HUD’s 7 Requirements for Housing Prepared for Creating Inclusive Communities By Jerry Christiansen Purpose: Introduce 7 HUD Requirements for Housing Describe some of the requirements Provide opportunity for discussion. In other words: If you have a question, raise your hand and ask.

Who is this guy and what is Freedom Resource Center? Accessibility Specialist Freedom CAPS Disabilities Rights Organization I have attended training on ADA and Housing (HUD) requirements Certified Aging In Place Specialist, designation from NAHB that requires training Freedom provides advocacy and training to help people at any age, with any disability to live as independently as they want to and can. We are not an emergency hotline, a goal is to help people learn how to avoid the emergencies.

The accessibility requirements of the Fair Housing Act are intended to provide usable housing for persons with disabilities without necessarily being significantly different from conventional housing. Note the underlined word. Not accessible housing, USABLE housing. What does that mean?

HUD’s Requires ‘Covered Units’ to have 1- Accessible building entry on Accessible route 2- Accessible public and common use areas 3- Usable doors 4- Accessible route into and through unit 5- Accessible switches, outlets, controls 6- Reinforced walls for grab bars 7- Usable kitchens and bathrooms Describing ‘Covered Units’ would take the entire time period. Very basic: apartments on ground floor and apartments on every floor served by an elevator are ‘covered units’. By HUD’s definition every building will have a ‘ground floor’. Some buildings may have more than one ground floor, ie a building on a sloped lot can have entrances on opposite sides that are both at ground level. Some exceptions for small buildings exist. Let’s look at the list of requirements. We will expand on each item, this is just a list.

HUD’s Requires ‘Covered Units’ to have 1- Accessible building entry on Accessible route 2- Accessible public and common use areas 3- Usable doors 4- Accessible route into and through unit 5- Accessible switches, outlets, controls 6- Reinforced walls for grab bars 7- Usable kitchens and bathrooms A couple words stand out. Accessible is used 5 times, usable shows up twice. Describing and defining Accessible would require several days. That means we will just mention the basics. Accessible for items 1, 2, and 4 share many of the same features. Let’s do a brief and basic description of the physical requirements of those.

If “accessible”, features must meet ADA requirements If “accessible”, features must meet ADA requirements. IBC contains all of ADA, in some cases IBC is more stringent. 36” wide, with 60” wide passing spaces no more than 200’ apart May narrow to 32” wide for no more than 2 ft long (doors must have 32” wide clear space) Maneuvering space on both sides of doors, dimensions depend on if door swings in or out and approach to door. Protruding objects between 27” and 80” above floor no more that 4” Firm, stable, slip resistant surfaces Slope: 5% maximum in direction of travel, 2% maximum cross slope. If steeper than 5%, must have ALL ramp features. Ramps cannot be steeper than 8.3% slope. Stairs are NOT accessible, but must meet accessibility guidelines for stairs.

Thresholds at Accessible Doors Usually only on exterior doors. Threshold need some elevation change to keep water from running in. Sliding doors (often found leading to patios/balconies) have design requirements, too. We don’t have time to look at them. Other accessible door requirements: 1) Maximum force to operate ANY interior door is 5 pounds. What about fire doors? 5 pounds is the maximum force for interior doors. No maximum set for exterior doors. 2) If equipped with door closer, minimum time to close 3) Hardware must be operable with closed fist. 4) No tight grasping, pinching or twisting Power openers are NOT required by ADA or Housing.

HUD’s Requires ‘Covered Units’ to have 1- Accessible building entry on Accessible route 2- Accessible public and common use areas 3- 4- Accessible route into and through unit 5- 6- 7- Let us look back at the list. All these items need to meet the Accessible requirements. Let us look at a sample diagram and see how this plays out.

Note accessible route(s) from the left Note accessible route(s) from the left. Drop off area, route to door, door, lobby, reception desk, drinking fountain, elevator, seating area, mailboxes, game room, note raised area in corner (#10) permissible if . . , exercise room with showers and toilets – access to room and equipment, laundry room – access to equipment, route to garage – note stairs and ramp, accessible spaces in parking, route to outdoor parking, wheelchair seating options in auditorium, ramp and stairs to get to auditorium, ramp and stairs to get on stage. The route from parking, valet drop off, bus stop must be accessible: 1) width, 2) slope, 3) surface 4) ramp features is needed. Parking must be accessible, we are not going to look at that in this session. The entry to the building must be accessible: 1) threshold, 2) width, 3) hardware, 4) closing time, 5) maneuvering space Can there be a 6” step to the landing of the accessible entry? NO, the maximum vertical change (step) is ¼ inch. Accessible routes must present so anyone can get to the public areas (laundry room, pool, bar, dining area, etc). Once at the public area, must be able to enter and use the public area. Does housing require a dining area? NO, but if a dining area exists it must be served by an accessible route and the dining area must be accessible. Would putting all the tables that a wheelchair could access in one corner be acceptable? NO Any route from the building entry to the covered apartment entry must have all the accessible features. The exterior side of the door to the apartment must be accessible and the person needs to be able to get to all areas within the apartment. Some exceptions exist for multi-story town houses and sunken living rooms.

Another look at accessible route to public and common areas Another look at accessible route to public and common areas. An accessible route needs to lead to the various elements. The elements themselves need to be accessible.

Accessible route into and through unit To me, accessible route into the unit would include accessible door, needs same features as entrance door to building. HUD says that the public side of the entrance door must be accessible. Accessible route needs to provide access to spaces inside unit. Some exceptions exist for certain sunken areas and lofts. Accessible route into kitchen and bathroom must connect to the Clear Floor Space (CFS) at each fixture in those rooms. We will look at these in more detail later. If bathroom or kitchen served by two entrances, both doors must provide accessible route

HUD’s Requires ‘Covered Units’ to have 1- Accessible building entry on Accessible route 2- Accessible public and common use areas 3- 4- Accessible route into and through unit 5- Accessible switches, outlets, controls 6- 7- Back to the list. We did a brief into to #1, #2 and #4 The next item on our list is #5 – Accessible switches, outlets and controls. What makes switches, outlets and controls accessible?

Clear Floor Space and Reach Range An accessible route must led to Clear Floor Space at the element (device) CFS is a 30” X 48” rectangle. What can be in the CFS? Nothing, it is CLEAR FLOOR SPACE. Includes: thermostats and other HACV controls, light switches and outlets. Some outlets may be in-accessible, if other outlets serving same space are provided. For example, outlet(s) may be in corner of kitchen counter if other accessible outlets serve the same counter area. Force to operate and type of motion not included in Guidelines. Circuit breakers and dedicated outlets (outlet microwave is plugged into) not required to be accessible Diagram 2 shows vertical reach range 15” to 48”. Early ADA guidelines allow up to 54” in certain cases. 2010 Standards changed to 48” max.

Height over counters If counter no more than 20” deep, maximum height still 48”. If counter is between 20” and 25” deep, maximum height is 44” Counter may not be more than 25” deep if person is to reach to back.

Accessible HACV Control? This picture was taken in an ‘accessible’ hotel room. Hotels fall under ADA, not our point of conversation. The picture is used to show that if the accessible route is not provided, a person with a mobility device can not operate the controls. If this were in a dwelling, the person could not live independently. One option may be to install remote control on the HACV unit.

HUD’s Requires ‘Covered Units’ to have 1- Accessible building entry on Accessible route 2- Accessible public and common use areas 3- Usable doors 4- Accessible route into and through unit 5- Accessible switches, outlets, controls 6- 7- Back to the list. We have looked at all the ‘accessibles’ on the list. Accessible doors need to meet all the ADA guidelines: width, opening force, hardware, CFS, closing speed Usable doors do not need to meet all the ADA guidelines. Where can usable doors be? Usable doors can be inside the covered unit. Passage doors in common and public spaces need to meet accessible guidelines.

Accessible Usable 32” min 32” nominal (-3/8) CFS approach CFS not required Hardware Hardware accessible may be accessible Accessible width 32” minimum, except for door hardware. Usable width may be as narrow as 31 5/8 “ CFS, for example you will see in bathroom in a minute that the 18” on latch side of door is not required Hardware: accessible operable with closed fist; usable may be standard knob

HUD’s Requires ‘Covered Units’ to have 1- Accessible building entry on Accessible route 2- Accessible public and common use areas 3- Usable doors 4- Accessible route into and through unit 5- Accessible switches, outlets, controls 6- Reinforced walls for grab bars 7- Back to the list. Not much left. Let us look at #6 next. Grab bars are not required, but the reinforcement for the grab bars is required.

Reinforcement areas These are the minimum. Vertical bars were not required along side toilet in IBC, still not required by ADA. Some users like a vertical bar by bathtub. HUD recommends, but does not require that reinforcement to be provided. Notice the style of grab bar by toilet. Reinforcement for this style of bar is larger than for horizontal bar along side toilet. HUD specifies reinforcement in floor for grab bars that mount to back wall, come our horizontally by toilet, then turn down and mount on floor.

The cost of not doing it right Recently we worked with an individual that requested grab bars in tub as a reasonable modification. Reinforcement was not in walls behind plastic tub surround. The tub is on the other side of this wall. The white circle is a repair to a wall after reinforcement was added. A crew cut out sheetrock, installed reinforcement and then repaired the sheetrock. One of my co-workers took this picture before the wall was repainted. Landlord/owner paid to install the reinforcement, fortunately for them this was in a hallway and not someone else’s bedroom. Tenant could be required to pay for grab bar and installation of grab bar.

HUD’s Requires ‘Covered Units’ to have 1- Accessible building entry on Accessible route 2- Accessible public and common use areas 3- Usable doors 4- Accessible route into and through unit 5- Accessible switches, outlets, controls 6- Reinforced walls for grab bars 7- Usable kitchens and bathrooms Back to the list. Anyone remember what is left? Bathrooms and kitchens are not required to be accessible. HUD’s ‘usable’ kitchens and bathrooms are far from accessible.

Usable kitchens must have Minimum clear floor space at fixtures and appliances Minimum clearance between counters Additional spec for U-shaped kitchen Accessible route into and through Accessible switches and controls Number 1 – The center of the clear floor spaces (CFS) must be centered on the fixture/appliance. Overlapping of 36” accessible route in to kitchen and clear floor spaces at all devices is supposed to provide enough space for person to position themselves safely. Number 2 – 40” between counters, measured at tightest space, does not include handles or controls. i.e. cannot measure between counter tops and then put refrigerator in that sticks out another 3” Number 3 – for example, 60” turning space is required in U-shaped, but not other shapes. We will see this in a bit. Numbers 4 and 5 are not spelled out in HUD Design Manual in the Usable Kitchen section. They are part of the “List of Seven” and need to be provided.

Galley (or pass through) kitchen Galley, or pass through, style kitchen. Note the CFS at each appliance. The center of CFS at the sink must line up with the center of the sink. Part of the CFS extends into the hallway, outside of the kitchen. Could a person have the oven door open and drive by with a wheelchair? To access the oven, a wheelchair user would have their toes under the oven door. A refrigerator door that opens 180o is preferred, but not required.

U-shaped kitchen U-shaped kitchen with range at base of U. 60” turning circle required if sink, range or cook top at base UNLESS sink or cook top has removable base cabinet. Layout in diagram 1 looks tight for wheelchair. 6” of space on either end of CFS when centered on range. The layout on the right shows removable base cabinet. Instead of 60” wide, this one is only 40” wide. The one on the right looks barely usable. How would a person in a wheelchair get into the refrigerator? Floor and walls inside of removable cabinet must be finished. Pipes and other devices in knee/toe space must be covered to prevent bruising or burning. So far kitchens shown are smallest possible with bare minimum appliances. If dishwasher, washer/dryer and or pantry added kitchen must get bigger.

Usable bathroom Accessible route to door w/ 32” clear opening Switches and controls in accessible locations Reinforced walls to allow grab bars to be installed Maneuvering space to allow entry, close & reopen door, exit Maneuvering space within bathroom to use fixtures HUD Design manual spells out first three items. We already discussed them, they are in the “List of Seven Items” required for covered dwellings. Apparently ‘maneuvering space’ does not mean the same thing as “accessible”.

Type A – Maneuvering Spaces 5’ 2” 9’ 4” HUD Type A, usable bathroom. Person using a wheelchair approaches the bathtub perpendicularly. Describe CFS provided to operate door and use fixtures. Note 18” on latch side of door is not required. Note dimensions of the room.

Type B – Maneuvering Spaces HUD Type B, usable bathroom. Person has a parallel approach to bathtub. The toes of a person using a wheelchair can hit wall at head of tub. Generally more accessible than Type A bathroom. Discuss CFS at fixtures. Again, note the 18” CFS on latch side of door is not required. Note dimensions of room. Instead of a closet opening into the hallway, that could be a bench at the head end of the tub that a person could use to transfer in and out of tub.

International Building Code Accessible Dwelling Type A Dwelling Type B Dwelling Type C Dwelling (Visitable) IBC contains everything in ADA and Housing. IBC has specifications beyond ADA and Housing. As one goes down the IBC list, the dwellings become less accessible. A HUD Type B bathroom is more accessible than a Type A bathroom. This can cause confusion when a person talking ‘Housing’ is interacting with a person talking “IBC’. The HUD Guidelines come from the Fair Housing Act. The most current manual I can find is dated 1998. The IBC is updated every 3 years. In some cases, you may want to consult a building official to see if code has been met. When dealing with items that may not be HUD or code compliant, it is important to know 1) when the building was built, 2) when the last alterations were done and what was altered, 3) was building built with government funding, 4) does landlord/owner receive government funding.

Thanks for your time! Questions?

Jerry Christiansen Freedom Resource Center 2701 9th Ave. S, Ste., H. Fargo, ND 58103 jerryc@freedomrc.org Phone: 701-478-0459 800-450-0459