Guidance for ADAAG Applicability for Passenger Rail Equipment

Sec. Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s)

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(a) New, used and remanufactured intercity rail cars, to be 

considered accessible by regulations in part 37 of this 

title shall comply with this subpart to the extent required 

for each type of car as specified below.

For Railcar features that are reviewed and agreed improvements by the Stakeholders and 

ADA action groups the process for granting equivalent facilitation should be clarified.

(a)(1) Single-level rail passenger coaches and food service cars 

(other than single-level dining cars) shall comply with 

§§38.113 through 38.123 of this part. Compliance with 

§38.125 of this part shall be required only to the extent 

necessary to meet the requirements of paragraph (d) of 

this section.

(a)(2) Single-level dining and lounge cars shall have at least one 

connecting doorway complying with §38.113(a)(2) of this 

part connected to a car accessible to persons using 

wheelchairs or mobility aids, and at least one space 

complying with §§38.125(d) (2) and (3) of this part, to 

provide table service to a person who wishes to remain in 

his or her wheelchair, and space to fold and store a 

wheelchair for a person who wishes to transfer to an 

existing seat.

902 Dining Surfaces and Work Surfaces 902.1 General. Dining surfaces and work surfaces shall comply with 

902.2 and 902.3. 902.2 Clear Floor or Ground Space. A clear floor space complying with 305 positioned for a 

forward approach shall be provided. Knee and toe clearance complying with 306 shall be provided. 902.3 

Height. The tops of dining surfaces and work surfaces shall be 28 inches (710 mm) minimum and 34 inches 

(865 mm) maximum above the finish floor or ground. 

This guidance does not extend to work surfaces for employees use; it is intended to 

ensure accessibility of passenger workstation and dining tables.

The requirement for crashworthy tables needs to be addressed as well as ergonomics. 

Design needs to be validated for ADA seating location based on height and knee 

clearences.

The addressed dimensions for such features as register and tray slide height may not be 

achievable in a rail car. This coupled with necessary aisle width restrictions leads to the 

design of ADA specific spaces and the use of service provider assistance in dining/galley 

situations.

Need minimum height to underside of surfaces, as crush zone tables per APTA SS-C&S018-12, if used, are thick.

Can 30 x 48 clear spaces intrude into adjacent aisle, as allowed in 49CFR Part 38.125(d)(2) 

“Such spaces shall adjoin and may overlap, an accessible aisle”?

Need minimum height to underside of surfaces, to insure wheelchair occupant may 

approach tray slide.

Some wheelchairs require more height!

Can 30 x 48 clear spaces intrude into adjacent aisle, as allowed in 49CFR Part 38.125(d)(2) 

“Such spaces shall adjoin and may overlap, an accessible aisle”?

Reference 49CFR Part 38.125

Some wheelchairs require more height!

Advisory 904.2 Approach. If a cash register is provided at the sales or service counter, locate the accessible 

counter close to the cash register so that a person using a wheelchair is visible to sales or service personnel 

and to minimize the reach for a person with a disability. 904.4.1 Parallel Approach. A portion of the counter 

surface that is 36 inches (915 mm) long minimum and 36 inches (915 mm) high maximum above the finish 

floor shall be provided. A clear floor or ground space complying with 305 shall be positioned for a parallel 

approach adjacent to the 36 inch (915 mm) minimum length of counter. EXCEPTION: Where the provided 

counter surface is less than 36 inches (915 mm) long, the entire counter surface shall be 36 inches (915 mm) 

high maximum above the finish floor. 904.4.2 Forward Approach. A portion of the counter surface that is 30 

inches (760 mm) long minimum and 36 inches (915 mm) high maximum shall be provided. Knee and toe 

space complying with 306 shall be provided under the counter. A clear floor or ground space complying with 

305 shall be positioned for a forward approach to the counter.904.5 Food Service Lines. Counters in food 

service lines shall comply with 904.5. 904.5.1 Self-Service Shelves and Dispensing Devices. Self-service 

shelves and dispensing devices for tableware, dishware, condiments, food and beverages shall comply with 

308. 904.5.2 Tray Slides. The tops of tray slides shall be 28 inches (710 mm) minimum and 34 inches (865 

mm) maximum above the finish floor or ground.

306.2 Toe Clearance. 306.2.1 General. Space under an element between the finish floor or ground and 9 

inches (230 mm) above the finish floor or ground shall be considered toe clearance and shall comply with 

306.2. 306.2.2 Maximum Depth. Toe clearance shall extend 25 inches (635 mm) maximum under an 

element. 306.2.3 Minimum Required Depth. Where toe clearance is required at an element as part of a clear 

floor space, the toe clearance shall extend 17 inches (430 mm) minimum under the element. 306.2.4 

Additional Clearance. Space extending greater than 6 inches (150 mm) beyond the available knee clearance 

at 9 inches (230 mm) above the finish floor or ground shall not be considered toe clearance. 306.2.5 Width. 

Toe clearance shall be 30 inches (760 mm) wide minimum.

306.3 Knee Clearance. 306.3.1 General. Space under an element between 9 inches (230 mm) and 27 inches 

(685 mm) above the finish floor or ground shall be considered knee clearance and shall comply with 306.3. 

306.3.2 Maximum Depth. Knee clearance shall extend 25 inches (635 mm) maximum under an element at 9 

inches (230 mm) above the finish floor or ground. 306.3.3 Minimum Required Depth. Where knee clearance 

is required under an element as part of a clear floor space, the knee clearance shall be 11 inches (280 mm) 

deep minimum at 9 inches (230mm) above the finish floor or ground, and 8 inches (205 mm) deep minimum 

at 27 inches (685 mm) above the finish floor or ground.
Sec. Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s)

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(a)(3) Bi-level dining cars shall comply with §§38.113(a)(2), 

38.115(b), 38.117(a), and 38.121 of this part.

902 Dining Surfaces and Work Surfaces 902.1 General. Dining surfaces and work surfaces shall comply with 

902.2 and 902.3. 902.2 Clear Floor or Ground Space. A clear floor space complying with 305 positioned for a 

forward approach shall be provided. Knee and toe clearance complying with 306 shall be provided. 902.3 

Height. The tops of dining surfaces and work surfaces shall be 28 inches (710 mm) minimum and 34 inches 

(865 mm) maximum above the finish floor or ground. 

Need minimum height to underside of surfaces, as crush zone tables per APTA SS-C&S018-12, if used, are thick.

Can 30 x 48 clear spaces intrude into adjacent aisle, as allowed in 49CFR Part 38.125(d)(2) 

“Such spaces shall adjoin and may overlap, an accessible aisle”?

Can 30 x 48 clear spaces intrude into adjacent aisle, as allowed in 49CFR Part 38.125(d)(2) 

“Such spaces shall adjoin and may overlap, an accessible aisle”?

Need minimum height to underside of surfaces, to insure wheelchair occupant may 

approach tray slide.

Reference 49CFR Part 38.125

Some wheelchairs require more height!

Advisory 904.2 Approach. If a cash register is provided at the sales or service counter, locate the accessible 

counter close to the cash register so that a person using a wheelchair is visible to sales or service personnel 

and to minimize the reach for a person with a disability. 904.4.1 Parallel Approach. A portion of the counter 

surface that is 36 inches (915 mm) long minimum and 36 inches (915 mm) high maximum above the finish 

floor shall be provided. A clear floor or ground space complying with 305 shall be positioned for a parallel 

approach adjacent to the 36 inch (915 mm) minimum length of counter. EXCEPTION: Where the provided 

counter surface is less than 36 inches (915 mm) long, the entire counter surface shall be 36 inches (915 mm) 

high maximum above the finish floor. 904.4.2 Forward Approach. A portion of the counter surface that is 30 

inches (760 mm) long minimum and 36 inches (915 mm) high maximum shall be provided. Knee and toe 

space complying with 306 shall be provided under the counter. A clear floor or ground space complying with 

305 shall be positioned for a forward approach to the counter.904.5 Food Service Lines. Counters in food 

service lines shall comply with 904.5. 904.5.1 Self-Service Shelves and Dispensing Devices. Self-service 

shelves and dispensing devices for tableware, dishware, condiments, food and beverages shall comply with 

308. 904.5.2 Tray Slides. The tops of tray slides shall be 28 inches (710 mm) minimum and 34 inches (865 

mm) maximum above the finish floor or ground.

306.2 Toe Clearance. 306.2.1 General. Space under an element between the finish floor or ground and 9 

inches (230 mm) above the finish floor or ground shall be considered toe clearance and shall comply with 

306.2. 306.2.2 Maximum Depth. Toe clearance shall extend 25 inches (635 mm) maximum under an 

element. 306.2.3 Minimum Required Depth. Where toe clearance is required at an element as part of a clear 

floor space, the toe clearance shall extend 17 inches (430 mm) minimum under the element. 306.2.4 

Additional Clearance. Space extending greater than 6 inches (150 mm) beyond the available knee clearance 

at 9 inches (230 mm) above the finish floor or ground shall not be considered toe clearance. 306.2.5 Width. 

Toe clearance shall be 30 inches (760 mm) wide minimum.

306.3 Knee Clearance. 306.3.1 General. Space under an element between 9 inches (230 mm) and 27 inches 

(685 mm) above the finish floor or ground shall be considered knee clearance and shall comply with 306.3. 

306.3.2 Maximum Depth. Knee clearance shall extend 25 inches (635 mm) maximum under an element at 9 

inches (230 mm) above the finish floor or ground. 306.3.3 Minimum Required Depth. Where knee clearance 

is required under an element as part of a clear floor space, the knee clearance shall be 11 inches (280 mm) 

deep minimum at 9 inches (230mm) above the finish floor or ground, and 8 inches (205 mm) deep minimum 

at 27 inches (685 mm) above the finish floor or ground.
Sec. Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s)

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(a)(4) Bi-level lounge cars shall have doors on the lower level, 

on each side of the car from which passengers board, 

complying with §38.113, a restroom complying with 

§38.123, and at least one space complying with 

§38.125(d) (2) and (3) to provide table service to a person 

who wishes to remain in his or her wheelchair and space 

to fold and store a wheelchair for a person who wishes to 

transfer to an existing seat.

902 Dining Surfaces and Work Surfaces 902.1 General. Dining surfaces and work surfaces shall comply with 

902.2 and 902.3. 902.2 Clear Floor or Ground Space. A clear floor space complying with 305 positioned for a 

forward approach shall be provided. Knee and toe clearance complying with 306 shall be provided. 902.3 

Height. The tops of dining surfaces and work surfaces shall be 28 inches (710 mm) minimum and 34 inches 

(865 mm) maximum above the finish floor or ground. 

It is recognized that some bi-level equipment may have the food services on the 

upper level. Inclusion of this section is intended for applicability to bi-level 

equipment where food service is provided on an accessible route.

Same comments as (a)(2) and (a)(3)

Same comments as (a)(2) and (a)(3)

Same comments as (a)(2) and (a)(3)

Advisory 904.2 Approach. If a cash register is provided at the sales or service counter, locate the accessible 

counter close to the cash register so that a person using a wheelchair is visible to sales or service personnel 

and to minimize the reach for a person with a disability. 904.4.1 Parallel Approach. A portion of the counter 

surface that is 36 inches (915 mm) long minimum and 36 inches (915 mm) high maximum above the finish 

floor shall be provided. A clear floor or ground space complying with 305 shall be positioned for a parallel 

approach adjacent to the 36 inch (915 mm) minimum length of counter. EXCEPTION: Where the provided 

counter surface is less than 36 inches (915 mm) long, the entire counter surface shall be 36 inches (915 mm) 

high maximum above the finish floor. 904.4.2 Forward Approach. A portion of the counter surface that is 30 

inches (760 mm) long minimum and 36 inches (915 mm) high maximum shall be provided. Knee and toe 

space complying with 306 shall be provided under the counter. A clear floor or ground space complying with 

305 shall be positioned for a forward approach to the counter.904.5 Food Service Lines. Counters in food 

service lines shall comply with 904.5. 904.5.1 Self-Service Shelves and Dispensing Devices. Self-service 

shelves and dispensing devices for tableware, dishware, condiments, food and beverages shall comply with 

308. 904.5.2 Tray Slides. The tops of tray slides shall be 28 inches (710 mm) minimum and 34 inches (865 

mm) maximum above the finish floor or ground.

306.2 Toe Clearance. 306.2.1 General. Space under an element between the finish floor or ground and 9 

inches (230 mm) above the finish floor or ground shall be considered toe clearance and shall comply with 

306.2. 306.2.2 Maximum Depth. Toe clearance shall extend 25 inches (635 mm) maximum under an 

element. 306.2.3 Minimum Required Depth. Where toe clearance is required at an element as part of a clear 

floor space, the toe clearance shall extend 17 inches (430 mm) minimum under the element. 306.2.4 

Additional Clearance. Space extending greater than 6 inches (150 mm) beyond the available knee clearance 

at 9 inches (230 mm) above the finish floor or ground shall not be considered toe clearance. 306.2.5 Width. 

Toe clearance shall be 30 inches (760 mm) wide minimum.

306.3 Knee Clearance. 306.3.1 General. Space under an element between 9 inches (230 mm) and 27 inches 

(685 mm) above the finish floor or ground shall be considered knee clearance and shall comply with 306.3. 

306.3.2 Maximum Depth. Knee clearance shall extend 25 inches (635 mm) maximum under an element at 9 

inches (230 mm) above the finish floor or ground. 306.3.3 Minimum Required Depth. Where knee clearance 

is required under an element as part of a clear floor space, the knee clearance shall be 11 inches (280 mm) 

deep minimum at 9 inches (230mm) above the finish floor or ground, and 8 inches (205 mm) deep minimum 

at 27 inches (685 mm) above the finish floor or ground.
Sec. Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s)

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(a) Clear Width

(a)(1) At least one doorway, on each side of the car from which 

passengers board, of each car required to be accessible 

by §38.111(a) and where the spaces required by 

§38.111(d) of this part are located, and at least one 

adjacent doorway into coach passenger compartments 

shall have a minimum clear opening width of 32 inches.

303.3 Beveled. Changes in level between 1⁄4 inch (6.4 mm) high minimum and 1⁄2 inch (13 mm) high maximum 

shall be beveled with a slope not steeper than 1:2. Advisory 303.3 Beveled. A change in level of 1⁄2 inch (13 

mm) is permitted to be 1⁄4 inch (6.4 mm) vertical plus 1⁄4 inch (6.4 mm) beveled. However, in no case may the 

combined change in level exceed 1⁄2 inch (13 mm). Changes in level exceeding 1⁄2 inch (13 mm) must comply 

with 405 (Ramps) or 406 (Curb Ramps). NOTE: “Clear width” means no protrusion into the vestibule or 

doorway is allowable.

While the regulation provides for a clear width of 32” for the door opening, it does 

not discuss the slope or threshold level of doorways. We believe it fair to point out 

that these items should be a consideration, as they affect the usability of railcars by 

persons with disabilities.

The term ‘ramp’ and ‘treshold’ need to be defined more clearly. if a feature such as 

a doorway where a level change currently exceed 1⁄2, that the ratio should be 1:5. 

The 1:8 ratio for Architectural standard is a difficult number to obtain without 

having awkward termination to ramp features. If features can be designed to be 

recessed in the car floor where it is knowingly acknowledged there could be an issue 

of exceeding 1⁄2” max height.

If Doorways can be designed to allow minimal variation in height early in the 

process, this would benefit the ADA access.

(a)(2) Doorways at ends of cars connecting two adjacent cars, to 

the maximum extent practicable in accordance with 

regulations issued under the federal Railroad Safety Act 

of 1970 (49 CFR parts 229 and 231), shall have a clear 

opening width of 32 inches to permit wheelchair and 

mobility aid users to enter into a single-level dining car, 

if available.

303.3 Beveled. Changes in level between 1⁄4 inch (6.4 mm) high minimum and 1⁄2 inch (13 mm) high maximum 

shall be beveled with a slope not steeper than 1:2. Advisory 303.3 Beveled. A change in level of 1⁄2 inch (13 

mm) is permitted to be 1⁄4 inch (6.4 mm) vertical plus 1⁄4 inch (6.4 mm) beveled. However, in no case may the 

combined change in level exceed 1⁄2 inch (13 mm). Changes in level exceeding 1⁄2 inch (13 mm) must comply 

with 405 (Ramps) or 406 (Curb Ramps). NOTE: “Clear width” means no protrusion into the vestibule or 

doorway is allowable.

While the regulation provides for a clear width of 32” for the door opening, it does 

not discuss the slope or threshold level of doorways. We believe it fair to point out 

that these items should be a consideration, as they affect the usability of railcars by 

persons with disabilities.

(b) Passageway. Doorways required to be accessible by 

paragraph (a) of this section shall permit access by 

persons using mobility aids and shall have an 

unobstructed passageway at least 32 inches wide 

leading to an accessible sleeping compartment 

complying with §38.127 of this part or seating locations 

complying with §38.125(d) of this part. In cars where 

such doorways require passage through a vestibule, such 

vestibule shall have a minimum width of 42 inches. (see 

Fig. 4)

303.3 Beveled. Changes in level between 1⁄4 inch (6.4 mm) high minimum and 1⁄2 inch (13 mm) high maximum 

shall be beveled with a slope not steeper than 1:2. Advisory 303.3 Beveled. A change in level of 1⁄2 inch (13 

mm) is permitted to be 1⁄4 inch (6.4 mm) vertical plus 1⁄4 inch (6.4 mm) beveled. However, in no case may the 

combined change in level exceed 1⁄2 inch (13 mm). Changes in level exceeding 1⁄2 inch (13 mm) must comply 

with 405 (Ramps) or 406 (Curb Ramps). NOTE: “Clear width” means no protrusion into the vestibule or 

doorway is allowable.

While the regulation provides for a clear width of 32” for the door opening and 42” 

for the vestibule, it does not discuss the slope or threshold level of doorways. We 

believe it fair to point out that these items should be a consideration, as they affect 

the usability of railcars by persons with disabilities. 

PRIIA Bi-level Equipment Spec require 44” vestibule

(c) Signals. If doors to the platform close automatically or 

from a remote location, auditory and visual warning 

signals shall be provided to alert passengers of closing 

doors.

The only guidance regarding audible signals in ADAAG relates to elevators and is 

contained in Section 407.2.2.3

(e) Signage. The International Symbol of Accessibility shall 

be displayed on the exterior of all doors complying with 

this section unless all cars and doors are accessible and 

are not marked by the access symbol (see fig. 6). 

Appropriate signage shall also indicate which accessible 

doors are adjacent to an accessible restroom, if 

applicable.

703.7 Symbols of Accessibility. Symbols of accessibility shall comply with 703.7. 703.7.1 Finish and Contrast. 

Symbols of accessibility and their background shall have a non-glare finish. Symbols of accessibility shall 

contrast with their background with either a light symbol on a dark background or a dark symbol on a light 

background. Advisory 703.7.1 Finish and Contrast. Signs are more legible for persons with low vision when 

characters contrast as much as possible with their background. Additional factors affecting the ease with 

which the text can be distinguished from its background include shadows cast by lighting sources, surface 

glare, and the uniformity of the text and background colors and textures. 703.7.2 Symbols. 703.7.2.1 

International Symbol of Accessibility. The International Symbol of Accessibility shall comply with Figure 

703.7.2.1. Figure 703.7.2.1 International Symbol of Accessibility Pictogram that shows the simplified profile of 

a person seated in a wheelchair.

For all potential signage, addition of braille in appropriate situations should be a 

consideration. 
Sec. Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s)

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(a) Where provided, handrails or stanchions within the 

passenger compartment shall be placed to permit 

sufficient turning and maneuvering space for 

wheelchairs and other mobility aids to reach a seating 

location, complying with § 38.125(d) of this part, from an 

accessible entrance. The diameter or width of the 

gripping surface of interior handrails and stanchions 

shall be 1 1/4 inches to 1 1⁄2 inches or shall provide an 

equivalent gripping surface. Handrails shall be placed to 

provide a minimum 1 1⁄2 inches knuckle clearance from 

the nearest adjacent surface.

505.4 Height. Top of gripping surfaces of handrails shall be 34 inches (865 mm) minimum and 38 inches (965 

mm) maximum vertically above walking surfaces, stair nosings, and ramp surfaces. Handrails shall be at a 

consistent height above walking surfaces, stair nosings, and ramp surfaces. 505.6 Gripping Surface. Handrail 

gripping surfaces shall be continuous along their length and shall not be obstructed along their tops or sides. 

The bottoms of handrail gripping surfaces shall not be obstructed for more than 20 percent of their length. 

Advisory 505.6 Gripping Surface. People with disabilities, older people, and others benefit from continuous 

gripping surfaces that permit users to reach the fingers outward or downward to grasp the handrail, 

particularly as the user senses a loss of equilibrium or begins to fall. 609.8 Structural Strength. Allowable 

stresses shall not be exceeded for materials used when a vertical or horizontal force of 250 pounds (1112 N) is 

applied at any point on the grab bar, fastener, mounting device, or supporting structure.

Thought should be given to placement of hand rails in restrooms to aid persons with 

lack of strength in their left or right hands (universal layout). 

Each space will be different whether in a sleeper compartment or a intercity 

condition. 

38.125(b)(13) 30” high min for lift rails;

38.125(c)(8) 30” high min for ramp handrails

(b) Where provided, handrails and stanchions shall be 

sufficient to permit safe boarding, on-board circulation, 

seating and standing assistance, and alighting by persons 

with disabilities.

609.8 Structural Strength. Allowable stresses shall not be exceeded for materials used when a vertical or 

horizontal force of 250 pounds (1112 N) is applied at any point on the grab bar, fastener, mounting device, or 

supporting structure.

Contract specification forces should apply, including APTA SS-C&S-006, if 

specified.

(c) At entrances equipped with steps, handrails or 

stanchions shall be provided in the entrance to the car in 

a configuration which allows passengers to grasp such 

assists from outside the car while starting to board, and 

to continue using such assists throughout the boarding 

process, to the extent permitted by part 231 of this title.

505.2 Where Required. Handrails shall be provided on both sides of stairs and ramps. 505.3 Continuity.

Handrails shall be continuous within the full length of each stair flight or ramp run. Inside handrails on 

switchback or dogleg stairs and ramps shall be continuous between flights or runs. 505.4 Height. Top of 

gripping surfaces of handrails shall be 34 inches (865 mm) minimum and 38 inches (965 mm) maximum 

vertically above walking surfaces, stair nosings, and ramp surfaces. Handrails shall be at a consistent height 

above walking surfaces, stair nosings, and ramp surfaces. Advisory 505.4 Height. The requirements for stair 

and ramp handrails in this document are for adults. 505.5 Clearance. Clearance between handrail gripping 

surfaces and adjacent surfaces shall be 11⁄2 inches (38 mm) minimum. 505.6 Gripping Surface. Handrail 

gripping surfaces shall be continuous along their length and shall not be obstructed along their tops or sides. 

The bottoms of handrail gripping surfaces shall not be obstructed for more than 20 percent of their length. 

Where provided, horizontal projections shall occur 11⁄2 inches (38 mm) minimum below the bottom of the 

handrail gripping surface. EXCEPTIONS: 1. Where handrails are provided along walking surfaces with slopes 

not steeper than 1:20, the bottoms of handrail gripping surfaces shall be permitted to be obstructed along 

their entire length where they are integral to crash rails or bumper guards. 2. The distance between horizontal 

projections and the bottom of the gripping surface shall be permitted to be reduced by 1/8 inch (3.2 mm) for 

each 1⁄2 inch (13 mm) of additional handrail perimeter dimension that exceeds 4 inches (100 mm). Advisory 

505.6 Gripping Surface. People with disabilities, older people, and others benefit from continuous gripping 

surfaces that permit users to reach the fingers outward or downward to grasp the handrail, particularly as the 

user senses a loss of equilibrium or begins to fall. 505.7 Cross Section. Handrail gripping surfaces shall have a 

cross section complying with 505.7.1 or 505.7.2. 505.7.1 Circular Cross Section. Handrail gripping surfaces 

with a circular cross section shall have an outside diameter of 11⁄4 inches (32 mm) minimum and 2 inches (51 

mm) maximum. 505.7.2 Non-Circular Cross Sections. Handrail gripping surfaces with a non-circular cross 

section shall have a perimeter dimension of 4 inches (100 mm) minimum and 61⁄4 inches (160 mm) maximum, 

and a cross-section dimension of 21⁄4 inches (57 mm) maximum. 505.10 Handrail Extensions. Handrail gripping 

surfaces shall extend beyond and in the same direction of stair flights and ramp runs in accordance with 

505.10. 505.10.2 Top Extension at Stairs. At the top of a stair flight, handrails shall extend horizontally above 

the landing for 12 inches (305 mm) minimum beginning directly above the first riser nosing. Extensions shall 

return to a wall, guard, or the landing surface, or shall be continuous to the handrail of an adjacent stair flight. 

505.10.3 Bottom Extension at Stairs. At the bottom of a stair flight, handrails shall extend at the slope of the 

stair flight for a horizontal distance at least equal to one tread depth beyond the last riser nosing. Extension 

shall return to a wall, guard, or the landing surface, or shall be continuous to the handrail of an adjacent stair 

flight 609.8 Structural Strength. Allowable stresses shall not be exceeded for materials used when a vertical 

or horizontal force of 250 pounds (1112 N) is applied at any point on the grab bar, fastener, mounting device, 

or supporting structure.

External handrails. Placement should be considered. Guidance from 505 for 

external handrails might intrude on requirements for safety appliance in those 

instances safety appliance regulation might take precedence

This regulation states that handrails must be configured to provide assists and 

continue to assist throughout boarding process. We think parts of ADAAG Section 

505 may be helpful in determining what would provide such assistance. 

38.115(c) is not talking about external handrails

38.115(c) does not require handrails both sides

38.125(c)(8) 30” high min for ramp handrails

May not be possible
Sec. Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s)

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(a) Floor surfaces on aisles, step treads and areas where 

wheelchair and mobility aid users are to be accommodated 

shall be slip-resistant.

302 Floor or Ground Surfaces 302.1 General. Floor and ground surfaces shall be stable, firm, and slip resistant and 

shall comply with 302. 302.2 Carpet. Carpet or carpet tile shall be securely attached and shall have a firm cushion, 

pad, or backing or no cushion or pad. Carpet or carpet tile shall have a level loop, textured loop, level cut pile, or 

level cut/uncut pile texture. Pile height shall be 1⁄2 inch (13 mm) maximum. Exposed edges of carpet shall be 

fastened to floor surfaces and shall have trim on the entire length of the exposed edge. Carpet edge trim shall 

comply with 303. Advisory 302.2 Carpet. Carpets and permanently affixed mats can significantly increase the 

amount of force (roll resistance) needed to propel a wheelchair over a surface. The firmer the carpeting and 

backing, the lower the roll resistance. A pile thickness up to 1⁄2 inch (13 mm) (measured to the backing, cushion, or 

pad) is allowed, although a lower pile provides easier wheelchair maneuvering. If a backing, cushion or pad is used, 

it must be firm. Preferably, carpet pad should not be used because the soft padding increases roll resistance. 

Does not agree with 49CFR Part 38.113 (d)(1) +/- 5/8” tolerance between car 

floor and platform height.

Does not agree with 49CFR Part 38.113 (d)(1) +/- 5/8” tolerance between car 

floor and platform height.

303.1 General. Where changes in level are permitted in floor or ground surfaces, they shall comply with 303. 

303.2 Vertical. Changes in level of 1⁄4 inch (6.4 mm) high maximum shall be permitted to be vertical. 303.3 Beveled. 

Changes in level between 1⁄4 inch (6.4 mm) high minimum and 1⁄2 inch (13 mm) high maximum shall be beveled with 

a slope not steeper than 1:2. Advisory 303.3 Beveled. A change in level of 1⁄2 inch (13 mm) is permitted to be 1⁄4 

inch (6.4 mm) vertical plus 1⁄4 inch (6.4 mm) beveled. However, in no case may the combined change in level 

exceed 1⁄2 inch (13 mm). Changes in level exceeding 1⁄2 inch (13 mm) must comply with 405 (Ramps) or 406 (Curb 

Ramps). 

303.3 Beveled. Changes in level between 1⁄4 inch (6.4 mm) high minimum and 1⁄2 inch (13 mm) high maximum shall 

be beveled with a slope not steeper than 1:2. Advisory 303.3 Beveled. A change in level of 1⁄2 inch (13 mm) is 

permitted to be 1⁄4 inch (6.4 mm) vertical plus 1⁄4 inch (6.4 mm) beveled. However, in no case may the combined 

change in level exceed 1⁄2 inch (13 mm). Changes in level exceeding 1⁄2 inch (13 mm) must comply with 405 (Ramps) 

or 406 (Curb Ramps). 

(b) All step edges and thresholds shall have a band of color(s) 

running the full width of the step or threshold which 

contrasts from the step tread and riser or adjacent floor, 

either light-on-dark or dark-on-light.

504 Stairways. 504.1 General. Stairs shall comply with 504. 504.2 Treads and Risers. All steps on a flight of stairs 

shall have uniform riser heights and uniform tread depths. Risers shall be 4 inches (100 mm) high minimum and 7 

inches (180 mm) high maximum. Treads shall be 11 inches (280 mm) deep minimum. 504.3 Open Risers. Open 

risers are not permitted. 504.4 Tread Surface. Stair treads shall comply with 302. Changes in level are not 

permitted. EXCEPTION: Treads shall be permitted to have a slope not steeper than 1:48. Advisory 504.4 Tread 

Surface. Consider providing visual contrast on tread nosings, or at the leading edges of treads without nosings, so 

that stair treads are more visible for people with low vision. 504.5 Nosings. The radius of curvature at the leading 

edge of the tread shall be 1⁄2 inch (13 mm) maximum. Nosings that project beyond risers shall have the underside 

of the leading edge curved or beveled. Risers shall be permitted to slope under the tread at an angle of 30 degrees 

maximum from vertical. The permitted projection of the nosing shall extend 11⁄2 inches (38 mm) maximum over the 

tread below. 

The ADAAG guidelines for stairs are included as guidance for minimum and 

maximum dimensions and uniformity. It may not be possible to achieve the 

minimum specified here due to the configuration of the rail cars. Risers and 

tread should be uniform and tread depth should be as large as possible
Sec. Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s)

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A grab bar at least 24 inches long shall be mounted behind 

the water closet, and a horizontal grab bar at least 40 inches 

long shall be mounted on at least one side wall, with one end 

not more than 12 inches from the back wall, at a height 

between 33 inches and 36 inches above the floor

609.2.1 Circular Cross Section. Grab bars with circular cross sections shall have an outside diameter of 11⁄4 

inches (32 mm) minimum and 2 inches (51 mm) maximum. 609.2.2 Non-Circular Cross Section. Grab bars 

with non-circular cross sections shall have a cross-section dimension of 2 inches (51 mm) maximum and a 

perimeter dimension of 4 inches (100 mm) minimum and 4.8 inches (120 mm) maximum. 609.3 Spacing.

The space between the wall and the grab bar shall be 11⁄2 inches (38 mm). The space between the grab bar 

and projecting objects below and at the ends shall be 11⁄2 inches (38 mm) minimum. The space between the 

grab bar and projecting objects above shall be 12 inches (305 mm) minimum. . 609.8 Structural Strength.

Allowable stresses shall not be exceeded for materials used when a vertical or horizontal force of 250 

pounds (1112 N) is applied at any point on the grab bar, fastener, mounting device, or supporting structure.

Thought should be given to placement of hand rails in restrooms to aid persons 

with lack of strength in their left or right hands. 

Each space will be different whether in a sleeper compartment or a intercity 

condition.

Contract specification forces should apply, including APTA SS-C&S-006, if 

specified.

(a)(4) Faucets and flush controls shall be operable with one hand 

and shall not require tight grasping, pinching, or twisting of 

the wrist. The force required to activate controls shall be no 

greater than 5 lbf (22.2 N). Controls for flush valves shall be

mounted no more than 44 inches above the floor.

308.2 Forward Reach.308.2.2 Obstructed High Reach. Where a high forward reach is over an obstruction, 

the clear floor space shall extend beneath the element for a distance not less than the required reach depth 

over the obstruction. The high forward reach shall be 48 inches (1220 mm) maximum where the reach 

depth is 20 inches (510 mm) maximum. Where the reach depth exceeds 20 inches (510 mm), the high 

forward reach shall be 44 inches (1120 mm) maximum and the reach depth shall be 25 inches (635 mm) 

maximum. 308.3 Side Reach. 308.3.2 Obstructed High Reach. Where a clear floor or ground space allows a 

parallel approach to an element and the high side reach is over an obstruction, the height of the 

obstruction shall be 34 inches (865 mm) maximum and the depth of the obstruction shall be 24 inches (610 

mm) maximum. The high side reach shall be 48 inches (1220 mm) maximum for a reach depth of 10 inches 

(255 mm) maximum. Where the reach depth exceeds 10 inches (255 mm), the high side reach shall be 46 

inches (1170 mm) maximum for a reach depth of 24 inches (610 mm) maximum.

As no touch devices become lower cost and more widely available thought 

should be given to installation in appropriate applications.

(a)(5) Doorways on the end of the enclosure, opposite the water 

closet, shall have a minimum clear opening width of 32 

inches. Doorways on the side wall shall have a minimum 

clear opening width of 39 inches. Door latches and hardware 

shall be operable with one hand and shall not require tight 

grasping, pinching, or twisting of the wrist.

404.2.7 Door and Gate Hardware. Handles, pulls, latches, locks, and other operable parts on doors and 

gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 

48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open 

position, operating hardware shall be exposed and usable from both sides. 

308 Reach Ranges (15” low) should apply,

allowing design flexibility

(b) Restrooms required to be accessible shall be in close 

proximity to at least one seating location for persons using 

mobility aids complying with § 38.125(d) of this part and shall 

be connected to such a space by an unobstructed path

having a minimum width of 32 inches.
Sec Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s) 38.125 Mobility Aid Accessibility

(a)(1) General. All intercity rail cars, other than level entry cars, 

required to be accessible by §§ 38.111 (a) and (e) of this 

subpart shall provide a level-change mechanism or boarding 

device (e.g., lift, ramp or bridge plate) complying with either 

paragraph (b) or (c) of this section and sufficient clearances 

to permit a wheelchair or other mobility aid user to reach a 

seating location complying with paragraph (d) of this section.

Updated definitions on the growing size of mobility aids and standards 

to improve dimensional considerations. The ADAAG need to define the 

classes of motorized and manual mobility devices to help understand 

footprint needed inside the railcar for transportation purposes.

(a)(2) Exception. If level

-entry boarding, portable or platform lifts, 

ramps or bridge plates meeting the applicable requirements 

of this section are provided on station platforms or other 

stops required to be accessible, or mini-high platforms 

complying with § 38.113(d) are provided, the car is not 

required to be equipped with a car-borne device. The access 

systems or devices used at a station to which section 37.42 

applies must permit compliance with that section.

(b) Car Lift

(b)(1) Design load. The design load of the lift shall be at least 600 

pounds. Working parts, such as cables, pulleys, and shafts, 

which can be expected to wear, and upon which the lift 

depends for support of the load, shall have a safety factor of 

at least six, based on the ultimate strength of the material. 

Nonworking parts, such as platform, frame, and attachment 

hardware which would not be expected to wear, shall have a 

safety factor of at least three, based on the ultimate strength 

of the material.

PRIIA Bi-level Specs require design load of 800 lbs for carborne lift

(b)(2) Controls

(b)(2)(i) Requirements. The controls shall be interlocked with the car 

brakes, propulsion system, or door, or shall provide other 

appropriate mechanisms or systems, to ensure that the car 

cannot be moved when the lift is not stowed and so the lift 

cannot be deployed unless the interlocks or systems are 

engaged. The lift shall deploy to all platform levels normally 

encountered in the operating environment. Where provided, 

each control for deploying, lowering, raising, and stowing the 

lift and lowering the roll-off barrier shall be of a monetary

[momentary] contact type requiring continuous manual 

pressure by the operator and shall not allow improper lift 

sequencing when the lift platform is occupied. The controls 

shall allow reversal of the lift operation sequence, such as 

raising or lowering a platform that is part way down, without 

allowing an occupied platform to fold or retract into the 

stowed position

In the following sentence from 38.125(b)(2)(i), “...Where provided, each 

control for deploying, lowering, raising, and stowing the lift and lowering the 

roll-off barrier shall be of a monetary [momentary] contact type requiring 

continuous manual...,” the word “momentary” is added and enclosed in 

brackets to correct a perceived error with the incorrect usage of the word 

‘monetary’ in the regulatory language of 38.125(b)(2)(i) 

(b)(2)(ii) Exception. Where physical or safety constraints prevent the 

deployment at some stops of a lift having its long dimension 

perpendicular to the car axis, the transportation entity may 

specify a lift which is designed to deploy with its long 

dimension parallel to the car axis and which pivots into or 

out of the car while occupied (i.e., “rotary lift”). The 

requirements of paragraph (b)(2)(i) of this section prohibiting 

the lift from being stowed while occupied shall not apply to a 

lift design of this type if the stowed position is within the 

passenger compartment and the lift is intended to be stowed 

while occupied.
Se

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Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s)

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(b)(2)(iii) Exception. The brake or propulsion system interlocks requirement does not apply to platform mounted or portable lifts provided that a mechanical, electrical or other system operates to ensure 

that cars do not move when the lift is in use.

(b)(3) Emergency operation. The lift shall incorporate an emergency method of deploying, lowering to ground or station platform level with a lift occupant, and raising and stowing the empty lift if the 

power to the lift fails. No emergency method, manual or otherwise, shall be capable of being operated in a manner that could be hazardous to the lift occupant or to the operator when 

operated according to manufacturer's instructions, and shall not permit the platform to be stowed or folded when occupied, unless the lift is a rotary lift and is intended to be stowed while 

occupied

(b)(4) Power or equipment failure. Platforms stowed in a vertical position, and deployed platforms when occupied, shall have provisions to prevent their deploying, falling, or folding any faster than 12 

inches/second or their dropping of an occupant in the event of a single failure of any load carrying component.

(b)(5) Platform barriers. The lift platform shall be equipped with barriers to prevent any of the wheels of a wheelchair or mobility aid from rolling off the lift during its operation. A movable barrier or 

inherent design feature shall prevent a wheelchair or mobility aid from rolling off the edge closest to the car until the lift is in its fully raised position. Each side of the lift platform which, in its 

raised position, extends beyond the car shall have a barrier a minimum 11⁄2 inches high. Such barriers shall not interfere with maneuvering into or out of the car. The loading-edge barrier (outer 

barrier) which functions as a loading ramp when the lift is at ground or station platform level, shall be sufficient when raised or closed, or a supplementary system shall be provided, to prevent a 

power wheelchair or mobility aid from riding over or defeating it. The outer barrier of the lift shall automatically rise or close, or a supplementary system shall automatically engage, and remain 

raised, closed, or engaged at all times that the lift platform is more than 3 inches above the station platform and the lift is occupied. Alternatively, a barrier or system may be raised, lowered, 

opened, closed, engaged or disengaged by the lift operator provided an interlock or inherent design feature prevents the lift from rising unless the barrier is raised or closed or the 

supplementary system is engaged

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(b)(6) Platform surface. The lift platform surface shall be free of any protrusions over 1⁄4 inch high and shall be slip resistant. The li plaorm shall have a minimum clear width of 281⁄2 inches at the 

platform, a minimum clear width of 30 inches measured from 2 inches above the lift platform surface to 30 inches above the surface, and a minimum clear length of 48 inches measured from 2 

inches above the surface of the platform to 30 inches above the surface. (See Fig. 1.)

PRIIA Bi-level Specs 

require 30” x 54” clear 

space for carborne lift 

platform surface

(b)(7) Platform gaps. Any openings between the lift platform surface and the raised barriers shall not exceed 5⁄8 inch wide. When the li is at car floor height with the inner barrier (if applicable) 

down or retracted, gaps between the forward lift platform edge and car floor shall not exceed 1⁄2 inch horizontally and 5⁄8 inch vercally

(b)(8) Platform entrance ramp. The entrance ramp, or loading-edge barrier used as a ramp, shall not exceed a slope of 1:8, when measured on level ground, for a maximum rise of 3 inches, and the

transition from station platform to ramp may be vertical without edge treatment up to 1⁄4 inch. Thresholds between 1⁄4 inch and 1⁄2 inch high shall be beveled with a slope no greater than 1:2.

(b)(9) Platform deflection. The lift platform (not including the entrance ramp) shall not deflect more than 3 degrees (exclusive of car roll) in any direction between its unloaded position and its position 

when loaded with 600 pounds applied through a 26 inch by 26 inch test pallet at the centroid of the lift platform.

PRIIA Bi-level Specs 

require design load of 800 

lbs for carborne lifts

(b)(10) Platform movement. No part of the platform shall move at a rate exceeding 6 inches/second during lowering and lifting an occupant, and shall not exceed 12 inches/second during deploying or 

stowing. This requirement does not apply to the deployment or stowage cycles of lifts that are manually deployed or stowed. The maximum platform horizontal and vertical acceleration when 

occupied shall be 0.3g.

(b)(11) Boarding direction. The lift shall permit both inboard and outboard facing of wheelchairs and mobility aids.

(b)(12) Use by standees. Lifts shall accommodate persons using walkers, crutches, canes or braces or who otherwise have difficulty using steps. The lift may be marked to indicate a preferred standing 

position.

(b)(13) Handrails. Platforms on lifts shall be equipped with handrails, on two sides, which move in tandem with the lift, and which shall be graspable and provide support to standees throughout the 

entire lift operation. Handrails shall have a usable component at least 8 inches long with the lowest portion a minimum 30 inches above the platform and the highest portion a maximum 38 

inches above the platform. The handrails shall be capable of withstanding a force of 100 pounds concentrated at any point on the handrail without permanent deformation of the rail or its 

supporting structure. The handrail shall have a cross-sectional diameter between 11⁄4 inches and 11⁄2 inches or shall provide an equivalent grasping surface, and have eased edges with corner 

radii of not less than 1⁄8 inch. Handrails shall be placed to provide a minimum 11⁄2 inches knuckle clearance from the nearest adjacent surface. Handrails shall not interfere with wheelchair or 

mobility aid maneuverability when entering or leaving the car.

(c) Car ramp or bridge plate

(c)(1) Design load. Ramps or bridge plates 30 inches or longer shall support a load of 600 pounds, placed at the centroid of the ramp or bridge plate distributed over an area of 26 inches by 26 inches, 

with a safety factor of at least 3 based on the ultimate strength of the material. Ramps or bridge plates shorter than 30 inches shall support a load of 300 pounds.

(c)(2) Ramp surface. The ramp or bridge plate surface shall be continuous and slip resistant, shall not have protrusions from the surface greater than 1

⁄4 inch high, shall have a clear width of 30 inches 

and shall accommodate both four-wheel and three-wheel mobility aids.

(c)(3) Ramp threshold. The transition from station platform to the ramp or bridge plate and the transition from car floor to the ramp or bridge plate may be vertical without edge treatment up to 1

⁄4

inch. Changes in level between 1⁄4 inch and 1⁄2 inch shall be beveled with a slope no greater than 1:2.

(c)(4) Ramp barriers. Each side of the ramp or bridge plate shall have barriers at least 2 inches high to prevent mobility aid wheels from slipping off.

(c)(5) Slope. Ramps or bridge plates shall have the least slope practicable. If the height of the vehicle floor, under 50% passenger load, from which the ramp is deployed is 3 inches or less above the 

station platform a maximum slope of 1:4 is permitted; if the height of the vehicle floor, under 50% passenger load, from which the ramp is deployed is 6 inches or less, but more than 3 inches, 

above the station platform a maximum slope of 1:6 is permitted; if the height of the vehicle floor, under 50% passenger load, from which the ramp is deployed is 9 inches or less, but more than 

6 inches, above the station platform a maximum slope of 1:8 is permitted; if the height of the vehicle floor, under 50% passenger load, from which the ramp is deployed is greater than 9 inches 

above the station platform a slope of 1:12 shall be achieved. Folding or telescoping ramps are permitted provided they meet all structural requirements of this section
Sec. Para. Subpart F Intercity Rail Cars and Systems Applicable ADAAG Section(s) Comment(s)

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(c)(6) Attachment

(c)(6)(i) Requirement. When in use for boarding or alighting, the ramp or bridge plate shall be attached to the vehicle, or 

otherwise prevented from moving such that it is not subject to displacement when loading or unloading a heavy power 

mobility aid and that any gaps between vehicle and ramp or bridge plate, and station platform and ramp or bridge 

plate, shall not exceed 5⁄8 inch.

(c)(6)(ii) Exception. Ramps or bridge plates which are attached to, and deployed from, station platforms are permitted in lieu of 

car devices provided they meet the displacement requirements of paragraph (c)(6)(i) of this section.

(c)(7) Stowage. A compartment, securement system, or other appropriate method shall be provided to ensure that stowed 

ramps or bridge plates, including portable ramps or bridge plates stowed in the passenger area, do not impinge on a 

passenger's wheelchair or mobility aid or pose any hazard to passengers in the event of a sudden stop.

(c)(8) Handrails. If provided, handrails shall allow persons with disabilities to grasp them from outside the car while starting to 

board, and to continue to use them throughout the boarding process, and shall have the top between 30 inches and 38 

inches above the ramp surface. The handrails shall be capable of withstanding a force of 100 pounds concentrated at 

any point on the handrail without permanent deformation of the rail or its supporting structure. The handrail shall have 

a cross-sectional diameter between 11⁄4 inches and 11⁄2 inches or shall provide an equivalent grasping surface, and have 

eased edges with corner radii of not less than 1⁄8 inch. Handrails shall not interfere with wheelchair or mobility aid 

maneuverability when entering or leaving the car.

(d) Seating

(d)(1) Requirements. All intercity rail cars required to be accessible by §§ 38.111 (a) and (e) of this subpart shall provide at 

least one, but not more than two, mobility aid seating location(s) complying with paragraph (d)(2) of this section; and at 

least one, but not more than two, seating location(s) complying with paragraph (d)(3) of this section which adjoin or 

overlap an accessible route with a minimum clear width of 32 inches.

(d)(2) Wheelchair or mobility aid spaces. Spaces for persons who wish to remain in their wheelchairs or mobility aids shall 

have a minimum clear floor space 48 inches by 30 inches. Such spaces shall adjoin, and may overlap, an accessible 

path. Not more than 6 inches of the required clear floor space may be accommodated for footrests under another seat 

provided there is a minimum of 9 inches from the floor to the lowest part of the seat overhanging the space. Seating 

spaces may have fold-down or removable seats to accommodate other passengers when a wheelchair or mobility aid 

user is not occupying the area, provided the seats, when folded up, do not obstruct the clear floor space provided (See 

Fig. 2).

306 Knee and Toe Clearance 306.1 General. Where space beneath an element is included as part of 

clear floor or ground space or turning space, the space shall comply with 306. Additional space shall 

not be prohibited beneath an element but shall not be considered as part of the clear floor or ground 

space or turning space. Advisory 306.1 General. Clearances are measured in relation to the usable 

clear floor space, not necessarily to the vertical support for an element. When determining clearance 

under an object for required turning or maneuvering space, care should be taken to ensure the space 

is clear of any obstructions.

38.125(d)(2) gives very clear, 

complete guidance; Why cloud 

the rational by reference to 

ADAAG Section 306? Does not 

help!

PRIIA Bi-Level Specs require clear 

floor space of 32” x 59” for 

wheelchair space

(d)(3) Other spaces. Spaces for individuals who wish to transfer shall include a regular coach seat or dining car booth or table 

seat and space to fold and store the passenger's wheelchair
Sec. Para. Subpart F Intercity Rail Cars and 

Systems

Applicable ADAAG Section(s) Comment(s)

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(a) Sleeping compartments required to be 

accessible shall be designed so as to 

allow a person using a wheelchair or 

mobility aid to enter, maneuver within 

and approach and use each element 

within such compartment. (See Fig. 5.)

304 Turning Space 304.1 General. Turning space shall comply with 304. 304.2 Floor or Ground Surfaces. Floor or ground surfaces of a turning space shall comply with 302. 

Turning space shall comply with 304.3.1 or 304.3.2. 304.3.1 Circular Space. The turning space shall be a space of 60 inches (1525 mm) diameter minimum. The space shall 

be permitted to include knee and toe clearance complying with 306. 304.3.2 T-Shaped Space. The turning space shall be a T-shaped space within a 60 inch (1525 mm) square 

minimum with arms and base 36 inches (915 mm) wide minimum. Each arm of the T shall be clear of obstructions 12 inches (305 mm) minimum in each direction and the 

base shall be clear of obstructions 24 inches (610 mm) minimum. The space shall be permitted to include knee and toe clearance complying with 306 only at the end of 

either the base or one arm. 

Given space constraints in railcars, it is 

understood that the space available in 

sleeping compartments are not equivalent to 

hotel rooms. Therefore, only a few of the 

ADAAG applicable to sleeping rooms are even 

remotely usable as guidance. However, to 

the extent feasible, the basic building blocks 

for accessibility can be followed. In addition, 

if fire alarm systems are provided on rail cars, 

this guidance will inform the rail service 

provider how to make it accessible

Same comments as (a)(2) and (a)(3)

Same comments as (a)(2) and (a)(3)

Clear Floor or Ground Space. 305.1 General. Clear floor or ground space shall comply with 305. 305.2 Floor or Ground Surfaces. Floor or ground surfaces of a clear floor or 

ground space shall comply with 302. 305.3 Clear Floor or Ground Space Clear floor or ground space is 30 inches by 48 inches (760 mm by 1220 mm) minimum. 305.4 Knee 

and Toe Clearance. Unless otherwise specified, clear floor or ground space shall be permitted to include knee and toe clearance complying with 306. 305.5 Position. Unless 

otherwise specified, clear floor or ground space shall be positioned for either forward or parallel approach to an element. Figure 305.5 Position of Clear Floor or Ground 

Space For a forward approach to an element, a clear floor or ground space, 30 inches by 48 inches (760 mm by 1220 mm) minimum, is shown with the shorter dimension 

parallel to the wall or element. For a parallel approach to an element, a clear floor or ground space, 30 inches by 48 inches (760 mm by 1220 mm) minimum, is shown with 

the longer dimension parallel to the wall or element. 305.6 Approach. One full unobstructed side of the clear floor or ground space shall adjoin an accessible route or adjoin 

another clear floor or ground space.

306 Knee and Toe Clearance 306.1 General. Where space beneath an element is included as part of clear floor or ground space or turning space, the space shall comply 

with 306. Additional space shall not be prohibited beneath an element but shall not be considered as part of the clear floor or ground space or turning space. Advisory 

306.1 General. Clearances are measured in relation to the usable clear floor space, not necessarily to the vertical support for an element. When determining clearance 

under an object for required turning or maneuvering space, care should be taken to ensure the space is clear of any obstructions.

306.2 Toe Clearance. 306.2.1 General. Space under an element between the finish floor or ground and 9 inches (230 mm) above the finish floor or ground shall be 

considered toe clearance and shall comply with 306.2. 306.2.2 Maximum Depth. Toe clearance shall extend 25 inches (635 mm) maximum under an element. 306.2.3 

Minimum Required Depth. Where toe clearance is required at an element as part of a clear floor space, the toe clearance shall extend 17 inches (430 mm) minimum under 

the element. 306.2.4 Additional Clearance. Space extending greater than 6 inches (150 mm) beyond the available knee clearance at 9 inches (230 mm) above the finish floor 

or ground shall not be considered toe clearance. 306.2.5 Width. Toe clearance shall be 30 inches (760 mm) wide minimum. Figure 306.2 Toe Clearance Figure 306.2(a) Toe 

Clearance: Elevation. Toes of a person in a wheelchair are shown extending for a maximum depth of 6 inches (150 mm) under an object that is 9 inches (230 mm) high

minimum. Figure 306.2(b) Toe Clearance: Plan. Toe clearance at an element, as part of clear floor space, shall extend 17 to 25 inches (430 to 635 mm) under the element. 

The clear floor space is 30 inches (760 mm) wide minimum.

306.3 Knee Clearance. 306.3.1 General. Space under an element between 9 inches (230 mm) and 27 inches (685 mm) above the finish floor or ground shall be considered 

knee clearance and shall comply with 306.3. 306.3.2 Maximum Depth. Knee clearance shall extend 25 inches (635 mm) maximum under an element at 9 inches (230 mm) 

above the finish floor or ground. 306.3.3 Minimum Required Depth. Where knee clearance is required under an element as part of a clear floor space, the knee clearance 

shall be 11 inches (280 mm) deep minimum at 9 inches (230 mm) above the finish floor or ground, and 8 inches (205 mm) deep minimum at 27 inches (685 mm) above the 

finish floor or ground. 306.3.4 Clearance Reduction. Between 9 inches (230 mm) and 27 inches (685 mm) above the finish floor or ground, the knee clearance shall be 

permitted to reduce at a rate of 1 inch (25 mm) in depth for each 6 inches (150 mm) in height. 306.3.5 Width. Knee clearance shall be 30 inches (760 mm) wide minimum. 

Figure 306.3 Knee Clearance Figure 306.3(a) Knee Clearance: Elevation. Knee clearance is 27 inches (685 mm) high minimum above the floor or ground for a minimum depth 

of 8 inches (205 mm), measured from the leading edge of the element. The vertical clearance decreases beyond this depth to a height of 9 inches (230 mm) minimum at 

depth of 11 inches (280 mm) minimum measured from the leading edge of the element. Figure 306.3(b) Knee Clearance: Plan. Combined knee and toe clearance can extend 

25 inches (635 mm) maximum under an element
307 Protruding Objects 307.1 General. Protruding objects shall comply with 307. 307.2 Protrusion Limits. Objects with leading edges more than 27 inches (685 mm) and 

not more than 80 inches (2030 mm) above the finish floor or ground shall protrude 4 inches (100 mm) maximum horizontally into the circulation path. EXCEPTION: 

Handrails shall be permitted to protrude 4 1/2 inches (115 mm) maximum. Advisory 307.2 Protrusion Limits. When a cane is used and the element is in the detectable 

range, it gives a person sufficient time to detect the element with the cane before there is body contact. Elements located on circulation paths, including operable elements, must comply with requirements for protruding objects. For example, awnings and their supporting structures cannot reduce the minimum required vertical clearance. 

Similarly, casement windows, when open, cannot encroach more than 4 inches (100 mm) into circulation paths above 27 inches (685 mm). Figure 307.2 Limits of Protruding 

Objects A frontal view shows a person using a cane walking along a wall. A wall-mounted object more than 27 inches (685 mm) from the floor protrudes no more than 4 

inches (100 mm) from the wall surface. An object overhead provides vertical clearance that is greater than 80 inches (2030 mm). 307.3 Post-Mounted Objects. Free-

standing objects mounted on posts or pylons shall overhang circulation paths 12 inches (305 mm) maximum when located 27 inches (685 mm) minimum and 80 inches (2030 

mm) maximum above the finish floor or ground. Where a sign or other obstruction is mounted between posts or pylons and the clear distance between the posts or pylons 

is greater than 12 inches (305 mm), the lowest edge of such sign or obstruction shall be 27 inches (685 mm) maximum or 80 inches (2030 mm) minimum above the finish 

floor or ground. Figure 307.3 Post-Mounted Protruding Objects Elevation drawing (a) shows an object mounted more than 27 inches (685 mm) high on a post. The object 

protrudes 12 inches (305 mm) maximum from the post on both sides. Elevation (b) shows signs or other obstructions mounted between posts or pylons. One object has its 

lowest edge mounted 27 inches (685 mm) high maximum between posts that are more than 12 inches apart. Another object is mounted with its lowest edge 80 inches 

(2030 mm) high minimum between posts that are more than 12 inches apart. 307.4 Vertical Clearance. Vertical clearance shall be 80 inches (2030 mm) high minimum. 

Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches (2030 mm) high. The leading edge of such guardrail or barrier shall be 

located 27 inches (685 mm) maximum above the finish floor or ground. EXCEPTION: Door closers and door stops shall be permitted to be 78 inches (1980 mm) minimum 

above the finish floor or ground. Figure 307.4 Vertical Clearance A person using a long cane is shown approaching the sloped underside of a staircase. A portion of the area 

below the stairs in front of the person has a vertical clearance less than 80 inches (2030 mm). A railing 27 inches (685 mm) high maximum separates this space from the 

areas where a vertical clearance at or above 80 inches (2030 mm) is maintained. 307.5 Required Clear Width. Protruding objects shall not reduce the clear width required 

for accessible routes. 308 Reach Ranges 308.1 General. Reach ranges shall comply with 308. 308.2 Forward Reach. 308.2.1 Unobstructed. Where a forward reach is 

unobstructed, the high forward reach shall be 48 inches (1220 mm) maximum and the low forward reach shall be 15 inches (380 mm) minimum above the finish floor or 

ground. Figure 308.2.1 Unobstructed Forward Reach A side view is shown of a person using a wheelchair reaching toward a wall. The lowest vertical reach point is 15 inches 

(380 mm) minimum and the highest is 48 inches (1220 mm) maximum.

38.127 Sleeping Compartment

308.2.2 Obstructed High Reach. Where a high forward reach is over an obstruction, the clear floor space shall extend beneath the element for a distance not less than the 

required reach depth over the obstruction. The high forward reach shall be 48 inches (1220 mm) maximum where the reach depth is 20 inches (510 mm) maximum. Where 

the reach depth exceeds 20 inches (510 mm), the high forward reach shall be 44 inches (1120 mm) maximum and the reach depth shall be 25 inches (635 mm) maximum. 

Figure 308.2.2 Obstructed High Forward Reach Figure (a) shows a person seated in a wheelchair reaching a point on a wall above a protrusion, such as a wall-mounted 

counter, which is 20 inches (510 mm) deep maximum. The maximum reach height is 48 inches (1220 mm). In figure (b), the obstruction is more than 20 inches (510 mm) 

deep, with 25 inches (635 mm) the maximum depth. The maximum reach height is 44 inches (1120 mm). 308.3 Side Reach. 308.3.1 Unobstructed. Where a clear floor or 

ground space allows a parallel approach to an element and the side reach is unobstructed, the high side reach shall be 48 inches (1220 mm) maximum and the low side reach 

shall be 15 inches (380 mm) minimum above the finish floor or ground. Figure 308.3.1 Unobstructed Side Reach The drawing shows a frontal view of a person using a 

wheelchair making a side reach to a wall. The depth of reach is 10 inches (255 mm) maximum. The vertical reach range is 15 inches (380 mm) minimum to 48 inches (1220 

mm) maximum. 308.3.2 Obstructed High Reach. Where a clear floor or ground space allows a parallel approach to an element and the high side reach is over an 

obstruction, the height of the obstruction shall be 34 inches (865 mm) maximum and the depth of the obstruction shall be 24 inches (610 mm) maximum. The high side 

reach shall be 48 inches (1220 mm) maximum for a reach depth of 10 inches (255 mm) maximum. Where the reach depth exceeds 10 inches (255 mm), the high side reach 

shall be 46 inches (1170 mm) maximum for a reach depth of 24 inches (610 mm) maximum. Figure 308.3.2 Obstructed High Side Reach In figure (a), a person seated in a 

wheelchair is shown reaching to the side over an obstruction 10 inches (510 mm) deep maximum and 34 inches (865 mm) high maximum. The maximum reach height is 48 

inches (1220 mm). In figure (b) the obstruction depth is 10 inches to 24 inches maximum (255 to 610 mm) and 34 inches (865 mm) high maximum. The maximum reach 

height is 46 inches (1170 mm). 

309 Operable Parts 309.1 General. Operable parts shall comply with 309. 309.2 Clear Floor Space. A clear floor or ground space complying with 305 shall be provided. 

309.3 Height. Operable parts shall be placed within one or more of the reach ranges specified in 308. 309.4 Operation. Operable parts shall be operable with one hand and 

shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.

806.3.1 Alarms. Where emergency warning systems are provided, alarms complying with 702 shall be provided. 702 Fire Alarm Systems 702.1 General. Fire alarm systems 

shall have permanently installed audible and visible alarms complying with NFPA 72 (1999 or 2002 edition) (incorporated by reference, see “Referenced Standards” in 

Chapter 1), except that the maximum allowable sound level of audible notification appliances complying with section 4-3.2.1 of NFPA 72 (1999 edition) shall have a sound 

level no more than 110 dB at the minimum hearing distance from the audible appliance. In addition, alarms in guest rooms required to provide communication features shall 

comply with sections 4-3 and 4-4 of NFPA 72 (1999 edition) or sections 7.4 and 7.5 of NFPA 72 (2002 edition) 806.3.1 Alarms. Where emergency warning systems are 

provided, alarms complying with 702 shall be provided. 702 Fire Alarm Systems 702.1 General. Fire alarm systems shall have permanently installed audible and visible 

alarms complying with NFPA 72 (1999 or 2002 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1), except that the maximum allowable sound 

level of audible notification appliances complying with section 4-3.2.1 of NFPA 72 (1999 edition) shall have a sound level no more than 110 dB at the minimum hearing 

distance from the audible appliance. In addition, alarms in guest rooms required to provide communication features shall comply with sections 4-3 and 4-4 of NFPA 72 (1999 

edition) or sections 7.4 and 7.5 of NFPA 72 (2002 edition)

902 Dining Surfaces and Work Surfaces 902.1 General. Dining surfaces and work surfaces shall comply with 902.2 and 902.3.

Signage. 703 Signs. 703.1 General. Signs shall comply with 703. 
Sec. Para. Subpart F Intercity Rail Cars and 

Systems

Applicable ADAAG Section(s) Comment(s)

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(b) Each accessible compartment shall 

contain a restroom complying with 

§ 38.123(a) which can be entered 

directly from such compartment.

603.3 Mirrors. Mirrors located above lavatories or countertops shall be installed with the bottom edge of the reflecting surface 40 inches (1015 

mm) maximum above the finish floor or ground. Mirrors not located above lavatories or countertops shall be installed with the bottom edge of the 

reflecting surface 35 inches (890 mm) maximum above the finish floor or ground. 

Given space constraints in railcars, it is understood that the space 

available in sleeping compartments are not equivalent to hotel rooms. 

Therefore, only a few of the ADAAG applicable to sleeping rooms are 

even remotely usable as guidance. However, to the extent feasible, 

the basic building blocks for accessibility can be followed. In addition, 

if fire alarm systems are provided on rail cars, this guidance will 

inform the rail service provider how to make it accessible

A 2 degree tilt to the mirrors was appreciated by people in 

wheelchairs.

Shower Size is not always achievable in a railcar. 36 x 36 or 36 x 48 is a 

tough spec to meet.

Grab bar configuration should be reviewed for both seated and 

standing passenger usability.

308 Reach Ranges (15” low) should apply, allowing design 

flexibility

The minimum clear floor area shall be 35 inches by 60 inches. 

Permanently installed fixtures may overlap this area a maximum of 6 

inches, if the lowest portion of the fixture is a minimum of 9 inches 

above the floor, and may overlap a maximum of 19 inches, if the 

lowest portion of the fixture is a minimum of 29 inches above the 

floor.

Contract specification forces should apply, including APTA SSC&S-006, if specified.

608.2 Size and Clearances for Shower Compartments. Shower compartments shall have sizes and clearances complying with 608.2. 608.2.1 Transfer 

Type Shower Compartments. Transfer type shower compartments shall be 36 inches (915 mm) by 36 inches (915 mm) clear inside dimensions 

measured at the center points of opposing sides and shall have a 36 inch (915 mm) wide minimum entry on the face of the shower compartment. 

Clearance of 36 inches (915 mm) wide minimum by 48 inches (1220 mm) long minimum measured from the control wall shall be provided.

608.3 Grab Bars. Grab bars shall comply with 609 and shall be provided in accordance with 608.3. Where multiple grab bars are used, required 

horizontal grab bars shall be installed at the same height above the finish floor. 608.3.1 Transfer Type Shower Compartments. In transfer type

compartments, grab bars shall be provided across the control wall and back wall to a point 18 inches (455 mm) from the control wall.

608.4 Seats. A folding or non-folding seat shall be provided in transfer type shower compartments. A folding seat shall be provided in roll-in type 

showers required in transient lodging guest rooms with mobility features complying with 806.2. Seats shall comply with 610.

608.5 Controls. Controls, faucets, and shower spray units shall comply with 309.4.

608.5.1 Transfer Type Shower Compartments. In transfer type shower compartments, the controls, faucets, and shower spray unit shall be installed 

on the side wall opposite the seat 38 inches (965 mm) minimum and 48 inches (1220 mm) maximum above the shower floor and shall be located on 

the control wall 15 inches (380 mm) maximum from the centerline of the seat toward the shower opening. 

610 Seats 610.1 General. Seats in bathtubs and shower compartments shall comply with 610. 610.3 Shower Compartment Seats. Where a seat is 

provided in a standard roll-in shower compartment, it shall be a folding type, shall be installed on the side wall adjacent to the controls, and shall 

extend from the back wall to a point within 3 inches (75 mm) of the compartment entry. Where a seat is provided in an alternate roll-in type shower 

compartment, it shall be a folding type, shall be installed on the front wall opposite the back wall, and shall extend from the adjacent side wall to a 

point within 3 inches (75 mm) of the compartment entry. In transfer-type showers, the seat shall extend from the back wall to a point within 3 

inches (75 mm) of the compartment entry. The top of the seat shall be 17 inches (430 mm) minimum and 19 inches (485 mm) maximum above the 

bathroom finish floor. Seats shall comply with 610.3.1 or 610.3.2. Figure 610.3 Extent of Seat Figure (a) is a plan view of a rectangular seat and figure 

(b) is a plan view of an L-shaped seat. The front edge of each is 3 inches (75 mm) maximum from the compartment entry. 610.3.1 Rectangular Seats. 

The rear edge of a rectangular seat shall be 2 1/2 inches (64 mm) maximum and the front edge 15 inches (380 mm) minimum and 16 inches (405 

mm) maximum from the seat wall. The side edge of the seat shall be 1 1/2 inches (38 mm) maximum from the adjacent wall. Figure 610.3.1 

Rectangular Shower Seat The rear edge is 21⁄2 inches (64 mm) maximum and the front edge 15 to 16 inches (380 to 405 mm) from the seat wall. The 

side edge is 11⁄2 inches (38 mm) maximum from the back wall. 610.3.2 L-Shaped Seats. The rear edge of an L-shaped seat shall be 2 1/2 inches (64 

mm) maximum and the front edge 15 inches (380 mm) minimum and 16 inches (405 mm) maximum from the seat wall. The rear edge of the "L" 

portion of the seat shall be 1 1/2 inches (38 mm) maximum from the wall and the front edge shall be 14 inches (355 mm) minimum and 15 inches 

(380 mm) maximum from the wall. The end of the "L" shall be 22 inches (560 mm) minimum and 23 inches maximum (585 mm) from the main seat 

wall. Figure 610.3.2 L-Shaped Shower Seat Figures (a) shows the “L” is oriented with the narrower portion toward the compartment opening and the 

base toward the back. The front edge of the narrow portion of the L is 15 to 16 inches (380 to 405 mm) from the seat wall and the base end is 22 to 

23 inches (560 to 585 mm) from the seat wall. The base of the L is 14 to 15 inches (355 to 380 mm) from the adjacent wall. Figure (b) shows that the 

seat is 21⁄2 inches (64 mm) maximum from the seat wall and the rear edge of the L portion is 11⁄2 inches (38 mm) maximum from the adjacent wall.

610.4 Structural Strength. Allowable stresses shall not be exceeded for materials used when a vertical or horizontal force of 250 pounds (1112 N) is 

applied at any point on the seat, fastener, mounting device, or supporting structure.

(c) Controls and operating mechanisms 

(e.g., heating and air conditioning 

controls, lighting controls, call buttons, 

electrical outlets, etc.) shall be 

mounted no more than 48 inches, and 

no less than 15 inches, above the floor 

and shall have a clear floor area 

directly in front a minimum of 30 

inches by 48 inches. Controls and 

operating mechanisms shall be 

operable with one hand and shall not 

require tight grasping, pinching, or 

twisting of the wrist.

Given space constraints in railcars, it is understood that the space 

available in sleeping compartments are not equivalent to hotel rooms. 

Therefore, only a few of the ADAAG applicable to sleeping rooms are 

even remotely usable as guidance. However, to the extent feasible, 

the basic building blocks for accessibility can be followed. In addition, 

if fire alarm systems are provided on rail cars, this guidance will 

inform the rail service provider how to make it accessible