U.S. General Services Administration
Technical Procedures Disclaimer
Prior to inclusion in GSA’s library of procedures, documents are reviewed by one or more qualified preservation specialists for general consistency with the Secretary of Interior Standards for rehabilitating historic buildings as understood at the time the procedure is added to the library. All specifications require project-specific editing and professional judgement regarding the applicability of a procedure to a particular building, project or location. References to products and suppliers are to serve as a general guideline and do not constitute a federal endorsement or determination that a product or method is the best or most current alternative, remains available, or is compliant with current environmental regulations and safety standards. The library of procedures is intended to serve as a resource, not a substitute, for specification development by a qualified preservation professional.
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We’ve reviewed these procedures for general consistency with federal standards for rehabilitating historic buildings and provide them only as a reference. Specifications should only be applied under the guidance of a qualified preservation professional who can assess the applicability of a procedure to a particular building, project or location. References to products and suppliers serve as general guidelines and do not constitute a federal endorsement nor a determination that a product or method is the best alternative or compliant with current environmental regulations and safety standards.
This document includes some general guidelines to follow in design projects involving handicapped accessibility to existing building hardware such as elevators, fire alarms or other hardware mounted to stone, unpainted wood, unpainted metal, or other ornamental wall finishes. Special care should be taken to avoid penetration into these historic materials.
While other local and state governmental agencies generally follow the Americans with Disabilities Act (ADA), in Federal facilities the more stringent Architectural Barriers Act Standards (ABAS) are adhered to (these replaced the previous Uniform Federal Accessibility Standards). In historic structures, the regulations are as follows:
F202.5 Alterations to Qualified Historic Buildings and Facilities.
Alterations to a qualified historic building or facility shall comply with F202.3 and F202.4.
EXCEPTION: Where the State Historic Preservation Officer or Advisory Council on Historic Preservation determines that compliance with the requirements for accessible routes, entrances, or toilet facilities would threaten or destroy the historic significance of the building or facility, the exceptions for alterations to qualified historic buildings or facilities for that element shall be permitted to apply.
Advisory F202.5 Alterations to Qualified Historic Buildings and Facilities Exception. Section 106 of the National Historic Preservation Act requires that a Federal agency with jurisdiction over a proposed Federal or federally assisted undertaking consider the effect of the action on buildings and facilities listed in or eligible for listing in the National Register of Historic Places prior to approving the expenditure of any Federal funds. The Advisory Council on Historic Preservation has established procedures for Federal agencies to meet this statutory responsibility. See 36 CFR Part 800. The procedures require Federal agencies to consult with the State Historic Preservation Officer, and provide for involvement by the Advisory Council on Historic Preservation in certain cases. There are exceptions for alterations to qualified historic buildings and facilities for accessible routes (F206.2.1 Exception 1 and F206.2.3 Exception 6); entrances (F206.4 Exception 2); and toilet facilities (F213.2 Exception 2). These exceptions apply only when the State Historic Preservation Officer or the Advisory Council on Historic Preservation agrees that compliance with requirements for the specific element would threaten or destroy the historic significance of the building or facility.
The Accessibility Office at the National Endowment for the Arts (NEA) provides a variety of resources for museum operators and historic properties including: the Design for Accessibility Guide and the Disability Symbols. Contact NEA about these and other resources.
The following “rules of thumb” will aid in the careful placement of building hardware in ornamental wall finishes.
- If the existing hardware is located within 54 inches from the floor, for side reach accessibility, and within 49 inches from the floor, for front reach accessibility (based on ADA wheelchair maneuverability requirements), retain the existing hardware in place.
- If new hardware is required, install it in place of the existing hardware to avoid cutting a new hole in the wall. Specify new hardware finishes matching the original hardware.
- Consult Regional Historic Preservation Officer (RHPO) to determine if salvaging the original hardware is required.
- Notify the RHPO in writing if retaining existing hardware in place will require special consideration (for historic preservation) in deviating from the handicapped access code. State the code requirement and the allowance (inches from required height) needed to reuse the existing hardware. The preservation staff member reviewing the project will prepare the special request for submission to the GSA Administrator.
- If the existing hardware is located above 54 inches from the floor, for side reach accessibility, or above 49 inches from the floor, for front reach accessibility, retain the existing hardware in place.
- Cut the wall the minimum extent necessary to install new, handicapped accessible hardware separately. Install the new hardware (matching original hardware’s finish) at a location five to ten feet away from the existing hardware. When this is not possible, align new and old hardware vertically.
- Do not install new and old hardware together on an enlarged backplate. Do not remove old hardware and cover hole with an enlarged backplate. The intent is to minimize cutting into the ornamental wall material.