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Understanding ADA Requirements for Historic Properties

The passing of the Americans With Disabilities Act (ADA) made access to places of public accommodation a civil right and is applicable to all properties, regardless of age or status as a ‘historic property.’ In other words, all places of public accommodation must remove barriers where feasible with no exclusions or exemptions. However, some historic properties may be eligible for leniencies in regard to meeting ADA standards.

To be eligible for implementation discretion, a property must fulfill one of the three requirements for qualification as ‘historic’ as recognized by the ADA. A property may be considered historic by ADA standards if it is listed on the National Register of Historic Places; if it is eligible to be listed on the National Register of Historic Places; or if the property is designated as historic under state or local law. Should a property fulfill one of these requirements, the ADA recognizes the importance of conserving the building’s historic nature while improving accessibility measures.

The ADA follows steps outlined by the National Parks Service’s Presentation Brief 32 improving accessibility in historic buildings. Steps introduced in this Brief include:

  1. Examining the property’s historical significance and identifying character-defining features.
  2. Completing an accessibility assessment to identify areas of non-compliance with ADA standards.
  3. Evaluating options for correction of non-compliant items while maintaining the historic integrity of the building.

If it is believed that ADA standards cannot be feasibly met without threatening or destroying the historic significance of a building, the next step is to consult with a State Historic Preservation Officer (SHPO) about possible exceptions. Exceptions may fall under one or more of the three main categories defined by the ADA: accessible routes exceptions, entrances exceptions, and toilet facilities exceptions.

Accessible Routes exceptions allow a historic property owner to supply only one accessible route from a site arrival point to an accessible site entrance. This exception also allows for only one accessible route on the same level as the accessible entrance. Entrances exceptions allow for the historic property’s accessible entrance to not be the main entrance to the building, including an unlocked entrance not used by the general public or a locked entrance with a notification system. Toilet facilities exceptions require only a single accessible restroom, which may be uni-gender.

Should the exceptions provided by the ADA still not allow for non-threatening removal of accessibility barriers, alternative methods of improved accessibility may be accepted on a case-by-case basis with SHPO approval. Accessibility consultants may also be able to help choose noninvasive methods for improved accessibility that do not harm the building’s historic character.

Read the full blog by Christy Kim, AIA, CASp on