A tight space is in need of a ramp.  The problem is the ramp has two 45 degree turns without landings.  The 2013 CBC applies to this project.  We are considering allowing a hardship as long as the cross-slopes comply.  I've attached the drawing in question.  It appears the cross-slopes work on paper.  Any advice would be appreciated. 

     From CBC : 

     "IIB-405.7.4 Change in direction. Ramps that change direction between runs at landings shall have a clear landing 60       inches (1525 mm) minimum by 72 inches (1829mm) minimum in the direction of downward travel from the upper ramp run."

      An advisory from US Department of Justice states:

      "Advisory 11B-405.7 Landings. Ramps that do not have level landings at changes in direction can create a compound slope that will not meet the requirements of this chapter. Circular or curved ramps continually change direction. Curvilinear ramps with small radii also can create compound cross slopes and cannot, by their nature, meet the requirements for accessible routes. "


Original Post

Hi Laura, "We are considering allowing a hardship" leads me to believe that you are the AHJ. One person's opinion. The federal advisory is meant to address curved ramps or slight changes in direction, not 45 degree changes, certainly not 2 in succession. Looking back at prior standards for ANSI intent reveals that intermediate landing was previously based on changes of direction of 30 degrees, which is significantly less than 45, and as I allude, I think you are actually looking at a change in direction of 90 degrees here since they are juxtaposed.  Of course, I am ignorant of the details of the project and that makes a difference in the standard of care required.

The type of project may allow deviations from standards for other reasons (is it strictly barrier removal at existing site, or alteration, or new construction?). The standard of care for strictly barrier removal may allow deviations from standards if they are safe and there is a hardship. The standard of care for alterations and new construction are much higher and would allow such a deviation only in extremely rare circumstances. A federal 9th circuit appeal decision established that there is zero tolerance in new construction for deviation from standards. If this is new construction or an alteration, this is very dangerous ground for the owner if challenged, even if there is a hardship. Moreover, I can't see a hardship from the information provided. I am not addressing whether it is usable or not. different question, and one where the answer only matters if this is strict barrier removal at an existing facility. This may not be the answer you are looking for but I feel strongly about it. 

Neal, it was a very large casino hotel in Vegas. overturned on appeal and the builder had to replace all the doors in all the rooms due to noncompliant clear width, amounting to only a small deviation. We are talking 1000 doors.

 Between flights but will find it eventually and pass it on.

Found it -new orleans hotel. but using phone here, hopefully you can search it: 

nonprofit corporation,
Plaintiffs-Appellants- Nos. 99-16468
Cross-Appellees, 99-16497
D.C. No.
COAST RESORTS, INC., a Nevada CV-97-01570-RLH
corporation; COAST HOTELS AND
CASINOS, INC., a Nevada
corporation; COAST WEST, INC., a
Nevada corporation,
Appeal from the United States District Court
for the District of Nevada
Roger L. Hunt, Magistrate Judge, Presiding
Argued and Submitted
November 16, 2000--San Francisco, California
Filed October 3, 2001
Before: Alex Kozinski, Michael Daly Hawkins, and
Marsha S. Berzon, Circuit Judges.
Opinion by Judge Hawkins


1.  There appears to be adequate room for a rectangular 90 degree transition, but it would encroach slightly into what appears to be a setback from an adjoining building.  No information is given regarding that separation, but perhaps it can be 'violated' to solve the ramp design deficiency.

2.  It appears the original post and follow-up provide an answer.  A continuous curved ramp 'through' the transition area could work, and looks viable (with perhaps a very small encroachment into the same setback mentioned above.

3.  What appears to be a narrow planting strip next to the 'lowest' parking stall could be eliminated, and the ramp condition improved as a result.

4.  Can the 'lowest' parking stall (apparently a compact stall) be shifted slightly to the left, to align with the stall at the very top of the drawing, providing more flexibility at the 'corner' area?

5.  I would caution the designer that the ramp as designed is problematic if taking into account the difficulties (or even impossibility) of building the ramp with the kind of Swiss watch tolerance called for - essentially zero tolerance is anticipated by the design.  This is a scenario that predictably will result in technical failure to comply with code once constructed... and will fall further out of conformance with time, as site soils compact and shift under localized ramp portions.  It is not advisable to specify ramps that are at the absolute maximum allowed slope.  At a minimum, the design parameters should be adjusted to something less than maximum to account for industry-allowable and specification-allowable construction tolerances for finished site concrete work.  

6.  If it is not possible to obtain agreement to an encroachment into the the setback mentioned in 1 and 2, above, and if the present overall site configuration/layout does not allow for slightly longer aggregate ramp runs, then the designer should go back to square one and perform some magic in the way of adjusting the site plan and/or grading so that that there is room for the ramp and there is a lesser total elevation gain from end to end of the ramp system.  There is no 'forgiveness' for violations under ADA (a federal civil rights law, not state building code), especially for new construction.  Even following 'guidance' from DOJ is not a safe harbor.  Despite what any code official or CASP might say is OK, if the ramps are not fully compliant when constructed, and not maintained in a fully compliant condition post-construction due to foreseeable soils settlement, an aggrieved party can bring suit against the property Owner (who, in turn, can look to the designers in a negligence suit).  The costs of defending a suit (even one that is without merit), and the potential monetary and re-construction penalties are risks that can be guarded against by both designer and owner.  Failure to avoid known risk is not a preferred route. 


Case in question was Mandalay Bay Hotel, they rushed to complete and installed 32" doors in lieu of 36" against the recommendation of the access consultant. (She lost her job and ultimately won an EEOC claim).

Just as structural and fire and life safety are primary minimums for construction, so to is access; then and only then comes design considerations.  

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