Exhibs Now Build to Most Restrictive
Requirements
ADA: NATO Works To
Simplify Compliance
by Steven John Fellman
NATO Washington Counsel
Today, most building codes
include requirements that public facilities such as theatres
be fully accessible to persons
with disabilities. However, your local building inspector
may have a difficult time determining exactly what regulations
apply to your new theatre.
At the outset, your state,
county or city will have its own building code. In recent
years code officials have
attempted to unify various building codes into the International
Building Code. The IBC is the uniform code that is being
followed by most jurisdictions. However, many jurisdictions
have not adopted the entire IBC. So the first question
a theatre architect has to answer is: “What is in
the local building code?”
With regard to disability
access, the question is even more confusing. The disability
access portions of the IBC
are based on the American National Standards Institute
117.1 standard.
The ANSI standard is
revised generally on 3-year cycles. Often it takes the
IBC some time to update its code provisions
to meet current ANSI requirements. However, some local
codes refer directly to ANSI. These code requirements may
change when the ANSI standards change.
There are two more complicating
factors. The Access Board is the federal agency responsible
for publishing guidelines
the Department of Justice must use as a minimum in writing
the Americans With Disabilities Act (ADA) regulations that
require theatre owner complaince. These guidelines are
known as the “ADA Accessibility Guidelines” (ADAAG).
The Access Board revised
its guidelines several years ago, but the Department
of Justice has not revised its regulations.
It has, however, proposed new regulations.
As a result, your architect
must not only look at the local building code, ANSI Standard
117.1, but he or she must
also look at the ADAAG, the current Justice regulations
and the proposed Justice regulations.
What if some of these
codes, standards and regulations have conflicting provisions?
Now you see the problem!
In fact, there are not only direct conflicts between
some of the accessibility requirements
of IBC, ANSI, the ADAAG, the existing Justice regulations
and the proposed Justice regulations, but some requirements
are included in one document and not included in the others.
What can your architect
do? He or she can make an informal “guess” of
what is required or you may be told to build to the most
restrictive requirements, which will substantially increase
your costs of construction.
Representatives of IBC, ANSI and the Access Board recently
met to see if it would be possible to unify the provisions
of the IBC, ANSI and the ADAAG. NATO was invited to join
in this effort and is actively participating in this process.
NATO is a member of the
task force assigned to unify the regulations involving
assembly areas. The initial responsibility
of the task force is to study a side-by-side comparison
of the IBC, the ADAAG and the ANSI standard and recommend
the most effective means of establishing unified requirements.
The initial meetings
of the “Assembly Task Force” have
been productive and we are hopeful that the results of
these efforts will provide uniformity in disability access
requirements, which will benefit disabled persons, theatre
owners and code officials. By working closely with representatives
of ANSI, the IBC and the Access Board, NATO ensures full
consideration in these important discussions. 
