According to the American Association of People With Disabilities, there are 39.1 million people with disabilities living in the United States, including the mentally challenged and those who are limited in activity due to chronic health or physical impairments.
With these people in mind, the U.S. Congress created the Americans with Disabilities Act (ADA) on July 26, 1990. Its primary purpose is to provide equal access to facilities and services for all Americans with physical challenges through removal of barriers in our built environment. The U.S. Architectural and Transportation Barriers Compliance Board (Access Board) was tasked to develop architectural standards for compliance with this new law. These standards are called the Americans with Disabilities Act Accessibility Guidelines (ADAAG). Section 4.28 of the ADAAG specifically provides guidelines for fire alarm systems.
The ADA cannot be enforced by local jurisdictions as a code, since no local government can enforce federal law. However, a few local jurisdictions have adopted local laws with the same language as the ADA, which essentially provides them the ability to enforce the ADA as code. Most fire alarm designers consider NFPA 72-1999, 'National Fire Alarm Code' as 'equivalent facilitation' to comply with the ADA. The requirements found in NFPA 72 exceed the minimum requirements found in the ADAAG.
Does the ADA Require a Fire Alarm System?
The ADA does not require a fire alarm system. NFPA 101, 'Life Safety Code,' NFPA 5000, 'Building Construction and Safety Code' or local building codes will mandate where a fire alarm system is required for new construction. Once a fire alarm system is installed, the ADA requires equal access to the system. For example, a system that provides an audible signal must also provide a visible signal to provide equal access for hearing-impaired occupants.
Where Is Compliance Required?
Basically, any property or part thereof, subject to occupancy by members of the public with physical impairments must be designed and built to provide equal access for all persons. However, many industrial facilities would not be entirely accessible to the general public. In a large welding fabrication shop, for instance, areas not subject to use by the public are not required to be ADA compliant, unless there are physically challenged workers in those areas.
The ADAAG does not require individual work areas (offices) to be ADA compliant, unless the areas are subject to public access. Physically challenged employees must identify their needs to the employer, and the employer must provide access throughout the areas used by the employee. Corridors, restrooms, meeting rooms and lobbies used by physically challenged employees are also required to be ADA compliant.
There are three areas in which ADA compliance is required for fire alarms: signaling for the hearing impaired, signaling for the blind, and access to manual fire alarm boxes for the physically challenged .
Signaling for the Hearing Impaired
The intent of the ADA as it relates to visible signaling for the hearing impaired is to provide an illumination level of 0.030 lumens per square foot at eye level. The prescriptive guidelines found in Section 4.28 of the ADAAG require a minimum 75-candela strobe with a spacing of not more than 100 feet between appliances. The ADAAG does not specify a polar light output distribution for the appliances, which leaves loopholes and makes design and enforcement difficult.
However, NFPA 72, 'National Fire Alarm Code' requires listed appliances and a minimum illumination level of 0.0375 lumens per square foot at the floor, which greatly exceeds the ADAAG minimum level of illumination. The only nationally recognized product standard used for listing visible notification appliances is UL 1971, 'Standard for Safety Visible Signaling Appliances for the Hearing Impaired.' Using dual-rated appliances (e.g. 15/75 cd) and following the requirements found in NFPA 72 is a generally accepted means of providing a level of protection equal to the ADAAG.
Placement. Ceiling-mounted appliances are not permitted by the ADAAG, but are permitted by NFPA 72. It is not always possible to provide complete coverage for large open areas using perimeter-mounted appliances because of the limited appliance ratings available. Table 4-4.4.1.1(b) of NFPA 72 addresses ceiling-mounted visible notification appliances and is valid for ceilings up to 30 feet in height. If the ceiling is more than 30 feet in height, pendants must be used to bring appliances to a minimum of 30 feet above the finished floor. Section 4.28.3 of the ADAAG permits ceiling-mounted notification appliances where there are no obstructions in the open area over six feet high. In this case, the appliances must be spaced not more than 10 feet apart.
Typical big box warehouse stores can be especially challenging because the commodity racks prevent direct viewing of the appliances by shoppers. In this case, each aisle must be treated as a corridor. Forklifts can also cause mechanical damage to the appliances. Mechanical protection should always be used in these cases. Additionally, it often takes a great number of appliances to cover an entire store.
Non-sleeping areas. The ADAAG and NFPA 72 have differing requirements for the mounting height of visible notification appliances. The ADAAG requires visible notification appliances to be mounted at least 80 inches above the finished floor, or six inches below the ceiling, whichever is lower. Section 4-4.4 of NFPA 72 requires visible appliances to be mounted such that the entire lens is between 80 and 96 inches from the finished floor. There is some overlap of the mounting height ranges, and mounting appliances in this range can satisfy both ADAAG and NFPA 72. It should be noted that NFPA 72 requires visible notification appliances to be mounted in the mounting heights as they are tested in the laboratory. Mounting them higher will attenuate the signal, which reduces the effectiveness of the appliance.
Sleeping areas. Sleeping areas present unique signaling challenges. Both NFPA 72 and the ADAAG require the visible signaling to be of sufficient intensity to wake a sleeping person. Section 4-4.4.3.2 of NFPA 72 requires a minimum 110-candela appliance to be mounted on a wall not less than 24 inches from the ceiling, or a 177 cd appliance if mounted less than 24 inches from the ceiling. The higher intensity is required in case there is a smoke layer, which could attenuate the signal. The appliance must be mounted not more than 16 feet from the pillow when room dimensions exceed 16 feet in any direction. Mounting heights for sleeping areas are the same in NFPA 72 and the ADAAG.
The ADAAG permits either a visible notification appliance or a tactile (vibrating) appliance for waking a sleeping occupant. NFPA 72 also permits tactile appliances, provided they are listed for this purpose, as required by Section 1-5.1.2. But there are currently none listed for this use. Therefore, a visible appliance is one of the only ways of satisfying both ADA and NFPA 72.
Rooms designated for the hearing impaired must be outfitted with a smoke alarm that has a visible signaling device as described above. Note that smoke alarms must be mounted within 12 inches of the ceiling or on the ceiling, so be sure they are provided with a 177 cd notification appliance. Some smoke alarms can be installed such that the integral strobe can be triggered by the building fire alarm system to provide warning of a building-wide alarm. Other approaches may rely on separate system-powered notification appliances in addition to the smoke alarm/integral notification appliance arrangement.
Synchronization. Flash rates of about four cycles per second (4 Hz) may adversely affect people with photosensitive epilepsy. Composite rates caused by more than two strobes in a single field of view can generate strobe rates in excess of this value, which may lead to an epileptic seizure. Nonetheless, notification appliances in large areas and within a common field of view require synchronization by NFPA 72 to prevent seizures.
The effect on photosensitive epileptics drops off quickly after about 55 feet. Most manufacturers have developed modules that synchronize visible notification appliances. Generally, it is best to use fewer high-powered visible notification appliances. This not only reduces installation costs, it can also eliminate the need to synchronize.
Signaling for the Blind
Audible signals must be of sufficient audibility to alert blind persons. Section 7.4.2 of NFPA 72 provides performance-based requirements for the sound pressure level (SPL) of fire alarm signals. The minimum SPL for public mode operation is 15 dBA above the average SPL, or 5 dBA above the maximum SPL lasting a minute or longer, whichever is greater, throughout the protected space. A good dispersion of lower-powered audible devices throughout the protected space will help ensure a uniform distribution of the signal. It is best to design the system so that a signal does not need to penetrate more than one wall or door. Hotels and apartments should be designed with at least one audible appliance in each unit. High-noise environments may require the use of tactile pagers to alert occupants.
Considerations for Limited Mobility
Persons using wheelchairs or other similar devices cannot generally reach more than 48 inches above the finished floor when facing the object they are trying to reach, and they cannot usually reach more than 54 inches when approaching an object from the side. According to the ADAAG, manual fire alarm boxes must be mounted not more than 48 inches high for front reach and 54 inches high for side reach. Manual fire alarm boxes mounted with the top of the back box at 48 inches will generally satisfy both sets of requirements, and complies with Section 2-8.1 of NFPA 72.
The Future
The Access Board has developed a new draft of the ADAAG, which was released on April 2, 2002. According to the Access Board's newsletter, the draft contains significant changes relating to fire alarms. It incorporates the ADAAG with the Architectural Barriers guidelines and also incorporates a new numbering system. But one of the most significant technical changes is found in Section 702.1, which directly references NFPA 72 (1999 edition). This change will make compliance with the ADA much easier. The one exception to NFPA 72 is for the maximum sound pressure level, which the ADAAG draft has set at 110 dBA.
It is unclear when the draft will clear the necessary hurdles, but the final rule will not be published for a while. Given the current administration's track record on rule making, expect to see a final rule no earlier than late 2003.
Compliance with the ADA is not that difficult. The real issue is that we need to have knowledge firmly planted in two documents. But once the current draft of the ADAAG becomes final, compliance will get a whole lot easier. In the meantime, we need to navigate our way through the labyrinth of regulations, guidelines, codes, and standards. A qualified consultant can help you better understand these issues for specific projects.
Merton Bunker is a senior consulting engineer with Rolf Jensen & Associates' Fairfax, Va. office. He can be reached by e-mail at [email protected]. To learn more about RJA, visit their Web site at www.rjagroup.com.
