Code Determination Number: 11

Date: February 7, 2023 

Subject: Design considerations for using both ADA Codes (2010 ADAAG, 2017 ICC A117.1)

Code Edition: 2010 ADAAG (ADA Standards for Accessible Design), 2017 ICC A117.1 (Accessible and Usable Buildings and Facilities)

Code Section: All sections

Questions (from Design Consultants): 

  1. Since UM System has adopted ICC A117.1, are consultants still required to reference ADAAG standards?
  2. Is an ADAAG disproportionality analysis required when designing an alteration to an existing facility?

Answer (from UM System AHJ): 

  1. Since UM System has adopted ICC A117.1, are consultants still required to reference ADAAG standards?

    Yes, consultants are required to comply with both the ICC standards and the ADA Standards for Accessible Design. The ADA is a federal law, setting minimum requirements for accessible design, and those federal guidelines still apply.  In navigating the use of both codes, our design intention is that, when the ICC and ADAAG requirements vary, consultants should choose the more restrictive version that provides the highest standard of accessibility. 

    Moreover, consultants should note that increasing the accessibility of facilities is a major priority for UM System, and we view every renovation and new construction project as an opportunity to improve the accessibility of our campuses. Because of this, considering potential accessibility improvements should be an essential agenda item for design kickoff and later planning meetings, alongside other key issues such as life safety, regardless of whether the renovation is large or small.

  2. Is a disproportionality analysis under ADAAG required when designing an alteration to an existing facility?

    Yes, consultants should plan to complete a disproportionality analysis any time alterations are made to primary function areas. 

    In making decisions related to disproportionality, each project will require a unique analysis based on the current accessibility of the existing building being renovated. If the existing building complies fully with 2010 ADA Standards, then planning for additional ADA improvements may be unnecessary, and need not be factored into the budget aside from ensuring that any newly added features also comply with ADAAG. 

    If the existing building has substantial accessibility issues, however, the disproportionality provision of the ADA may require that up to a maximum of 20% of the final budget of the project be dedicated to making accessibility improvements in order to comply with the 2010 ADA Standards. Thus, completing this analysis early in the planning process for a project is key.

    If the facility being altered has not been substantially renovated since 1992, then it is very likely that a large number of ADA improvements will be necessary, and ADA should be given particular attention in the renovation. If the facility was renovated after 1992 but before 2012, then it will likely need improvements that reflect the requirements of the updated 2010 ADAAG standards, such as increasing the number of accessible entrances.

    In prioritizing ADA improvements, first priority should be given to those elements that will provide the greatest improvement in accessibility, in the following order:

    1. Accessible entrances
    2. Accessible path of travel to the altered areas
    3. Accessible restrooms; and
    4. Other accessibility features, such as drinking fountains and accessible parking.