INTERPRETIVE OPINION

Pursuant to §103-50, Hawaii Revised Statutes (HRS), all buildings and facilities constructed by, or on behalf of the State or any county, shall conform to the Americans with Disabilities Act Accessibility Guidelines (ADAAG) and amendments. In accordance to HRS §103-50 and Chapter 11-217, Hawaii Administrative Rules, the Disability and Communication Access Board has authority to issue interpretive opinions to HRS §103-50 design standards.

Docket: DCAB 2006-02: What is the minimum clearance at a door to allow a front approach, when the prominent approach to the door is a side approach? When is front approach required rather then optional?

Summary: The ADAAG Section 4.13.6 Maneuvering Clearance at Doors and Figure 25 specifies the minimum dimensions for front and side approach to a door. However, the ADAAG does not clarify when front approach door maneuvering clearance could be used in lieu of side approach door maneuvering clearance. For example, a front approach to a door in a corridor with a predominant side approach may be allowable when the corridor has adequate width. An analysis was conducted in an attempt to determine the minimum accessibility requirements to allow front approach to a door with a predominant side approach. Based on the analysis, a front approach to a door not in an alcove with a predominant side approach appears to be accessible when a turning space is provided at the door and an accessible route adjoins the front edge of the door maneuvering clearance. This requirement appears to provide adequate space to approach, open, and maneuvering through the door, and does not appear to lessen or conflict with a guideline adopted under HRS §103-50.

All doors in alcoves shall comply with the clearances for front approaches, as noted in the ADAAG Figure 25. Based on the analysis described above, front approach to a door in an alcove appears to be accessible when an accessible route adjoins the front edge of the door maneuvering clearance. Turning space is not required at a door in an alcove. This requirement appears to provide adequate space to approach, open, and maneuvering through the door, and does not appear to lessen or conflict with a guideline adopted under HRS §103-50.

Ruling: For buildings or facilities subject to HRS §103-50,

ADAAG Section 4.13.6 Maneuvering Clearances at Doors

Doors with a predominant side approach are allowed to comply with front approach door maneuvering clearances when a turning space is provided at the door and an accessible route adjoins the entire front edge of the door maneuvering clearance. All doors in alcoves shall comply with front approach door maneuvering clearances and shall have an accessible route adjoining the entire front edge of the door maneuvering clearance.

[Rul: 9/27/2006] (Auth and Imp: HRS §103-50)

If you have any questions or comments regarding this ruling, please call us at 586-8121.

DISABILITY AND COMMUNICATION ACCESS BOARD

919 Ala Moana Blvd. Honolulu, HI 96814

Phone: (808) 586-8121 (V/TTY)

Fax: (808) 586-8129