Accessible bleachers and social stairs located at Title II and Title III facilities are required to comply with the Americans with Disabilities Act (ADA). This article will discuss the ADA scoping requirements for bleachers and social stairs in State and local government facilities, public accommodations, and commercial facilities. Federal regulations 28 CFR 35.151(g) and 28 CFR 36.406(f) and, 2010 ADA Standard 221, cover scoping requirements for accessible assembly areas including bleachers and social stairs. Standard 802 covers technical requirements for accessible assembly areas including bleachers and social stairs. The photo above is representative of an accessible bleacher installation. The photo below is representative of social stairs.

Bleachers and social stairs are another form of assembly areas. As such, these installations must follow the ADA Standards for assembly areas with one exception. Regarding vertical dispersion, bleachers and social stairs are not required to provide wheelchair spaces in rows other than rows at points of entry to the seating. So if you enter the bleachers or social stairs at the top, the wheelchair spaces only have to be provided at the top row. Same for the bottom. The photo below is the lower row of seats in a bleacher installation where wheelchair spaces and companion seats are installed at the point of entry to the bleachers.

Points of entry to bleacher seating may include, but are not limited to, cross aisles, concourses, vomitories, and entrance ramps and stairs. Vertical, center, or side aisles adjoining bleacher seating that are stepped or tiered are not considered entry points. The photo below is representative of a ramp leading to the bleacher seating.

Bleachers and social stairs should have the required number of wheelchair spaces and companion seats and these features should be located within the footprint of the general seating area. In the photo below, a row of bleacher seats in a gymnasium has been recessed to provide room for wheelchair spaces within the foot print of the bleacher installation.

In the photo below a bleacher installation has permanently installed companion seats. Note that one companion seat is wide enough for two individuals. So that two-person companion seat can serve two different wheelchair spaces.

Where the circulation path provided is wider than the required accessible route width, the wheelchair space(s) may intrude into that portion of the circulation path that is provided in excess of the required route width. The photo below is representative where wheelchair spaces on the left side of the circulation path do not overlap the accessible route that leads to the bleacher seats.

If temporary bleacher seating is installed at an assembly area where permanent seats already exist, the seating chart for wheelchair spaces required should include all seats, temporary and fixed/permanent, when calculating the number of accessible wheelchair spaces and companion seating required. However, the accessible wheelchair spaces and companion seating should not be located in the temporary seating unless the temporary seating is installed at a venue where there is no permanent seating, then accessible wheelchair spaces and companion seating can [and should] be installed within the temporary seating.

Most press boxes greater than 500 square feet in size and located within an assembly area should be on an assessible route. An accessible route is not required to press boxes in bleachers that have points of entry at only one level provided that the aggregate area of all press boxes is 500 square feet (46 m2) maximum. An accessible route shall not be required to free-standing press boxes that are elevated above grade 12 feet (3660 mm) minimum provided that the aggregate area of all press boxes is 500 square feet (46 m2) maximum [2010 ADA Standard 206.2.7]. The photo below is a freestanding press box more than 12 feet above grade, with only one entry, and a size of less than 500 SF. So an accessible route to the press box is not required.

Note that an assembly area with a press box may require an assistive listening system (ALS) if audible communication is integral to the use of the assembly area. In other words, if a microphone and speakers are used to communicate to the seating area from the performance area, in this case the press box, ALS should be available.

Social stairs are fixed installations so the requirements for wheelchair spaces should be included in the initial design. The ADA Standards do not provide requirements for the height or depth of social stairs. The photo below is representative of social stairs.

Note that the term “social stairs” can be misleading because the sitting area is not a stair system in any legal sense. The sitting surfaces of social stairs do not satisfy the building code or ADA for dimensions of stair systems and should be considered sitting areas similar to bleachers.

SUMMARY

Bleachers and social stairs are forms of assembly areas. As such, these installations should comply with the ADA Standards for assembly areas. Social stairs are not stairs as defined by any code and should be considered as sitting areas similar to bleachers.

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If you observe a facility, bleachers, or social stairs that are not ADA compliant and you would like to know how to proceed, please see the link at What To Do When A Building Is Not ADA Compliant or Accessible.

ADA Inspections Nationwide, LLC, offers ADA/ABA/FHA accessibility compliance inspections for buildings and facilities, as applicable to the different laws, and expert witness services with respect to ADA/ABA/FHA laws for building owners, tenants and managers. Also, ADAIN offers consulting for home modifications as a CAPS consultant for people wishing to age in place in their homes. For a complete list of services please see ADAIN Services.

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