Accessibility Compliance Checklist

Audit Setup and Scoping

    Properties built or altered after March 15, 2012 follow the 2010 ADA Standards; pre-2012 work was governed by the 1991 standards and may be grandfathered until altered. Multifamily housing built after March 13, 1991 is also subject to Fair Housing Act design and construction rules. Note any state accessibility code (e.g., California Title 24, Texas TAS) that exceeds federal minimums.

    Locate the most recent accessibility survey, any CASp report (California), DOJ settlement agreements, and open tenant accommodation requests. Outstanding remediation items roll forward to this audit; closing them silently is a common gotcha when ownership changes hands.

    Property manager leads, maintenance supervisor walks the path of travel, and a leasing agent shadows for the leasing-office portion. Plan the route from the public right-of-way through parking, entrance, leasing office, common areas, and a sample dwelling unit.

Parking and Site Arrival

    2010 ADA §208.2 sets the ratio: 1 accessible space per 25 up to 100 spaces, then sliding scale. At least one of every six accessible spaces must be van-accessible. Count by parking facility, not by total site — a property with three lots needs the ratio met in each.

    Standard accessible aisles are 60 inches wide; van-accessible aisles are 96 inches (or the space itself is 132 inches wide with a 60-inch aisle). Surface slope cannot exceed 1:48 in any direction — most failures are pre-existing slopes from original site grading, not striping issues.

    Each accessible space needs a sign with the International Symbol of Accessibility, mounted so the bottom is at least 60 inches above the finished surface (so it stays visible when a vehicle is parked). Van-accessible spaces need a 'Van Accessible' designation. Ground-only striping does not satisfy the requirement.

    Path of travel must be at least 36 inches wide, free of abrupt vertical changes over 1/4 inch (or 1/2 inch with a bevel), and have running slope no greater than 1:20 (or be a ramp). Watch for trip hazards from settled concrete, tree-root heave, and seasonal landscaping overgrowth.

Entrances and Path of Travel

    Under 2010 ADA §206.4, at least 60% of public entrances must be accessible — and where a building has a primary public entrance, that one must be accessible. Routing visitors with disabilities to a side or rear 'service' entrance is a recurring DOJ enforcement target.

    Clear width is 32 inches with the door open 90 degrees, measured between the face of the door and the stop. Interior non-fire doors max 5 lbf opening force; exterior doors have no federal force limit but many state codes set 8.5 lbf. Test with a door pressure gauge, not by feel.

    Maximum running slope is 1:12; cross slope no greater than 1:48. Ramps over 6 inches rise need handrails on both sides, 34-38 inches above the surface, with 12-inch top and bottom extensions. Confirm landings every 30 feet and at every change of direction.

    Photo evidence drives both the remediation scope and the legal defense. Capture each barrier with a tape measure or slope gauge in frame so the dimension is visible. Tools like HappyCo or zInspector tag photos to a unit/area code automatically.

Common Areas and Restrooms

    Hallways must be at least 36 inches wide, with a 60-inch turning circle (or T-shaped turn) at dead ends and rooms. Watch for furniture, vending machines, and package shelving that narrow the clear width below 36 inches.

    Cab interior at least 51 by 68 inches, call buttons centered 42 inches above the floor, raised and braille floor designations on both jambs at 60 inches, audible floor announcements. Confirm the most recent state elevator inspection certificate is posted in the cab.

    Accessible stall: 60-inch turning radius, grab bars 33-36 inches above the floor (rear bar 36 inches long, side bar 42 inches long, located 12 inches from the rear wall). Lavatory rim no higher than 34 inches with knee clearance of 27 inches. Pipe insulation under the lavatory is required to prevent burns.

    At least one section of the leasing counter must be 36 inches or lower with a 30-by-48-inch clear floor space, or provide an equivalent service alternative. Sample units used for tours need an accessible route from the leasing office.

Signage and Communication

    Permanent room identification (restrooms, stairwells, exit, suite numbers) requires raised characters and Grade 2 braille, mounted on the latch side of the door, centered 60 inches above the floor. Directional and informational signs do not need braille but need contrast and sans-serif characters per §703.5.

    NFPA 72 requires synchronized visual notification appliances in common areas, public restrooms, corridors, and any room where occupants may be alone. In multifamily, FHA-covered units need wired interconnection points so a tenant-installed strobe can tie into the building system.

    Title III requires auxiliary aids on request — relay services (711), VRS for sign language, large-print or accessible-PDF leasing documents. Document the firm's commitment in writing; 'we'll figure it out' is not an effective-communication policy.

Dwelling Unit Accessibility (FHA)

    Fair Housing Act design and construction rules apply to covered multifamily dwellings first occupied after March 13, 1991: all ground-floor units in non-elevator buildings, and all units in buildings with elevators. Pre-1991 buildings are exempt from new-construction rules but still subject to reasonable-modification obligations under §3604(f)(3)(A).

    The seven: accessible building entrance on accessible route; accessible public/common areas; usable doors (32-inch nominal clear); accessible route into and through the unit; light switches/outlets/thermostats in reachable locations; reinforced bath walls for grab bars; usable kitchens and baths. Pull a HUD FHA Design Manual checklist and walk one ground-floor or elevator-served unit per building type.

    Pull every accommodation/modification request from the last 12 months. Confirm each was answered in writing within a reasonable time (HUD guidance: typically 10 business days), with denial letters citing the specific basis. ESA and service-animal requests are accommodations, not lease violations — no pet rent, no breed restriction.

Findings, Remediation, and Owner Sign-Off

    Title III requires barrier removal that is 'readily achievable' — easily accomplishable without much difficulty or expense. Sort findings into readily achievable (signage, grab bars, repainting striping), capital projects (ramp construction, elevator retrofit), and operational fixes (training, policy). Get vendor quotes for the capex items before owner review.

    Sequence readily-achievable items within 30 days, capex items within the current budget cycle. Open work orders in AppFolio/Buildium/Yardi tied to each finding so completion is tracked. Items deferred for budget reasons need a written justification in the file.

    Cover service animals vs pets, the difference between accommodation and modification, source-of-income protections in jurisdictions that recognize them, and the firm's accommodation-request intake form. NAA and IREM both publish training modules; document attendance for the owner file.

    Final package: audit summary, photo log, barrier list with cost estimates, remediation schedule, training attendance, and any open accommodation requests. Owner countersignature acknowledges the findings and approves the capex spend.

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