owners have certain obligations, a tenant may make internal
modifications that don’t satisfy ADA. Make sure the lease is clear
who is ultimately responsible in those situations.
Solutions to Improve Emergency Response
One of the difficulties with ADA compliance is the lack of specifics in the law. Because it’s not a building code, there’s nothing
in the mandate that will tell you which accommodations you are
required to make.
For guidance on devices and structural modifications, you
can turn to any number of codes: NFPA, International Building
Code, ANSI A117.1 – Standard for Accessible and Usable Buildings
and Facilities, and OSHA regulations for means of egress and
emergency protocols. Multifamily property managers should review HUD’s Fair Housing Act Accessibility Guidelines and those
in federal facilities need to comply with the Uniform Federal Accessibility Standards (UFAS). It’s worth checking into language
specified in your local and state regulations as well.
“Considering that ADA calls for measures that are readily
achievable, perfection is not the goal. The worst thing owners
can do is say that because they can’t do a certain retrofit, they’re
not going to do anything at all,” Muse stresses. “If there are 10
things that could improve your facility’s life safety but you only
have the budget for three, start there.”
One system to focus on is your mass notification. Rather than
a standard horn, a combination of visual and audible devices will
ensure anyone with a sensory impairment has the opportunity to
receive emergency alerts.
“We recommend a multilayered mass notification system
with visible and colored strobe lights that are paired with voice
messages,” Bauer says. “The alerts can be preprogrammed or
broadcast live to differentiate between emergencies. For another
way to reach those with hearing difficulties, look into software
packages or services that provide global calling, mass texting,
and email alerts.”
If it’s not feasible to use intelligible audio throughout your
building, you can designate a central location that people should
meet at to receive more instructions. These spots are often
equipped with electronic displays in addition to voice communi-
cations, says Wilson.
Digital and tactile signage with raised letters is another
overlooked area, Bauer adds. These types of signs can help those
with sight difficulties and be placed in locations where voice
communications aren’t available.
“Another trend I’m seeing is that people are using message
boards and digital signage to provide visual emergency instructions, particularly in areas of refuge,” says Wilson.
Beyond a standard illuminated EXIT sign, consider adding
models with compact lights that can flash for additional wayfinding. Even low levels of smoke can make an exit hard to see, much
less for those with vision impairments. Take it a step further and
use wayfinding with Braille and raised lettering. If signs have a
tactile component, however, they need to be placed at a height
that is easily reached and without obstructions. You can even
specify models that include audible alarms or voice notification.
“It’s also important to consider the color of your signage.
Depending on the color combination, someone who is colorblind
may be unable to see the lettering,” notes Muse. “It doesn’t mean
that you get rid of all of your red signs, for example, but maybe a
Evacuation planning for wheelchair users is paramount if
your building has stairs. It may be prudent to invest in a stair
2) Overlooking Areas of Refuge
Do you have a tornado shelter, an assembly point in the parking lot, or rooms that convert to lockdown mode? You can direct
people with impairments to these meeting spots, but what happens once they reach the area of refuge and need to wait until a
situation is resolved? Owners should evaluate locations where
people congregate in an emergency, says Bauer.
These include any areas that double as a safety zone, such as a
gymnasium, cafeteria, auditorium, or assembly hall. These sites
should have accommodations that address mobility and communication assistance, Wilson emphasizes.
3) Blocking the Path of Egress
Whether occupants need to shelter in place or evacuate the
building, it’s imperative their path of egress is free of obstructions. Consider how disorienting an emergency can be – you
don’t want the built environment adding to the chaos. Tactical
and visual signage, properly marked exits, uncluttered corridors, and easy-to-open doors will ensure people can move
“Door clearances are a big one,” adds Fraser. “You have to have
4) Forgetting Evacuation Plans and Drills
18 inches between the edge of the door on the latch side and any
wall or nearby objects. That way, a wheelchair can approach on
the pull side and open the door freely.”
“If your building has automatic doors or push buttons, look at
how they respond during lockdown mode. The ideal sequence
should call for the sensors or push buttons to deactivate from the
outside so an intruder can’t use them but remain in operation on
the inside so the path of egress isn’t blocked,” notes Wilson.
Has it been over a calendar year since you ran a drill or
updated your emergency plan? It’s critical you have current
documentation for your life safety protocol, particularly as these
procedures should outline provisions for individuals who require assistance, says Muse. For a checklist of accommodations,
see sidebar on page 37.
While ADA doesn’t legally cover transitory disabilities, that
doesn’t mean owners are off the hook from ensuring the safety
of an occupant who’s temporarily impaired, says Wilson. Think
about the student on crutches, the employee recovering from
back surgery, or a worker who’s injured his or her hand. Even
medical conditions such as asthma, pregnancy, and obesity can
create mobility limitations that could warrant additional assistance. What about occupants who become impaired as a result
of an emergency? What happens if someone’s ability to move or
communicate becomes momentarily compromised?
Running drills and tabletop exercises is the only way to identify
these life safety gaps before they put someone at risk. Also remember that exercises should cover a range of emergencies beyond fire,
such as storm, earthquake, flood, biochemical, and active shooter.
5) Failing to Put Someone in Charge
If life safety is a direct responsibility of your department, make
sure one of your team members is assigned to keep tabs on it.
ADA isn’t a checklist that can be completed and then forgotten
about, argues Muse – it’s something you should build into your
facility’s operational practices.
“It’s incumbent upon each company to designate a safety
officer who has ADA compliance in his or her scope of duties,”
Be careful of lease situations, adds Muse. While building