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Picnic and Camping Area Facility Guidelines

Discussion of Proposed Specifications to Comply with Americans with Disabilities Act

From: REGULATORY NEGOTIATION COMMITTEE ON ACCESSIBILITY GUIDELINES FOR OUTDOOR DEVELOPED AREAS, FINAL REPORT, SEPTEMBER 1999

Following is the portion of the report dealing with picnic tables, fire rings, cooking surfaces, trash receptacles, and related facilities for both camping and picnic areas:

FIXED PICNIC TABLES

Proposed section 16.5.1.1 requires that where one fixed picnic table is provided in a picnic area, it shall be accessible and comply with 16.5. The table shall also be located along an outdoor recreation access route complying with 16.3. This section is included in order to ensure that a picnic area with only one table is accessible to and usable by people with disabilities. If only one table is provided, and it is not accessible, people with disabilities would not have the option of choosing another table.

Proposed section 16.5.1.2 requires that where two or more fixed picnic tables are provided in a picnic area, at least 50 percent, but no less than two, shall comply with 16.5. Of the picnic tables required to be accessible, 40 percent, but never less than two, shall be located along an outdoor recreation access route. For example, if ten tables are provided in a picnic area, this provision would require five tables to be accessible. In addition, of the five required to be accessible, 40 percent, or two, would need to be located along an outdoor recreation access route.

This provision applies only to picnic tables that are "fixed" to the ground, (i.e. permanently attached such as by a chain from the table to a concrete footing below ground). Some committee members initially proposed 100 percent scoping, requiring all tables to be accessible. Other members considered 100 percent too high and more than what is currently required in ADAAG for the built environment. After much debate, committee members agreed that 50 percent scoping would adequately accommodate the demand for accessible tables. Committee members considered this to be realistic and feasible for most outdoor recreation providers, and would result in a higher number of accessible tables in smaller picnic areas.

In the outdoor recreation environment, the natural terrain often presents a real obstacle. Although this would not affect the accessibility of the table itself, it could impact getting to the table. The committee realized that in many picnic areas, it might not be possible to locate all accessible tables along an outdoor recreation access route. Rather than decreasing the number of accessible tables, the decision was made to reduce the scoping for accessible route connections. While some committee members wanted all accessible tables to be located along an access route, other committee members felt that would be unrealistic in the outdoor environment given constraints of the natural terrain. The committee finally reached consensus on requiring 40 percent of the accessible tables to be located along the outdoor recreation access route.

The proposed scoping provision addresses picnic tables located in an "area." An "area" refers to a designated location when picnic related elements are located. For instance, a picnic "area" is a designated location where picnic related elements are located Areas may be separated and include different settings on the same site. For example, a picnic area located next to a lake in a park is considered a separate picnic area from a pavilion with numerous picnic tables within the same park. Picnic "areas" may also be separated and designated by a name or connected to a separate entrance road.

Proposed 16.5.2 requires accessible tables to be dispersed among the various types of picnic settings or opportunities provided. For example, a particular picnic area may offer picnic sites near the lake, in the woods, and in the open, sunny portion of the area. This provision requires that the number of accessible tables be distributed throughout the area, so that people with disabilities would have a choice of picnic locations similar to what other visitors to the area have. This section would not increase the total number of accessible tables required in 16.5.1.2.

Proposed 16.5.3 addresses wheelchair seating spaces and requires at least one wheelchair seating space at an accessible picnic table. Where the table top perimeter exceeds 24 linear feet, the number of accessible seating spaces shall comply with the table 16.5.3. More accessible seating spaces would be required where the perimeter of the table top (not including the bench) exceeded 24 linear feet. The location of the accessible seating space(s) would be left to the discretion of the designer, although the appendix notes recommend that the accessible spaces be dispersed rather than clustered in one location.

Committee members discussed this issue at length, finally basing the number of accessible seating spaces on an average table dimensioned at ten-foot long by 2-1/2 foot wide. Such a table has a perimeter of 25 linear feet and is designed to accommodate up to ten people. The committee decided tables of that size should provide two accessible seating spaces, while smaller tables should only require one accessible space. Tables with a perimeter of 45 to 64 linear feet, i.e. if at least two but less than three ten-foot long tables were joined together, would require three accessible seating spaces. Tables with 65 to 84 linear feet would require four accessible spaces, and so on.

Proposed 16.5.4 addresses the technical provisions for the wheelchair seating space. Each accessible seating space will provide knee space of at least 30 inches wide, 19 inches deep, and 27 inches from ground/floor to the bottom of the table top. This provision departs from ADAAG in that it also requires a toe clearance of 9 inches above the ground/floor extending for a total depth of 24 inches. This is an additional 5 inches minimum beyond the 19-inch knee space depth in current ADAAG. This ensures that adequate toe clearance is provided at tables that have a solid leg at each end (rather than an A-shape frame or individual legs). A 19-inch deep space at the end of a solid leg table would not allow a person using a wheelchair to be sufficiently close to the table.

Proposed 16.5.5 addresses table clearance. This provision departs from current ADAAG by requiring a 36-inch minimum clear space surrounding the usable portions of a table, measured from the outside edge of the seat, or the outside edge of the table if no seat is provided.

Tables placed in buildings are generally expected to have ample space for moving around. This is not always the case where picnic tables are located in the outdoor environment. For that reason, the committee recommends a minimum clear space that would provide maneuvering room beyond the accessible seating space to all usable portions of the table to allow for movement around the table.

Proposed 16.5.6 addresses surfaces. This provision requires the surface of the clear space and accessible seating space to be firm and stable. Slip resistance is not required because of the tree leaves and needles, duff (partly decayed organic material on the forest floor), mud, snow, ice, etc. that often cover outdoor areas. Exception 1 permits departure from this requirement where at least one of the conditions of 16.1.1 applies.

Proposed 16.5.7 requires slopes of the required clear spaces not to exceed 1:50 in any direction, which is consistent with current ADAAG.

Exceptions are provided to address the unique aspects of the outdoor environment. Natural and natural-appearing surfaces are often used in picnic areas. A 1:50 slope on these surfaces may not be adequate to ensure proper drainage. In these cases, exception 1 allows the slope in any direction to be 1:33 maximum. Exception 2 states that this provision does not have to be met where at least one of the conditions in proposed section 16.1.1 applies.

FIRE RINGS

Proposed 16.6.1.1 requires that where only one fire ring is provided in a picnic area, it shall comply with 16.6.3 through 16.6.7 and be connected to an outdoor recreation access route complying with 16.3.

Proposed section 16.6.1.2 requires that where two or more fire rings are provided in a picnic area, at least 50 percent, but not less than 2, shall comply with section 16.6. In addition, of the 50 percent required to be accessible, 40 percent shall be located along an outdoor recreation access route. This proposed provision is consistent with other outdoor elements proposed in this section.

Proposed 16.6.2 requires that the accessible fire rings be located throughout the picnic area and dispersed among the types of fire rings, if different styles or designs are provided. For example, a picnic area may provide fire rings without cooking surfaces (i.e. for camp fires only) and some with cooking surfaces. In addition, this picnic area may offer picnic sites nestled in the trees, some near the water, and others in open meadows. This section would require that accessible fire rings be available in both types and distributed among the different picnic sites, affording people with disabilities the same choice of fire ring location that is available to other visitors. This provision does not require an increase in the total number of accessible picnic tables.

Proposed 16.6.3 requires a clear space extending a minimum of 48 inches deep by 48 inches wide be provided at all usable portions of the fire ring. This clear space exceeds what is generally required in current ADAAG to allow both a forward and parallel approach and provide more space to move away from the heat. Exception 1 permits the clear space to be reduced to no less than 36 inches deep by 36 inches wide when one of the conditions of 16.1.1 exists. A clear space of less than 36 inches x 36 inches at accessible fire rings could pose a safety hazard to users. As a result, no exception is provided to further reduce the clear space requirement to less than 36 inches by 36 inches.

Proposed 16.6.4 requires the fire surface height to be 9 inches minimum above the ground/floor and is consistent with the current ADAAG specifications for the dimensions for low side reach.

Proposed 16.6.5 addresses raised edges around fire rings. In this situation, the edge/curb is viewed as the obstruction. Where a raised edge or curb is provided around a fire ring, this proposed section would require that the combined reach over the edge/curb and down to the fire building surface shall comply with ADAAG 4.2.6.

Proposed 16.6.6 requires the slope of the clear space required by 16.6.3 to not exceed 1:50 in any direction. This is consistent with current ADAAG. However, many natural and natural-appearing surfaces used in the outdoor environment require more than 1:50 slope for proper drainage. Exception 1 permits the slope of the clear space to be 1:33 maximum in any direction. In the event that at least one of the conditions of 16.1.1 applies, the slope of the clear space is not required to meet this provision.

Proposed 16.6.7 requires the surface of the clear space at the usable portions of the fire ring to be firm and stable. Consistent with other clear space requirements around outdoor elements, slip resistance is not required. If at least one of the conditions of 16.1.1 applies, the requirements of a stable and firm surface of the clear space is not required.

COOKING SURFACES, GRILLS, PEDESTAL GRILLS

Proposed 16.7.1.1 requires that where only one cooking surface, grill, or pedestal grill is provided in a picnic area, it shall comply with section 16.7. Proposed 16.7.1.2 requires that where multiple cooking surfaces, grills, or pedestal grills are provided in a picnic area, 50 percent, but no less than two, shall comply with 16.7. Of the 50 percent required to be accessible, 40 percent, but no less than two, shall be located along an outdoor recreation access route complying with 16.3. The rationale for this provision is consistent with picnic tables (16.5.1), fire rings (16.6.1) and other outdoor elements.

Proposed 16.7.2 requires accessible cooking surfaces, grills, and pedestal grills to be dispersed throughout the area and among the types provided. For example, if a picnic area offers different types of cooking surfaces, the total number of accessible cooking surfaces is to be distributed among the different types provided. This provision would not increase the number of cooking surfaces, grills, or pedestal grills required to be accessible per 16.7.1.

Proposed 16.7.3 requires accessible cooking surfaces be installed between 15 inches and 34 inches above the ground/floor. This provides a comfortable reach range for cooking. A 34 inch height is consistent with counter tops (ADAAG Appendix 9.2.2(7). The 15 inches is consistent with current ADAAG 4.2.5 for the minimum low forward reach.

Proposed 16.7.4 requires operating controls and mechanisms to comply with current ADAAG 4.27.1 (General), 4.27.2 (Clear Floor Space), and 4.27.3 (Height). In the outdoor recreation environment, picnic and camping elements must be vandal-resistant, large animal-resistant (i.e., bears) and adaptable to weather conditions of extreme heat, cold, and moisture. While compliance with ADAAG 4.27.4 (Operation) is reasonable and feasible in the indoor/built environment, it is not realistic in the outdoor environment. Therefore, compliance with ADAAG 4.27.4 is not required.

Proposed 16.7.5 requires that a minimum clear space of 48 inches deep by 48 inches wide be provide at all usable portions of the cooking surface, grill, or pedestal grill. This allows both a front and parallel approach. If at least one of the conditions of 16.1.1 applies, exception 1 permits the clear space to be reduced to no less than 36 inches by 36 inches. This proposed provision is also consistent with fire rings (16.6.4).

Proposed 16.7.6 addresses the slope of the clear floor or ground space of cooking surfaces. As with picnic tables and fire rings, this proposed provision requires the slope of the clear space at usable portions of cooking surfaces, grills, and pedestal grills to not exceed 1:50 in any direction. If proper drainage can not be met with a 1:50 slope because of the type of surface used, exception 1 permits the slope of the clear space to be up to 1:33 in any direction. If at least one of the conditions of 16.1.1 exists, exception 2 permits departure from 16.17.6.

Proposed 16.7.7 addresses surface of the clear floor or ground space of cooking surfaces. The surface of the clear space at usable portions of cooking surfaces, grills, and pedestal grills is required to be firm and stable. Exception 1 permits departure from this provision where at least one of the conditions of 16.1.1 exists.

FIXED TRASH/RECYCLING CONTAINERS

Proposed 16.8 requires each trash or recycling container to be accessible and comply with ADAAG 4.27.

Proposed 16.8.1 requires that each trash or recycling container be accessible. The committee considered this to be a health issue making it imperative that each container meet the provisions for accessibility. This requirement is compatible with those for other singly occurring elements in an outdoor setting, as well as providing consistency with existing ADAAG. Exception 1 permits 50 percent of the bins in a multi-bin container to be exempt from this provision.

An exemption is provided where the container has one or more compartments. Here, 50 percent of the compartments must be accessible. The committee determined that this requirement would assure the user of finding at least one accessible compartment in a multi-bin container.

Proposed 16.8.2 requires the clear space of fixed trash/recycling containers to comply with ADAAG 4.2.4.1 and 4.2.4.2. This ensures sufficient clear space for use by persons using wheelchairs and other mobility devices.

Proposed 16.8.3 requires the surface of the clear space to be stable and firm. An exception permits departure from this provision where at least one of the conditions of 16.1.1 exists. This provision does not apply where one of the conditions in 16.1.1 exists.

Proposed 16.8.4 requires the slope of the clear space to be no greater than 1:50. An exception permits a 1:33 slope for proper drainage. This provision does not apply where one of the conditions in 16.1.1 exists.

Proposed 16.8.5 requires operating controls for the containers to comply with ADAAG 4.27.3 and 4.27.4. However, an exemption from this requirement is provided where the container has a hinged, sliding or other cover and is situated where it is subject to large animal intrusion, thus dictating animal-resistant controls. Current designs for controls and operating mechanisms preclude providing secure storage of trash or recycled material from large animals, and still meet the reach and operating force requirements of ADAAG 4.27.4. Where problems exist with large animal intrusion, the necessity of protecting the health of the user and the animal populations override accessibility requirements.

WOOD STOVES/FIREPLACES

Proposed 16.9.1 requires each wood stove and fireplace to comply with this section. Wood stoves and fireplaces are designed and constructed to provide warmth to the user. Secondarily, they might also be used for cooking.

Proposed 16.9.2 requires that a clear space 48 inches deep minimum, and 48 inches wide minimum be provided from all usable portions of the wood stove or fireplace. This is consistent with space requirements for other elements in outdoor developed facilities, such as fire rings and grills. The 48 inch dimensional requirement allows for front and side approach. The committee agreed that the extra space required beyond current ADAAG requirement of 30 inches by 48 inches is warranted in this case where safety is paramount. An exception is provided to reduce this requirement to 36 inches minimum depth where one or more of the conditions in section 16.1.1 exists.

Proposed 16.9.3 requires the controls for operation of wood stoves and fireplaces to comply with ADAAG 4.27. This is consistent with existing ADAAG.

Question: Are there controls and operating mechanisms for fireplaces available that will meet the requirements of ADAAG 4.27? If not, what modifications will allow for most operating mechanisms of woodstoves and fireplaces to meet this provision.

Proposed 16.9.4 requires the clear space slope in all directions be 1:50 maximum. Exception 1 allows for a 1:33 maximum for proper drainage. This requirement is consistent with other provisions in section 16. It also provides an element of safety for the operator so that the controls may be operated with minimal risk due to design. Exception 2 allows a departure from this provision where one or more of the conditions in 16.1.1 exist.

Proposed 16.9.5 requires the clear space surface to be firm and stable. This is consistent with other provisions of section and provides a safe place from which to operate the wood stove or fireplace. Where one or more of the conditions in 16.1.1 exist, this provision does not apply.

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