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An accessibility checklist for reopening a renovated public building is a documented walk against the 2010 ADA Standards, the applicable alteration rule, and the building codes your jurisdiction adopted—not a single Department of Justice form. If construction started on or after March 15, 2012, the altered work is designed to the 2010 Standards. When the renovation changes a primary-function area, the connected path of travel must also be upgraded to the maximum extent feasible, with a 20% disproportionate-cost limit and a defined spending priority.
What standard governs a reopening now?
First identify who operates the facility and when physical construction began. A state or local government building is generally covered by Title II (28 CFR 35.151); a privately owned place customers or visitors enter is generally a Title III place of public accommodation (28 CFR 36.402 and 36.403). Both use the 2010 ADA Standards for new construction and alterations that started on or after March 15, 2012. The U.S. Department of Justice describes those Standards as the minimum scoping and technical requirements for facilities to be readily accessible and usable by people with disabilities (2010 ADA Standards).
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- Work begun before September 15, 2010 may be governed by the 1991 Standards or UFAS.
- Work begun from September 15, 2010 through March 14, 2012 could use the 1991 Standards, UFAS, or the 2010 Standards.
- Work begun on or after March 15, 2012 uses the 2010 Standards. Razing a structure or ceremonial groundbreaking does not, by itself, start physical construction.
The 2004 ADA Accessibility Guidelines appendices adopted into the 2010 regulation control for DOJ-regulated facilities; later Access Board revisions do not become the federal reopening standard until DOJ adopts them. A newer Access Board guideline can be useful design information, but it is not a substitute for the adopted regulation.
Keep ADA compliance separate from permitting. ICC A117.1 and the International Building Code apply as your state or locality adopts them. A permit can issue while a project still violates the federal ADA. Where the adopted code is stricter, such as an additional vertical grab bar or a family toilet room in certain assembly and mercantile occupancies, design and inspect to the stricter requirement as well. Confirm the edition your jurisdiction has adopted rather than assuming a national edition.
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When does a renovation trigger a path-of-travel upgrade?
An alteration that affects, or could affect, usability or access must make the altered portion accessible to the maximum extent feasible. If the work alters an area containing a primary function—a major activity for which the facility exists—the path of travel to that area must also be upgraded, unless the additional work is disproportionate. Examples include a cafeteria dining area, conference-center meeting rooms, public-service offices, and a bank customer-service lobby. Corridors, entrances, mechanical and boiler rooms, storage, janitorial closets, employee lounges, and ordinary restrooms are not primary-function areas (a restroom can be primary where providing restrooms is the facility’s purpose, such as a highway rest stop).
The path of travel is the continuous, unobstructed pedestrian route from an exterior approach, sidewalks, streets and parking, through an entrance, to the altered area and the rest of the facility. It includes walks, curb ramps, ramps, clear floor paths, elevators or lifts, and the restrooms, public telephones and drinking fountains serving the altered area.
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A free scan shows the junk files, broken settings and background clutter dragging Windows down - then fixes them in one click.Free scan · Windows 10 & 11The 20% rule is narrow: path-of-travel work is deemed disproportionate when its cost exceeds 20% of the cost of the alteration to the primary-function area (28 CFR 35.151(b)(4)(iii)(A)). It is not a waiver for the renovated room itself. Make the altered room compliant to the maximum extent feasible, then spend path-of-travel dollars in this order:
- An accessible entrance.
- An accessible route to the altered area.
- At least one accessible restroom for each sex, or one unisex restroom when only unisex rooms are provided.
- Accessible public telephones.
- Accessible drinking fountains.
- When possible, parking, storage and alarms.
Record the primary-function construction cost, every path-of-travel item and cost, and the calculation before reopening. The project cannot evade the rule by splitting one undertaking into small contracts. If related primary-function alterations occurred on the same path during the preceding three years, aggregate alterations undertaken on or after March 15, 2011, when testing disproportionality.
Title II’s path-of-travel provision applies only to alterations undertaken for purposes other than meeting program-accessibility obligations under §35.150. Have counsel or the public entity’s ADA coordinator address that cross-reference rather than assuming the 20% calculation applies in every Title II project.
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Does the 1991 safe harbor excuse existing features?
Only in limited circumstances. Title II protects path-of-travel elements constructed or altered to the 1991 Standards or UFAS before March 15, 2012 from incremental 2010 upgrades solely because a primary-function area is later altered. Title III’s parallel rule refers to elements built or altered to the 1991 Standards and does not repeat UFAS or the March 15, 2012 wording. The Northwest ADA Center’s 2014 checklist explains the practical element-by-element approach: an element that complied with the 1991 Standards need not be changed merely for a later 2010 difference, but altering that element ends its safe harbor. Elements not covered by the 1991 Standards do not receive this protection. Do not design new work to the 1991 rules.
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How should the reopening walk check arrival routes and surfaces?
Walk every site arrival point: accessible parking, passenger loading, public sidewalks and streets, and each public-transportation stop. At least one accessible route must connect those points to an accessible entrance, and an interior circulation path must remain interior. A site reached only by a vehicular way with no pedestrian access does not require a pedestrian route; a parking lot intended for pedestrians does.
- Route width is 36 inches minimum continuously. A 32-inch narrowing is allowed for no more than 24 inches.
- Provide a 60-by-60-inch or T-shaped passing space at least every 200 feet. A 180-degree turn around an obstruction narrower than 48 inches needs 48 inches at the turn and 42 inches approaching it, unless the turn itself is 60 inches clear.
- Walking surfaces, egress stairs, parking spaces, aisles and loading zones must be stable, firm and slip resistant. The Standards set no coefficient-of-friction number; specify a surface that remains slip resistant in expected conditions and maintain coatings.
- Carpet pile is no higher than 1/2 inch to the backing, cushion or pad. Fasten it against buckling and trim exposed edges securely.
- Grates and openings reject a 1/2-inch sphere; elongated openings run perpendicular to travel.
- A change up to 1/4 inch needs no edge treatment; up to 1/2 inch must be beveled no steeper than 1:2. Higher changes require a ramp, curb ramp or walk at no more than 1:20.
Common-use circulation paths inside employee work areas of 1,000 square feet or more (measured to permanent walls, partitions, counters, casework or furnishings) must be accessible. Smaller or weather-exposed work areas still need an accessible approach, entrance, exit and means of egress under the applicable building code.
What ramp and curb-ramp measurements must pass?
Any running slope steeper than 5% is a ramp. Use a uniform running slope no steeper than 1:12, cross slope no steeper than 1:48, 36-inch clear width, and no more than 30 inches of rise per run. Level landings are required at the top and bottom and at direction changes; a turning landing is at least 60 by 60 inches. Handrails are required on both sides when rise exceeds 6 inches, are 34–38 inches high, continuous and non-abrasive, and need edge protection.
There is no total ramp-length limit, but long multi-run ramps can be strenuous. In alterations, a top landing that cannot fit may require compliant side flares. Built-up curb ramps cannot project into parking spaces, aisles or traffic lanes; diagonal ramps need a 48-inch bottom clear space and a 24-inch curb segment beyond each flare. Detectable warnings are required at transit facilities covered by Department of Transportation standards, not automatically at every DOJ-only curb ramp. Check the governing transportation standard for a public sidewalk or transit project.
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Are entrances, doors and security systems ready?
In new construction, at least 60% of public entrances must be accessible, in addition to entrances serving parking, pedestrian tunnels, elevated walkways and individual tenancies. In an alteration, provide an accessible entrance when an existing entrance is altered without a compliant alternative, when an entrance is added, or as required for the path of travel. A qualified historic building may use a non-public entrance only when the State Historic Preservation Official or Advisory Council determines that a public entrance would threaten historic significance; a locked alternative needs notification or remote monitoring.
- Security bollards, screening and queue equipment cannot obstruct the route or accessible egress. A person diverted around a metal detector must retain an equivalent view of personal belongings.
- Two-way communication systems at every entrance, including inaccessible ones, need audible and visible signals; handset cords are at least 29 inches. Operable parts at accessible entrances meet the reach and force rules.
- At least one door, doorway or gate at each accessible room, space and entrance must provide the required clear width. Confirm the 32-inch minimum clear width at 90 degrees in the adopted Standards text before recording a field result.
- Hardware operates with one hand, without tight grasping, pinching or twisting, at no more than 5 lbf; operable parts are 34–48 inches high. Round knobs generally fail because they require twisting.
- Interior door opening force is 5 lbf maximum; fire doors use the minimum force allowed by code, and no maximum is specified for exterior hinged doors. Retract the latch, place a gauge about 2 1/2 inches from the latch edge, push slowly perpendicular to the face, and remove it at 70 degrees, following the Access Board measurement method.
- New thresholds are 1/2 inch maximum; altered thresholds may be 3/4 inch maximum when beveled 1:2 on both sides. Doors in series have at least 48 inches plus the width of a door swinging into the space. Keep the 10-inch bottom push side smooth and maneuvering clearances free of furniture and level changes.
When is vertical access required?
Title II and Title III have different story exceptions. A government building generally needs an accessible route between stories; the exception is a building of no more than two stories where the other story has no public-use space and an occupant load of five or fewer. Title III facilities under three stories or under 3,000 square feet per story may omit an inter-story route, except for shopping centers or malls with five or more sales or rental establishments, professional health-care offices, and public-transit facilities or airport terminals. A mixed-use building loses the exception on any story whose occupancy does not qualify.
Adding a stair or escalator where none existed, with major structural modification, separately triggers a route to every level it serves unless a compliant route is already present. Stories excluded from vertical access still meet all other Standards.
How do you verify parking and loading?
Count each parking facility separately, including employee and restricted lots. At least one of every six accessible spaces, or fraction of six, is van accessible. Van spaces add 3 feet of width, may share an aisle, and require 98 inches of vertical clearance from space through route to an exit. The basic table is:
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|---|---|---|
| 1–25 | 1 | 1 |
| 26–50 | 2 | 1 |
| 51–75 | 3 | 1 |
| 76–100 | 4 | 1 |
| 101–150 | 5 | 1 |
| 151–200 | 6 | 1 |
| 201–300 | 7 | 2 |
| 301–400 | 8 | 2 |
| 401–500 | 9 | 2 |
Facilities over 500 spaces use the continuing federal table; verify the footnotes before applying larger rows. Hospital outpatient facilities need accessible patient and visitor parking equal to at least 10%; qualifying rehabilitation and outpatient physical-therapy facilities need at least 20%. Other medical offices use the ordinary table.
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Place spaces on the shortest accessible route to an accessible entrance and disperse them when parking serves multiple entrances. A garage and surface lot are separate facilities. Signs show the International Symbol of Accessibility; van spaces also say “van accessible.” Mount signs at least 60 inches to the bottom edge. Pavement symbols never replace signs. Valet operations still need accessible spaces and a passenger loading zone. Mechanical stacker garages need a loading zone even though they need not provide spaces. The 2010 Standards do not set an electric-vehicle charging ratio.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What must the restroom, telephone and fountain inspection cover?
The ADA does not determine how many toilet rooms a building must have; plumbing and building codes do. It determines which provided rooms are accessible. In new construction, employee rooms count, and at least half of each clustered group of single-user rooms must comply. Portable single-user units provide access to at least 5% of each cluster; construction-worker units are exempt.
For a primary-function alteration, provide at least one accessible restroom for each sex, or one unisex room where only unisex rooms are provided. An accessible unisex room normally cannot substitute for inaccessible multi-user rooms unless technical infeasibility is documented; it must be on the same floor and in the same area. A single-user room has a privacy latch and no more than one lavatory, one water closet and one urinal (or a second water closet instead of the urinal).
- Turning space is a 60-inch circle or T-shaped space.
- Grab bars beside and behind the water closet are rigid, do not rotate, and resist 250 pounds. Maintain the exact 1 1/2-inch wall gap.
- Do not let a lavatory overlap the water-closet clearance (except in residential dwelling units). Dispensers must allow continuous paper flow, must not control delivery, and outlets cannot exceed 48 inches.
Technical infeasibility is narrow: structural or site constraints make full compliance have little likelihood of being accomplished. Combining compartments can be infeasible if fixture counts would fall below plumbing code, but maximum feasible access is still required. A partial alteration brings only altered elements under the rule; a complete gut brings the entire room under it. Check the adopted IBC as well: some assembly and mercantile occupancies trigger an accessible family or unisex room when six or more fixtures are required. The extracted official guide did not confirm a toilet-seat height number, so do not insert one from memory.
Where public telephones or drinking fountains serve the altered area, inspect them after restrooms and before lower-priority items. Relocation of an inaccessible fountain is an eligible path-of-travel cost.
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What should the final reopening checklist record?
- Project file: construction-start date, Title II or III status, primary-function areas, safe-harbor elements, three-year alteration history, cost calculation, historic determinations and technical-infeasibility findings.
- Entrance: accessible arrival route, unobstructed security equipment, communication signals and any monitored historic alternative.
- Route: slopes, widths, surfaces, openings, passing spaces, ramps, landings, handrails, interior routing and vertical access.
- Restrooms: required rooms, turning space, clearances, grab bars, dispensers and same-floor unisex solution where justified.
- Telephones and fountains: clear floor space, reach, volume or TTY features where applicable, and fountain accessibility.
- Parking: count by facility, van ratio, aisle and clearance, shortest route, signs, loading and specialty medical percentages.
- Doors: clear width, hardware height and force, opening force measurement, thresholds, maneuvering clearances and door-series spacing.
- Altered rooms: counters, doors, turning areas and every replaced element meet the 2010 Standards to the maximum extent feasible.
- Leftovers: remove loose gravel, unsecured carpet, parallel grates, water-holding landings, over-tight closers, desk-mounted parking signs and furniture in clearances. Confirm elevators or lifts are operational on opening day.
Retain photographs, field dimensions, gauge readings, invoices and corrective-action dates. The record should show not only what passed, but why a limit was used and what work was prioritized when the 20% cap applied.
What is the difference between an ADA checklist and a barrier-removal checklist?
The older DOJ Checklist for Readily Achievable Barrier Removal is a guide for existing facilities under the ADA Accessibility Guidelines. It is not the alteration standard for reopening a renovated building. Use the 2010 Standards and the applicable Title II or III alteration regulation for new work; use barrier-removal analysis separately for pre-existing barriers that are not being altered.
Does a building permit mean the renovation meets the ADA?
No. A permit shows compliance with the adopted building code process, not a federal civil-rights determination. Compare the permit set and field conditions to the 2010 Standards, then resolve any stricter state or local code items. When a conflict appears, document the governing provision and obtain accessibility expertise before opening.
Frequently Asked Questions
Is the path-of-travel limit always exactly 20%?
The 20% disproportionate-cost test applies to path-of-travel work tied to a primary-function alteration under the cited alteration rule. Title II projects undertaken solely for program accessibility under §35.150 are treated separately, so confirm the project purpose before applying the cap.
If there is no sidewalk onto the site, must the owner build an accessible route?
Not where the only arrival is a vehicular way with no pedestrian access. If the vehicular way is intended for pedestrians, such as a shopping-center parking lot, an accessible route is required from that arrival point.
What slip-resistance coefficient does the ADA require?
None. The Standards do not publish a minimum coefficient because no consensus rating method exists. Specify a stable, firm, slip-resistant surface for expected conditions and maintain it.
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Can an accessible unisex restroom replace inaccessible multi-user rooms?
Only in limited alteration situations where making the multi-user rooms compliant is technically infeasible. The unisex room must be in the same area and on the same floor, and the file should explain the structural or site constraint and the access provided to the maximum extent feasible.
Are detectable warnings required on every curb ramp?
No. DOJ building standards require them at transit facilities covered by Department of Transportation standards, while other sidewalks may follow different transportation or public-right-of-way requirements. Check the standard governing that particular site work.
