ADA Compliance Overview
To understand the bathroom emergency pull cord requirements of the ADA, it is important to start by understanding the ADA itself, and when it applies. "ADA" is the acronym for the Americans with Disabilities Act. Passed by Congress in 1990, the ADA is a wide ranging civil rights law that prohibits discrimination based on disability in schools, public accommodations, commercial facilities, state and local government buildings, public transportation, and more. The primary purpose of the ADA is to ensure that people with disabilities have the same rights and opportunities as everyone else.
The U.S. Attorney General has stated that the ADA applies broadly to all parts of public life, including private businesses, state and local governments, and commercial facilities. In the context of bathrooms, it is likely that the ADA will apply anytime a building is open to the public. Thus when a person with a disability uses a public building, he/she also must have access to a suitably designed and constructed bathroom.
The ADA also contains accessible design and construction standards, which are called the "Accessibility Guidelines . " In 1991, the Department of Justice published regulations containing Accessibility Guidelines under title III (places of public accommodation) and title II (public entities) of the ADA. These regulations provided detailed architectural guidelines to be followed in the design and construction of new buildings and spaces.
In 2010, DOJ updated its regulations and adopted updated Accessibility Guidelines known as the ADA Standards for Accessible Design. The ADA Standards for Accessible Design are available here.
The Standards set minimum accessibility requirements for many elements of design in public bathrooms, including door hardware, toilet seats, stalls, grab bars, sinks, mirrors, and dispensers. These accessibility requirements are very important to the ability of people with disabilities to access restrooms. For example, the proper height and location of grab bars, and a properly located toilet paper dispenser can mean the difference between whether a person with a disability can or cannot independently use a restroom. As such, it is critical that you are careful to ensure that bathrooms you are designing or constructing are ADA compliant.
Why Pull Cords Are Important
Emergency pull cords play a crucial role in ensuring the safety and independence of individuals with disabilities in emergency situations. These devices are designed to be easy to reach and operate from the floor in case of a fall, allowing individuals to quickly call for help without having to search for a phone or other communication device. When properly installed and maintained, they provide users with peace of mind by ensuring that assistance can be summoned immediately in the event of an emergency.
In addition to enhancing safety, emergency pull cords also help to promote and ensure independence for individuals with disabilities. By providing a means of communication and connection to emergency services, they empower users to remain in control of their environment and seek help when needed, without having to rely on the presence of other people. This is especially important for those who may have limited mobility and live or work in remote areas with little or no staff support.
Furthermore, emergency pull cords are required to be installed in certain ADA-compliant bathrooms to ensure compliance with the Americans with Disabilities Act (ADA). This requirement is based on the understanding that individuals with disabilities need immediate access and support during emergencies, and the installation of these devices is one of the ways to ensure that this need is met. Failure to install and maintain emergency pull cords in ADA-compliant bathrooms not only puts the safety and well-being of individuals with disabilities at risk but may also subject owners and operators to legal liability for violating ADA accessibility requirements.
Additional ADA Requirements for Bathroom Pull Cords
While the Primary Standard governing ADA compliant pull cords in bathrooms (restrooms) is the SBOA, there are specific pull cord placement, length, and accessibility requirements set forth in a series of ADA and TAS guidelines. While the SBOA is the reference point for accessible pull cords, some establishments will have to make minor modifications to meet several other pull cord requirements.
Some of the key requirements for location set forth by the SBOA and other accessible restroom guides are as follows:
· 31% of all accessible water closet compartments must be fitted with a pull cord, and at least one pull cord must be located in each compartment.
· The pull cord must have a maximum length of 54 inches, with a minimum of 60 inches. However, a 60 inch pull cord is the general recommended standard.
· The pull cord must be easily accessible and within the reach range for individuals in wheelchairs. In accordance with relevant ADA standards, for an adult in a wheelchair, the end of the pull cord would have to hang no higher than 48 inches. SSI suggests though keeping the pull cord at a height of 40 inches, which would theoretically increase accessibility in a commercial bathroom and provide easier access by children and persons with disabilities.
· Apart from being at a maximum height of 48 inches to be accessible to persons with physical disabilities, the pull cord must also be bright in color. An emergency pull cord must be yellow/orange or contrast sharply with adjacent walls and colors in a bathroom, such as white/black. If the pull cord is all black, it may become camouflaged and difficult to see.
· In cases where a shower is also provided in the comparable restroom, a pull chain must also be installed at a height of no more than 54 inches, although a height of 40 inches is also recommended for greater accessibility.
These requirements can sometimes go beyond those set forth by the SBOA, and businesses and public facilities need to be mindful of the added pull cord requirements when complying with ADA regulations.
Best Practices for Installation
When installing ADA bathroom emergency pull cords, it’s essential to follow best practices to ensure accessibility and usability for all individuals, especially those with varying degrees of mobility. Here are some tips: Location and Height: Install the pull cord within the reach of all potential users. As a general rule, this means positioning the cord within 36-48 inches above the finished floor level. Additionally, the pull cord should be attached securely in a clear area, as opposed to next to obstacles that could impede a user’s ability to reach it easily. Fully Extend and Test the Cord: When installing a new pull cord, extend it from the ceiling to the floor to ensure it can be easily reached. After installation , test the unit by using the cord to activate the alarm and verify it sends an audible alert and also displays the location of the pull cord in the control panel. Follow Manufacturer’s Instructions: ADA requirements are sometimes more stringent than manufacturers. Therefore, always refer to the installation instructions that come with the product and contact your distributor or our Technical Support if you have questions. At Emergency Products & Research, we offer a range of products that follow best practices for pull cord installations in ADA bathrooms. In addition to privacy signs, we also supply pull cords and other ADA-compliant bathroom hardware, including grab bars, warning signs, and lights/alarms, for schools, churches, airports, and government buildings.
Common Mistakes for ADA Compliance
One of the most common mistakes businesses and facility managers make is relying on Figures 28(a) and 28(b) from the appendices of the 2010 ADA Standards for Accessible Design when selecting and installing accessible emergency pull cords. While the commentary included in the appendices can be useful in some circumstances, it does not hold the same force as the rest of the ADA Standards and can be inaccurate.
Another common mistake is using what were previously ADA-acceptable pull cords with new accessible water closets. The 1991 ADAAG included a "pull-side" layout where accessible water closets had pull cords on the adjacent wall. The 2010 ADA Standards do not allow this configuration. As the 2010 ADA Standards are mandatory, all accessible water closets must now have pull cords located on the rear wall above the water closet if they are to be fully compliant.
A few facilities in the eastern United States confuse the new pull cord requirements with what have been acceptable in Canada. The Canadian Standards for Accessibility Features entitle Canadians with disabilities to more extensive assistance. These requirements were incorporated into their National Building Code and may still impact Canadian facilities. However, U.S. facilities should not try to emulate the Canadian standards as only the 2010 ADA Standards are mandatory requirements for U.S. facilities.
Making mistakes is part of our human condition, however my goal is that you don’t repeat any of these mistakes by learning from others’ mistakes.
Why & How Your Business Will Benefit
When effectively incorporated into an emergency management plan, ADA emergency pull cords can be a massive help for all stakeholders. Providing a safe environment benefits everyone—employees, customers, and emergency responders alike. For the business, having these emergency devices in full compliance can mean the difference between good standing or a black mark after a lawsuit . When a company meets ADA standards for safer workplaces, it is protecting itself as well. Legal compliance can prevent drawn-out courtroom procedures and penalties because you made a mistake. It can allow your insurance provider to give you a lower rate because you are doing everything you can to make your workplace safer. Most importantly, it shows that you are committed to the safety of the people that you work with and the surrounding community.