27-year member: Sealant Waterproofing
and Restoration Institute.
What
is SWRI?
"Beware the naked man who offers you his
shirt," says businessman and author Harvey
Mackay.
Likewise, beware the manufacturer who claims his products are "ADA Approved". ADA is an "Act", a law,
administered by the Civil Rights Division of the US Department of
Justice. They don't approve anything. They do publish
standards for accessible design. According to the administering
department, "The
ADA Standards for Accessible Design, or the “ADA Standards,” refer to
the requirements necessary to make a building or other facility
architecturally (physically) accessible to people with disabilities."
ADA, Spiked-Heels, & Expansion Joints: Where do you stand?
We
are often asked to comment on the suitability of our materials as they
relate to Americans with Disabilities Act (ADA) Standards For Accessible
Design.
Sometimes we are asked to comment on our materials' suitability to
small-footprint-spiked-heel traffic as it relates to ADA.
First of
all, let's separate the two issues. The behavior of a joint system
under high-heel traffic conditions is a separate matter altogether and has no
relationship to
ADA.
Now
let's consider the two issues independently--first in summary and then
if you would like further detail, read beyond the summary.
SUMMARY
1) ADA and Expansion Joints:
ADA only
applies to joints that cut through an “Accessible Route”. An Accessible
Route is a clearly identified route of access and egress at a structure
that must be compliant with ADA standards for accessible design.
This means that if a joint
in the middle of a parking deck is 100-feet away from the nearest
designated accessible route—then ADA does not apply to the expansion
joint or the material installed into the joint opening.
If an
expansion joint does traverse a designated Accessible Route, then ADA guidelines
apply. If the joint opening itself is in compliance with the
aspect(s) of ADA standards applied interpretively to expansion joints
and it is sealed with a joint system then the joint system must comply
with ADA in the same interpreted aspects.
That
being said, it is not unreasonable to apply the interpreted ADA provisions
of elevation changes to expansion joints regardless of their location.
In this regard the systems offered by EMSEAL for this use comply with these
interpretations as defined in our conversations with ADA Accessibility
Specialists.
2)
Small-Footprint-Spiked-Heel Concerns:
As
stated before, concerns about a traffic surface or joint sealant’s
suitability to high-heel traffic are totally unrelated to ADA.
The personal preference of a pedestrian to wear small-footfprint-high-or-spiked heels is not a disability under ADA
or any other law of accommodation. Pedestrians make their wardrobe
selections fully aware of
the risks posed by the choice.
Any
expansion joint material must, by nature, be able to accommodate
movement while maintaining watertightness. In order to accommodate
movement, a material must either be pliant and able to stretch and
compress, or can be more rigid but of a geometric design to accommodate
movement through an "accordion" motion of folding and unfolding or
through a suitable mechanical motion.
Either
way the resulting product leaves a surface that cannot be considered
absolute proof against the possibility of pedestrian injury in the same
way that no surface intended for walking is absolutely free of hazards.
Mortar or caulk joints in concrete sidewalks, brick, stone or composite pavers, drainage grates, door
thresholds, slick or highly polished floors, to name a few all pose
possible hazards and must be expected to be treated with suitable
judgment by pedestrians in respect of their attire and ability to
traverse the surface.
ADA
Compliance and Pedestrian Suitability in More detail:
1) ADA COMPLIANCE
In November of 1993 in lengthy conversations with an Accessibility
Specialist at the US Architectural & Transportation Barriers Compliance
Board, EMSEAL clarified the Board's position with respect to
expansion joints in respect of the Accessibility Guidelines for
Buildings and Facilities component of the Americans with Disabilities
Act (ADA).
In April of 1997 in further conversations with same, this understanding
was confirmed and it was further verified that no changes have been made
to the Act in respect to expansion joints and that in the pending major
revision to the guidelines no changes specific to expansion joints are
being made.
In January of 2007, a further search of the latest revision to the
document "ADA Standards For Accessible Design, July 1, 1994) shows no
specific reference to expansion joints.
There being no provision of the guidelines that pertains specifically to
expansion joints. The aspects of the guidelines therefore that are
applied to expansion joints are: 1) the relationship of expansion joints
to "Accessible Routes" 2) the guidelines for elevation changes.
1) "Accessible Routes", "Accessible Parking Spaces" and their
Relationship to Expansion Joints
An accessible route is defined in the guidelines as follows: "A continuous unobstructed path connecting all accessible elements
and spaces of a building or facility." "Exterior accessible routes may
include parking access aisles, curb ramps, crosswalks at vehicular ways,
walks, ramps, and lifts."
An accessible parking space is defined in the guidelines as follows: "Section 4.6.2 Location. Accessible parking spaces serving a
particular building shall be located on the shortest accessible route of
travel from adjacent parking to an accessible entrance. In parking
facilities that do not serve a particular building, accessible parking
shall be located on the shortest accessible route of travel to an
accessible pedestrian entrance of the parking facility. In buildings
with multiple accessible entrances with adjacent parking, accessible
parking spaces shall be dispersed and located closest to the accessible
entrances."
As confirmed in the discussion with the Accessibility Specialist, the
general assumption is that a parking garage patron with a disability
arrives in a vehicle, parks in an "Accessible Parking Space", and in a
short pedestrian activity uses the nearby "Accessible Route" to
move from the
parking deck to an adjacent structure or other destination.
In this typical scenario and in most parking garages, the structural
expansion joints are located at intervals in the deck that are in
distant enough from the accessibility area that they are never crossed
by patrons with disabilities and are therefore not subject to the
guidelines.
In this light, it is practical to consider the design of the deck such
that the high performance structural expansion joints don't come into
play in respect to ADA guidelines.
2) Guidelines for Elevation Changes
In locations where expansion joint do intersect accessible routes and
parking spaces, the only provision in the Standards that is applied is
that of "Changes in Level" and elevation changes at "Thresholds and
Doorways".
Changes in Level: "4.5.2 Changes in Level. Changes in level up to 1/4 in (6mm) may be
vertical and without edge treatment. Changes in level between 1/4 in and
1/2 in (13mm) shall be beveled with a slope no greater than 1:2. Changes
in level greater than 1/2 in (13mm) shall be accomplished by means of a
ramp that complies with 4.7 or 4.8."
Thresholds and Doorways: Section 4.13.8 Thresholds and Doorways . Thresholds at doorways shall
not exceed 3/4 in (19mm) in height for exterior sliding doors or 1/2 in
(13mm) for other types of doors. Raised thresholds and floor level
changes at accessible doorways shall be beveled with a slope no greater
than 1:2.
While blockout-mounted structural expansion joint systems are usually
utilized in the joints remote from accessibility areas, the THERMAFLEX
TM (double-cell) and TCR (multi-cell) systems are suitable also in the
cases where they do cross accessibility areas because they are in
compliance with the above guidelines.
II: PEDESTRIAN SUITABILITY of THERMAFLEX, DSM, MIGUTAN, and other
EXPANSION JOINT SYSTEMS
Expansion joint materials must, by nature, be able to accommodate
movement while maintaining watertightness. In order to accommodate
movement, the materials must either be pliant and able to stretch and
compress, or can be more rigid but of a geometric design to accommodate
movement through an "accordion" motion of folding and unfolding.
Either
way the resulting product leaves a surface that cannot be considered
absolute proof against the possibility of pedestrian injury in the same
way that no surface intended for walking is absolutely free of hazards.
Mortar or caulk joints in concrete sidewalks, brick, stone or composite pavers, drainage grates, door
thresholds, slick or highly polished floors, to name a few all pose
possible hazards and must be expected to be treated with suitable
judgment by pedestrians in respect of their attire and ability to
traverse the surface.
Metal coverplates, while sometimes considered a preferable alternatives
to softer materials, are generally selected for their ability to span
larger joints that cannot be bridged with system installed between the
joint faces. Regardless, they too cannot be considered proof against the possibility of slipping
or perhaps even tripping.