Handbook RE-4, Standards for Facility Accessibility
We have revised Handbook RE-4, Standards for Facility Accessibility, to be consistent with new federal regulations published by the U.S. Access Board in July 2004. The new standards will become effective for the Postal ServiceTM on October 1, 2005.
The accessibility guidelines issued by the Access Board include scoping chapters on enforcement of the Americans with Disabilities Act (ADA). However, as a matter of law, the Postal Service is subject to the Architectural Barriers Act (ABA), rather than the ADA. Accordingly, the ADA scoping chapters were not included in the revised Handbook RE-4. In addition, some sections in the guidelines published by the Access Board pertain to recreational and other facilities that normally are not included in Postal Service facilities. Accordingly, some of this material was not included in the revised handbook. If these standards are relevant for a particular Postal Service facility, reference should be made to the complete guidelines published by the Access Board on July 23, 2004 (36 CFR parts 1190 & 1191) and available on the Access Board's Web site at www.access-board.gov.
The revised RE-4 contains text, figures, and advisory information. Please note that while the advisory material often provides useful information, it should not be construed as mandatory. The accessibility guidelines, as formally adopted by the Postal Service and published in the Federal Register, specifically exclude these advisories.
Terminology. The new accessibility guidelines require that certain terms be defined by the participating federal agencies. Section F202.6.2 requires that "primary function areas" be defined and section F202.4 contains requirements for alterations affecting "primary function areas" stating, "...an alteration that affects or could affect the usability of or access to an area containing a primary function shall be made so as to ensure that, to the maximum extent feasible, the path of travel to the altered area, including the rest rooms, telephones, and drinking fountains serving the altered area, are readily accessible to and usable by individuals with disabilities, unless such alterations are disproportionate to the overall alterations in terms of cost and scope as determined under criteria established by the Administrator of...the United States Postal Service."
Primary Function Areas. The primary function of the Postal Service is to provide mail service for our customers that includes accepting, distributing, transporting, and delivering the mail. Two essential facilities for fulfilling these functions are (1) customer lobby areas where customers conduct their retail transactions, access mail depositories, and Post OfficeTM boxes and (2) workroom areas where Postal Service employees distribute the mail and perform other core postal operations. Therefore, for purposes of the accessibility guidelines applicable to the Postal Service under the Architectural Barriers Act, two "primary function areas" are identified: Customer Lobbies and Workroom Areas.
Disproportionality. According to section F202.4, "alteration" of elements in a primary function area can trigger a requirement to make accessibility improvements along the path of travel to the area and improvements to rest rooms, telephones, and drinking fountains that serve the altered area if the alteration "affects or could affect the usability of or access to an area containing a primary function." It is conceivable that almost any repair or alteration project in a "primary function area" could affect the usability of the area. Therefore, a literal interpretation of this provision could require an expansion of the scope of virtually any alteration in a primary function area, regardless of the size and scope of the original project. According to section F202.4, accessibility improvements must be made to the path of travel to the altered area and to rest rooms, telephones, and drinking fountains that serve the altered area "unless such alterations are disproportionate to the overall alterations in terms of cost and scope."
For purposes of the accessibility guidelines applicable to the Postal Service under the Architectural Barriers Act, two criteria must be considered in making a determination whether accessibility improvements are disproportionate to the cost and scope of the original alteration: a "magnitude threshold" for the original alteration and a "maximum percentage threshold" for the accessibility alteration.
Magnitude Threshold. It is anticipated that, in most cases, a significant additional effort would be required to assess physical conditions along the path of travel and for rest rooms, telephones, and drinking fountains that serve the altered area, and to determine the scope, budget, and appropriate design requirements for any corrective alterations. Unless the original alteration is of substantial magnitude, a disproportionate effort would be devoted to such investigation, design, and administration leaving few, if any, funds to accomplish corrective work. Accordingly, a "magnitude threshold" is established such that no accessibility improvements to the path of travel, or to any associated facilities, will be required under F202.4 for alterations that have an estimated total cost less than 20 percent of the fair market value of the facility.
Percentage Threshold. For alterations subject to F202.4 that meet or exceed the "magnitude threshold," the maximum cost for accessibility improvements to the path of travel, including all costs for accessibility improvements to rest rooms, telephones, and drinking fountains that serve the altered area, will not exceed 20 percent of the total cost of the original alteration. Costs for accessibility improvements in excess of the 20 percent threshold will be deemed "disproportionate."
Handbook RE-4 is available on the Postal Service PolicyNet Web site:
• Go to http://blue.usps.gov.
• Under "Essential Links" in the left-hand column, click on References.
• Under "References" in the right-hand column, under "Policies," click on PolicyNet.
• Click on HBKs.
(The direct URL for the Postal Service PolicyNet Web site is http://blue.usps.gov/cpim.)
Handbook RE-4 will be available from the Material Distribution Center (MDC) at a later date and we will release the ordering information at that time.
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