A Brief Overview of the ADA Standards
The ADA (Americans with Disabilities Act) is a federal law that was enacted in the United States in 1990. The purpose of the ADA is to ensure that people with disabilities have the same rights and access as those who do not have disabilities, in all areas of public life including jobs, schools, transportation and all public and private places that are open to the general public. Under the ADA there are five sections, known as titles, that cover general prohibitions on disability discrimination (Title I), the delivery of health and other services (Title II), telecommunications (Title III) and public accommodations and commercial facilities (Title IV) . The ADAAA (ADA Amendments Act) 2008 amended the ADA in 2008 to expand the definition of individuals with disabilities and protect even more individuals with a variety of conditions.
Title III of the ADA requires public accommodations to follow specific standards regarding accessibility design. The general rule is that a public accommodation, like a private retail store, must comply with the 2010 Standards for Accessible Design in Public Accommodations and Commercial Facilities, as well as the 1991 Standards when possible. Compliance with these standards and the ADA in general is required for businesses that are considered "public accommodations" and considered to operate "public areas" like fitting rooms and restrooms. Fitting rooms in retail stores are considered "public areas."
Fitting Room Dimensions Under ADA Rules
There are two sets of requirements for the dimensions of fitting rooms to be accessible. First, there is a minimum size requirement for fitting rooms, including turning space and door width. If a fitting room is more than 1,000 square feet, then it must comply with the minimum requirements for a handicapped restroom under the California Building Code. Second, even if a fitting room complies with the minimum size requirements, it might not be sufficient if it provides inadequate maneuvering clearance for a person using a wheelchair. Notice that the only minimum requirement for the width of a fitting room is 30 inches. Most fitting rooms would meet this requirement. So what are the other dimensions? The minimum requirement for a fitting room is 5′ x 5,’ or 25 square feet. The minimum turning space is 5′ radius, which is why the fitting room would behave as a 5′ x 5′ square.
Fitting Rooms – Accessibility and Features of Fixture and Furniture
In addition to the accessible route, transfer and maneuvering space requirements, fitting rooms also have requirements for fixtures and furniture. These requirements are provided at Section 803.2 of the 2010 ADA Standards. In fitting rooms that have seats, at least one seat must be provided in each family or assisted or unassisted stall, and the seat must be a fold-down (versus a built-in) seat. The toilet seat must be either high-rise (18" above the floor) or the seat used must be a [raised] toilet seat.
Fitting rooms must be provided with mirror in accordance with Section 307 of the 2010 ADA Standards and Advisory Technical Appendix C. Fitting room mirrors may not exceed 36" above the floor. At least one grab bar meeting the requirements provided at Section 610 must be provided for unassisted stalls in all fitting rooms that provide a toilet seat. Where a seat is provided, it must meet the height requirement to be clear of the grab bar. Where seats are provided, directional signage must be provided at the entry door to communicate that the seat is available.
Fitting Rooms – Signage, Symbols, and Displays
Avoiding the hassle of an enforcement action or a private plaintiff lawsuit can involve simply having correct signage in and around the fitting room. For example, what vanities need to be marked with Braille? If a store has a handicap door opener for the fitting room, must it be marked to show the maximum allowable force to activate it? These and other signage questions are addressed throughout our ADA Title III Manual.
Fitting Rooms – Lighting and Safety Requirements
The ADA also includes language that requires fitting rooms to have general lighting so that merchandise can be seen. The source of this general lighting must be a permanent fixture(s), because portable lamps and other like items cannot be relied upon as permanent. Fitting rooms are also required to provide a fixed object such as a mirror to make the entrance visible from the inside , so one can see when someone is trying to enter, and to provide a safety feature such as a hook, a call button, or a staff assist cord, to summon help if necessary. Any fixtures or features that assist in providing safety must not reduce the clear floor space and turning space.
Fitting Rooms – Common Design Mistakes
Failure to ensure a 36-inch wide accessible entrance path.
Making fitting rooms no deeper than 48 inches when they have accessible entrances that are not more than 32 inches wide.
Failing to ensure that there is a 60-inch turning radius in any fitting rooms that measure less than 4 feet wide.
Positioning grab bars too far from the wall or in non-compliant locations.
Installing redundant controls in fitting rooms that operate all fixtures and controls only from one side of the space, despite the accessible car being on the opposite side.
Installing inaccessible fixtures in reachable spaces.
Failing to provide the right number of accessible features and controls in fitting rooms (e.g. sinks, toilets).
Not integrating the controls for everything in the fitting rooms (lights, doors, mirrors, etc.) into a "single user" feature.
Failing to install hinged doors in fitting rooms that are inaccessible to wheelchair users.
Failing to install power-operated doors in fitting rooms that have swinging doors and fewer than 4 fixtures, fittings and elements (including sinks, toilets, baby changing stations, and grab bars).
Fitting Rooms – Tips and Steps for Easy Compliance
The Department of Justice regulations require fitting rooms to be accessible. The focus of the following commentary is on practical steps a business can take to ensure that its fitting rooms are accessible.
Accessible fitting rooms. Accessible fitting rooms must be located in the same area as sales and rental counters. Additionally, if you have multi-person dressing rooms, at least one must be accessible. Showers with changing tables are also to be accessible. Audits. The first step to ensuring compliance is for your business to audit fitting rooms to determine whether they comply with ADA requirements . The Audit must identify areas that need to be adjusted or changed to ensure compliance. Auditing more than just the fitting rooms is a prudent practice as it can help ensure that issues that may impact fitting rooms are addressed. Training. Once an Audit has been conducted, and necessary changes made, training is critical to maintaining compliance. All employees should be trained in fitting room policies, procedures, and how they are expected to provide assistance to customers with disabilities. Training on these topics should be ongoing.