sections I am basing the requirement for accessibilty.  With regards to "technically infeasable", I only find this language in the provisions for existing construction.

The applicants contention, which I don't agree with, is that this is a "challenge course" type activity, certain people will not be able to use it.  If you are 600 pounds, you can not go on it.

As Brugers pointed out, it is not likely that our Jurisdiction has adopted the access-board.gov website as a refernced standard, so is it unwise to use the Federal Government's own information, provided as a service to promote compliance with the accessiblity guidelines and statues???

It seems like a good reference, given the reason for creation and the fact it is backed or funded by those tasked with enforcement.  Why should I avoid using this as a guide for accessiblity?? Why should I use this guide??

I appreciate everyones input, playing devils advocate, etc....

If I use the letter of the law IBC, they will need to make this entire setup fully accessible.  That is scoped in 1103.1.  The listed exceptions couldn't be reasonably applied to this situation.  The access-board.gov offers very specific guidelines for amusement rides which would seem a much more practical application, and, as put forth by those whose goals are to ensure compilance, a reasonable resource for making decisions such as this.

While the owner/applicant states that a rider would not be allowed to start mid way through the tour, it would be reasonable to surmise that should someone be unable to continue or unwilling to continue, they would be permitted to exit the tour and make their way back to the parking lot.  In that context, I am leaning towards making accessible routes to all load and unloading points required.

Assuming they did that for a moment, accessible routes connecting the platforms and towers.  Do the towers then need to be accessible??  There is a requirement to climb some sort of ladder to get to the next hook in point.  To make ramps or even stairs would require far more effort and resources than the ride would be worth.

Could one reasonably require accessible routes to all the elements, towers and platforms, but not have the towers and platforms themselves be accessible?????


----------



## brudgers (Oct 19, 2010)

Yankee said:
			
		

> Again, there are many disabilities and don't constrain yourself to thinking only of wheelchairs. A legally blind person could ride a zip line with no equipment to haul around and need to navigate the intermediate elements, and probably lots of other disabilities that I can't think of also.


Of course there are other disabilities, but the major design issues are largely related to mobility impairments...in other words, blind people can use stairs, high urinals, small stalls, etc..


----------



## brudgers (Oct 19, 2010)

righter101 said:
			
		

> While the owner/applicant states that a rider would not be allowed to start mid way through the tour, it would be reasonable to surmise that should someone be unable to continue or unwilling to continue, they would be permitted to exit the tour and make their way back to the parking lot.


You can't exit a roller coaster mid ride.

More or less, a person leaving in mid-ride is being rescued because they are in distress.



			
				righter101 said:
			
		

> In that context, I am leaning towards making accessible routes to all load and unloading points required.


Despite being able to cite a specific code requirement, of course. You had already made up your mind.

Your decision should be based on the design presented, not the way you wish things were if only accessboard.gov were incorporated into the code by reference.

All you're doing is fishing for excuses to deny.


----------



## mark handler (Oct 19, 2010)

Some in wheelchairs have extreme upper body strength. They need to get there.


----------



## righter101 (Oct 19, 2010)

brudgers said:
			
		

> You can't exit a roller coaster mid ride. More or less, a person leaving in mid-ride is being rescued because they are in distress.
> 
> Despite being able to cite a specific code requirement, of course. You had already made up your mind.
> 
> ...


I don't have my mind already made up and I am not "fishing for excuses to deny".  I am trying to enforce the building code and not violate any federal civil rights that have been granted to disabled people.

I would agree with the "mid ride" exiting.  That is why I put this up for discussion, to hear all points of view.

Can we make this really simple Brugers, tell me what you would do.  What level of accessibilty would you require??  That might be eaiser for me to get your point of view rather than have you assume, incorrectly, things about my motives and intent.

I think your point about mid ride exiting is very valid and worth considering.  I don't have my mind already made up.  I am trying to make it up now and I am willing to listen to every point of view.

The applicant is on one end of the spectrum, basically wanting to make nothing accessible and just offer this ride to only fit, fully ablebodied persons.  I find this unacceptable.

The buidlng code states that all sites and elements within the site must be accessible.  This seems quite cut and dry.  It would be in most applications.

I believe, reasonably, that this is one of those grey areas in the code.

WWBD??

What would brugers do??


----------



## righter101 (Oct 19, 2010)

One other note about leaving the ride mid way through, it may not necessairly be distress.  Some people may be perfectly ok with flying through the forest canopy on zip lines, 50 feet off the ground.  What happens when they get off at the tower, climb down, and realize that the next segement of the zipline goes over a lake??  They were unaware of this and have a real fear of being above the water.  No way are they going to continue.  They are not needing to be rescued, they just can not continue.  The reasons for not continuing are not always distress.

As far as not being able to "exit a roller coaster mid ride", Brugers, you are absolutely correct.  This, however is not a roller coaster.  It is unique.


----------



## brudgers (Oct 19, 2010)

Imagine if there were spiders. A person might be afraid of spiders.

Imagine if there were foreigners. A person might be afraid of foreigners.

Lake, spiders, foreigners. The person is leaving because they are in distress.

I take that back. No person is actually leaving. We are just imagining they are.

If we stick to reality, then we approve the plans or find an actual specific section of code.


----------



## mjesse (Oct 20, 2010)

This discussion makes me appreciate international vacations all the more..







I enjoy traveling outside the U.S. and participating in all the "unsafe" and "un-accessible" activities.

My wife and I always get a laugh saying "We'd never allow _this_ back home!"

Although, here is one in Branson, MO. that doesn't look very accessible http://www.bransonzipline.com/photoGallery.cfm


----------



## Yankee (Oct 20, 2010)

. . . . railings?


----------



## brudgers (Oct 20, 2010)

We don't need no stinkin' railings.


----------



## Mech (Oct 20, 2010)

That's why they have harnesses! :lol:


----------



## righter101 (Oct 20, 2010)

Modification letter

Here is what I ended up with for the modification request.  Feedback is appreciated.  Applicant information has been omitted.

October 20, 2010

To:	(****)

Re:	Modification request dated October 11th, 2010

                Permit # TPN  (****)

I have received your request to modify some of the accessibility requirements as they pertain to the “Zip Line Tour” constructed under the permit listed above.

Discussion:

This permit was issued under the 2006 International Building Code and the tour was classified as an “A5” occupancy, the designation given to amusement rides.  Your submitted letter confirms this project is indeed an amusement ride, based on definitions found in the WAC.

The accessibility requirements are scoped in Chapter 11 of the 2006 IBC, specifically:

1103.1 Where required. Sites, buildings, structures, facilities,

elements and spaces, temporary or permanent, shall be accessible

to persons with physical disabilities.

1104.2 Within a site. At least one accessible route shall connect

accessible buildings, accessible facilities, accessible elements

and accessible spaces that are on the same site.

These sections have listed exceptions to the accessibility requirements; however, none of the listed exemptions could be reasonably applied to this project.

Using the United States Access Board (www.access-board.gov), a federal agency whose function is to provide technical guidance on accessible design and enforcement of accessibility standards, we find a section on amusement rides.

The USAB offers the following guidelines for accessibility:

Exceptions

There are four types of rides that are not covered by the guidelines. However, other ADA requirements still apply. The four types are:  (1 thru 3 omitted)

•	#4 Rides that do not have seats must only provide an accessible route to the load and unload areas and a turning space in the load and unload area.

Conclusion:

The loading and unloading for each segment of the ride is considered an “accessible element”, and as required by IBC 1104.2, shall be provided with an accessible route.

Using the IBC and the USAB guidelines for amusement rides, an accessible route to the load and unload areas and a turning space in the load and unload areas shall be provided.  Your request for modification is hereby denied.

The proposed “Zip Line Tour” will require the following items for compliance:

1)  Complete and submit a revised site plan showing what is actually being built (per inspector request dated 8-16-10)

2)  Provide details (on revised drawings) showing accessible routes to be provided between load and unload areas of the ride.  If a zip line terminates in a location that requires walking, hiking, or otherwise traversing the site, an accessible route will be required between the unloading (termination of one segment) and the loading (start of the next segment).

3)  The towers, ramps, ladders, and other elements necessary for the zip line will require an accessible route to them as well as the turning space as noted in the USAB guidelines.

4)  Technical specifications and provisions for “accessible route”, “turning space”, “accessible parking”, and all other accessible elements of this project shall be constructed in accordance with the ANSI A117.1-2003 Standard for Accessibility.

5)  Previously noted accessible elements, including but not limited to accessible parking and accessible restroom facilities, shall continue to be required.

6)  Upon completion of all elements of the permit, contact (****) County for an inspection to verify compliance.  All work will be subject to inspection, approval and possible correction.

7)  Prior to inspection, a copy of the operation manual for the facility shall be provided to (****) County for review.

Sincerely,

John (****)

Deputy Building Official, (****) County

(****)


----------



## JBI (Oct 20, 2010)

What if there were spiders AND it was a roller coaster???? Lions and tigers and bears OH MY! Ben, you're killing me...

righter, good letter with appropriate Code sections provided. Too bad you don't have a Board of Review to bring this to...


----------



## brudgers (Oct 22, 2010)

JBI said:
			
		

> What if there were spiders AND it was a roller coaster????


Depends. Are there any Foreigners?


----------



## Rick18071 (Oct 22, 2010)

If the zip-line starting point is raised to a higher level above grade I would use these exceptions:

1104.4 At lest one accessible route shall connect each accessible level, including mezzanines, in multilevel buildings and facilities.

Exceptions:

 1. less than 3,000 ft. located above or below accessible levels.

                 2. Levels that do not contain accessible elements or other spaces as determined by sections 1107 or 1108 are not                                                                       r                    required to be served by an accessible route from an accessible level.

1107 deals with dwellings and sleeping units

1108 deals with assembly, self-service storage, and judicial facilities.


----------



## AegisFPE (Oct 22, 2010)

I think their rock climbing wall analogy seems reasonable, based on 1109.14.4.5 which does not require accessibility for raised diving platforms.

It seems a zipline platform could also be considered like a raised diving platform.

However, because the code does not specifically address it, maybe you are waiting for your applicant to make that statement, which you could approve, rather than giving them the design approach.


----------



## mtlogcabin (Oct 22, 2010)

ADAAG

"The scoping and technical provisions of the guidelines were developed to address common amusement rides. There will be other amusement attractions that have unique designs and features which are not adequately addressed by the guidelines. In those situations, the guidelines are to be applied to the extent possible."



> Question: using the scoping provisions of the IBC Ch. 11, what would you require to be accessible. I have a no brainer of the parking, accessible restrooms at the parking lot, accessible path to the start of the ride... beyond that??[/QUOTE]Nothing


----------



## brudgers (Oct 23, 2010)

You guys are not helping.

The goal was to find reasons to disallow it, not to follow Milton's Rule.


----------



## Rick18071 (Oct 25, 2010)

Would anyone make ski slopes, lifts, and T-bars accessable?

Did a zip-line myself. You had to walk half way up a ski slope to the platform at the start. Since there was no parking, public transportation stop, passsenger loading zone, public street or sidewalk (1104.1) on the ski slope there was nothing to run an accessible route from.


----------



## Yankee (Oct 25, 2010)

Rick18071 said:
			
		

> Would anyone make ski slopes, lifts, and T-bars accessable?Did a zip-line myself. You had to walk half way up a ski slope to the platform at the start. Since there was no parking, public transportation stop, passsenger loading zone, public street or sidewalk (1104.1) on the ski slope there was nothing to run an accessible route from.


http://www.beneficialdesigns.com/skiaccess/skiaccess.html#ADAski


----------



## brudgers (Oct 25, 2010)

Max slope for accessible skiing is 1:12 with a landing every 30 feet...

...and at each change in direction.


----------



## Rick18071 (Oct 25, 2010)

Yankee - I don't enforce civil right laws like ADA, only building codes (IBC and ANCI 117.1)


----------



## Yankee (Oct 26, 2010)

Rick18071 said:
			
		

> Yankee - I don't enforce civil right laws like ADA, only building codes (IBC and ANCI 117.1)


That wasn't the question, the question was "Would anyone make ski slopes, lifts, and T-bars accessable?". That's the question I answered.


----------

