ADA Transition Plan to Make Facilities Accessible for Programs and Services

I. Introduction

The Americans With Disabilities Act (ADA) of 1990 requires no qualified individual with a disability shall, on the basis of that disability, be excluded from participating in or be denied the benefits of the programs, services, or use of facilities or be subject to any discrimination. ADA Title II requires the University to make reasonable accommodations to facilities where programs and services are offered. This is a continuation of University barrier removal efforts under the 1973 Rehabilitation Act, Section 504. While Section 504 was concerned with "programmatic" access, the ADA requires Universities to take proactive measures to insure reasonable access to every facility where programs and services are offered.

The ADA defines "reasonable accommodations" as "easily accomplishable and able to be carried out without much difficulty or expense." The Department of Justice gives little guidance in defining "reasonable accommodations" and "easily accomplishable". However, the University has been proactive in doing costly renovations such as relocating partitions, installing elevators, upgrading electrical service and changing plumbing and wiring systems to accommodate modifications.

This section of the Transition Plan describes the methodology to identify, prioritize, fund, and remove structural barriers that adversely impact accessibility to programs and services.

II. Goal

The ADA requires the University to remove structural barriers to achieve program and service accessibility by January 26, 1995. To achieve this objective, a survey of facilities and programs was conducted to determine if structural barriers adversely impact any programs and services. Once it is determined that a program or service is adversely impacted and cannot be relocated to an accessible facility, then immediate steps will be taken to remove the barriers.

III. Scope

All academic and support facilities were surveyed at University Park Campus and Commonwealth Campuses. This represents a list of almost 600 major buildings totaling more than 18 million square feet.

IV. Facility Survey Methodology

1. ADA Education and Training

To become knowledgeable of ADA law, staff members studied the ADA Handbook published by the Equal Employment Opportunity Commission and the U.S. Department of Justice, and the Federal Register, Vol. 56, No. 144 on rules and regulations governing design for ADA Accessibility Guidelines (ADAAG).

An ADA library was established in the Office of Physical Plant (OPP) Office 101D.

Staff members also attended the following ADA seminars: Compliance with the Americans with Disabilities Act presented by the International Facilities Management Association (IFMA); The Basics of Facilities Compliance under the ADA by the Key Productivity Center.

2. Survey Forms

More than 20 different survey forms, suitable for University use, were designed.

3. ADA Task Force and ADA Workshops

The ADA Task Force is one of four major committees dedicated to ADA concerns. Its mission was to train faculty, staff, and students to complete surveys of facilities, programs, and employment procedures. Training was done in three and one half-hour workshops, which included a slide presentation on ADA design regulations, instructions on the use of survey forms and survey tools.

College and Department teams completed the building surveys. The College and Department teams surveyed their assigned spaces such as, offices, conference rooms, study rooms, and laboratories. The student survey teams surveyed all common use areas such as, entrances, lobbies, restrooms, classrooms, laboratories, elevators, stairways, and corridors.

All surveyors were given survey forms, building block plans, room assignment lists, a measure stick, a bubble level to measure slopes, and the ADAAG design manual.

4. Database and Reports

The survey data is being entered into a computer database and is used to prepare the Facility and Site Reports, which are a summary of structural barriers discovered in each building. A second report, the ADA Summary by Element Report, is a composite of structural barriers and removal cost estimates by campus location.

These reports are suitable for prioritizing and tracking barrier removal projects.

The barriers are classified between structural barriers and non-structural barriers for cost estimating purposes.

STRUCTURAL BARRIERS – These are barriers that are difficult and expensive to eliminate. The ADA regulations offer alternatives to structural barriers. The alternatives are:

- Relocation of a program or service - Programs or services will be relocated to assist individuals with permanent or temporary disabilities.

- Renovation - In situations where a program or service cannot be relocated then a portion of the building will be renovated to accommodate disabled individuals.

- Replacement - In extreme situations a building may be determined to be obsolete and need replacement.

NON-STRUCTURAL BARRIERS – These are barriers that can be removed easily and without much expense.

- Room Signage – Permanent room identification, such as room numbers, will comply with ADA and include Braille.

- Door Hardware – Lever or pull handles will replace round door knobs.

- Elevator Controls – Controls will be set at the correct height with proper sight and sound signals.

- Telephones – Public telephones will be set at the correct location. TDDs and volume controls will be provided.

- Seating and Tables – Wheelchair seating will be provided in assembly areas with tables or desk tops at the correct height.

- Protrusions – Protruding objects will be modified for compliance or removed.

- Alarms – Install strobe light alarms as needed.

- Directional Signage – Directional signage to accessible entrances, rest- rooms, and routes will be provided.

- Assistive Listening Devices – Listening assistance is being designed into assembly areas, classrooms, on a case-by-case basis.

- Power Doors – Although ADA regulations do not require power assist door operators, they will be installed on a case-by-case basis.

- Drinking Fountains – Fountains will be set at the correct locations. A cup dispenser is an acceptable solution.

- Counter Height – Existing counters can be adjusted or an adjacent table can be used.

5. Human Resources

The survey of more than 18 million square feet of University space resulted in a tremendous amount of data. Budget 142-83 was established to pay for student data processing assistance.

6. Certification – Facility Survey Methodology

An independent architectural firm, E. Pawlowski Associates, was engaged to examine our facility survey methodology for compliance with ADA regulations. Results of that examination are favorable.

V. University Access Committee – Barrier Removal Priority

All academic and support facilities were surveyed at University Park Campus and Commonwealth Campuses. This represents a list of almost 600 major buildings totaling more than 18 million square feet.

The University Access Committee is the second of four major committees appointed by the Executive Vice President and Provost, dedicated to ADA concerns. The UAC mission is to prioritize and fund barrier removal projects in accordance with the Facilities Project Implementation Policy.

UAC will review barrier removal project requests from several sources. The main source for projects is from the facility and program surveys. Other sources of projects can come from the ADA Coordinators Office, Disabilities Services Office, and students. The process of selecting projects for review is based on the following priority management process:

Priority Management of Barrier Removal Projects

The Pennsylvania State University is taking a priority management approach to remove physical barriers that deny individuals with disabilities equal opportunity to participate in University life. This approach focuses initially on priority-one buildings and first-priority structural barriers.

Building priority is based on the following criteria:

a. Priority-One recognizes those building which have intense use and occupancy with major concern for students.

b. Priority-Two recognizes those buildings with less use and occupancy but a major concern for research and specific service.

c. Priority-Three recognizes those newer buildings designed in compliance with ADA regulations and needing few modifications.

d. Priority-Four recognizes those buildings that may be replaced in five years.

The first barriers to be removed within priority-one buildings are first-priority structural barriers.

Removal of first-priority structural barriers will enable a person to:

a. Get into the building.

b. Get to the program or service offered in the building.

c. Use the restrooms and building services.

d. Get additional accommodations to access a program or service.

Barrier removal in priority-one buildings will require a lot of time and money, after which, the next lower group of buildings and barriers will be removed. The priority management approach will be continually modified to keep it focused on vital areas.

VI. Facilities Project Implementation Policy

The University Access Committee has responsibility for prioritizing and funding barrier removal projects following the guidelines established in the Facilities Project Implementation Policy.

The Committee will review facility and program survey data to determine if a structural barrier adversely impacts access to programs or services. If so, UAC will review solutions, obtain cost estimates and assign project priority. The OPP ADA Steering Committee is the third of four major committees dedicated to ADA concerns. OPP ADASC provides technical assistance on renovations and new construction. The fourth committee provides a public review of renovation and new construction plans. Projects approved by UAC will also be approved by members of the Facilities Resources Committee, as specified in the Project Implementation Policy.

Whenever there is a need to relocate a program or service, UAC members will discuss relocation issues with the Director of Facilities Resources and Planning and the appropriate colleges or departments.

VIII. Barrier Removal Example – Wagner Building Entrance

A typical example of the barrier removal process begins with a facility survey of a particular building element such as entrances.

Building entrances are surveyed using the appropriate survey form.

UAC members review the survey of the Wagner Building as a priority-one building. A review of first-priority barriers indicates a lack of accessible entrances to Wagner Building.

It is then determined from the program survey data, that the programs cannot be relocated to another location.

A preliminary solution and cost estimate is prepared and a Project Request Form is prepared. A design to remove the entrance barrier is based on procedures in the OPP Design Manual.

The Budget Administrator approves the project and cost before the project is scheduled for completion.

The entire project process is tracked to completion, which is explained in A Guide to the Project Process.

Submitted by:
James J. Lettiere, Manager
Space Planning and Management
Office of Facilities Resources and Planning
September 1994

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