ADA Compliance For Windows

By Steve Fronek, P.E.

To help ensure that fresh air and a connection with the outdoors are made accessible to people with physical disabilities, windows capable of meeting operating force and motion requirements of ICC/ANSI A117.1 “Accessible and Usable Buildings and Facilities” are being specified. In addition to forces and motions, the designer must ensure operable windows are located and detailed in a way that meets the “reach” limitations of ICC/ANSI A117.1.

Codes And Compliance

Operable windows intended for use in accessible spaces are often mistakenly called “ADA windows.” The Americans with Disabilities Act (ADA) is a law, not a building code, specification, or test method, and as such, it is missing many of the necessary technical requirements for compliance testing. Two of the government agencies that have regulations to help ensure compliance are the U.S. Department of Justice, “ADA Standards for Accessible Design” and the U.S. Access Board “ADA and ABA Accessibility Guidelines (ADAAG).”

ADA windows
(Photo: Wausau Window and Wall Systems)

In addition to U.S. governmental agencies, local authorities having jurisdiction (AHJs) sometimes adopt accessibility requirements for operable windows, including the Texas Department of Aging and Disabilities Services (TDADS), Chicago Public Schools (CPS), and the Chicago Mayor’s Office for People with Disabilities (MOPD), as well as the New York City Building Code.

Local AHJs should be consulted in determining applicability and in defining detailed requirements for any given structure or space. Like any code issues, the local AHJ makes the final rules. Most, but certainly not all, AHJs in the U.S. adopt the International Building Code (IBC) for new construction. Requirements for renovation and window replacement vary widely by jurisdiction and must be investigated on a project-specific basis.

Efforts currently are underway to have the American Architectural Manufacturers Association (AAMA) 513-14 “Standard Laboratory Test Method for Determination of Forces and Motions Required to Activate Operable Parts of Operable Windows and Doors in Accessible Spaces” referenced as a compliance test method in the next version of ICC/ANSI A117.1. This updated ICC/ANSI A117.1 publication likely will include modified requirements for operating force of hung and sliding windows, as well as for sliding glass doors. Facility executives interested in accessibility issues should monitor status of the A117.1 update and its subsequent referencing in the IBC 2018 Edition closely.

ADA windows
Examples of window hardware (Photo: Wausau Window and Wall Systems)

Product Design

It should not be expected that standard “off the shelf” operable windows could be adjusted to meet accessibility requirements, even if properly located in plan and section. Especially on large windows, achieving ease-of-operation with restricted motion likely will require specially designed compression weather-seals and low-friction hardware components. Hardware must be selected that ensures windows do not fall shut under their own weight, or require two hands to hold closed and lock simultaneously.

Keep in mind that motorized and mechanical operators have long been available for almost any window type. As long as forces and motions necessary to activate and operate motorized and mechanical features meet the requirements of ICC/ANSI A117.1, these may be deemed accessible operator types.

Testing And Installation

Production line testing of operating force can help ensure that windows leaving the factory are compliant with AAMA 513-14 requirements. Accessible operating window products will require additional care in installation, final adjustment, and maintenance to achieve and maintain compliance. Plumb, square, and level installation is critical. Building settlement can affect operating forces, and necessitate post-installation adjustment.

ADA windows
Example reach diagram for ADA compliance (Image: Wausau Window and Wall Systems)

Standard operable windows cannot always be “adapted” to achieve accessibility at a later date. The fieldwork necessary will vary widely with application and window type. Adaptation may be as simple as hardware adjustment, or virtually impossible without complete reconfiguration of window openings and surrounding conditions. If adaptability is desired, the facility executives are strongly encouraged to develop a window accessibility plan early in the design process, then have products detailed and specified accordingly.

Product development and compliance testing efforts at most manufacturers are well underway, to provide a broad selection of accessible window types, both manually operated and motorized. Whether required by code or not, accessible operating windows may be a very desirable feature of occupied spaces in skilled nursing and personal care facilities; condominiums, apartments, and hotels; as well as classrooms and dormitories. Accessible operating windows help ensure that fresh air and a connection with the outdoors are made accessible to people with physical disabilities.

Another Angle: NAFS Operating Force Limitations – A Comparison

Accessibility and barrier-free design notwithstanding, the North American Fenestration Standard AAMA/WDMA/CSA 101/I.S.2/A440-11 (NAFS), referenced in IBC-2015 sets different operating force limits for standard CW and AW Performance Class windows most commonly used in commercial buildings. Note the inherent differences between window types.

ADA windows

NAFS defines CW Class windows as: “…commonly used in low-rise and mid-rise buildings where larger sizes, higher loading requirements, limits on deflection, and heavy use are expected.”

NAFS defines AW Class windows as: “…commonly used in high-rise and mid-rise buildings to meet increased loading requirements and limits on deflection, and in buildings where frequent and extreme use of the fenestration products is expected.”

The measurement lbf means pounds of force. For example, accessible projected windows are available that, using a force of 5 pounds (5lbf) or less may be operated with one hand to unlock, open, close and lock, without tight grasping, pinching or twisting of the wrist.

ADA windowsFronek leads Wausau Window and Wall Systems’ new product development, marketing, field service, technical support and general research. He is the past-president the American Architectural Manufacturers Association (AAMA), and has served on many AAMA’s committees and task groups, including guiding the evolution of thermal performance standards as they exist today. Fronek is a member of the Lawrence Berkeley National Laboratory’s (LBNL’s) High-performance Building Façade Solutions Public Advisory Committee and a LEED Green Associate.