Carol A. Cocuzzi, Principal, Accessibility Matters, LLC

Carol A. Cocuzzi, Principal
Accessibility Regulations Consultant
Since 1988
Business Address: 49 Bigelow Street, Pittsburgh, PA 15207
Phone: (412) 403-3023 (VOICE / TDD)
E-mail: ccocuzzi@accessibilitymatters.net
Website: www.accessibilitymatters.net

CAROL A. COCUZZI, PRINCIPAL
BIO
Ms. Carol Cocuzzi is Founder and Principal of Accessibility Matters, LLC since 2008,
a small, woman-owned, accessibility consulting business which assists all businesses in all
industries, design and construction professionals, Federal, State, and local government
entities, and commercial and multifamily residential housing providers and developers
achieve accessibility compliance.
Ms. Cocuzzi is responsible for the management, growth and technical services of her
company. In her capacity, Ms. Cocuzzi coordinates design and construction consulting
services including facility/building evaluations of new and existing properties, plan review
during from the schematic phase through construction documents, regulatory and product
review and research, self-evaluation and transition plan development, customized on-site
and online technical and awareness training programs, and expert witness services. Her
objective is to provide cost-efficient and practical modifications compliance
recommendations and suggestions to her customers to ensure they have meet the
letter...and spirit of all Federal, State and local disability-related laws and building codes.
Ms. Cocuzzi has a thorough working knowledge of Federal Regulations including ADA
Title I: Employment, Title II: State and Local Government Programs, Services, and
Activities, and Title III: Public Accommodations and Commercial Facilities, Section 504
of the Rehabilitation Act of 1973, Architectural Barriers Act of 1968, and Fair Housing Act
of 1988. She is well-versed in the scoping and technical provisions of International
Building Code (IBC), and has been a certified Accessibility Specialist/Plans Examiner
through the International Codes Council (ICC) since 2003.
Additionally, Ms. Cocuzzi develops and participates in the company's customer service
sensitivity training programs, fire and life safety awareness programs and design and
construction training programs. She performs public speaking on behalf of the company
related to the ADA and other accessibility-related issues.
As a woman who has lived with a disability all of her life, Ms. Cocuzzi has a unique
understanding to the needs, challenges, and issues that face people with disabilities in their
everyday lives. This sensitivity allows her to bring a professional, personal and creative
approach to resolving accessibility concerns, particularly as it relates to removing barriers
within existing structures, in new design, construction, furniture/equipment usability and
functionality, and training.
ADDRESS: 49 Bigelow Street, Pittsburgh, PA 15207
PHONE: (412) 403-3023
E-MAIL: ccocuzzi@accessibilitymatters.net
WEBSITE: www.accessibilitymatters.net

RELEVANT WORK EXPERIENCE
2008 to Principal, Accessibility Matters, LLC, Pittsburgh, PA
Present Founder of an accessibility consulting business that’s main objective is to
assist large and small businesses within all industries, design and construction
professionals, Federal, State, and local government entities, and commercial
and multifamily residential housing providers and developers ensure
regulatory compliance with all disability-related laws and building codes.
Responsible for all contract negotiations, management and growth of the
company and supervision of 1 part-time employee and 1 independent
subcontractor.
1994 to Vice President, Design Consulting Services (Promotion)
2007 Accessibility Development Associates, Inc., Pittsburgh, PA
An affiliate of Three Rivers Center for Independent Living, Inc.
Responsible for the creation, development, management and growth of the
design consulting services department that provides comprehensive plan
review, product research and review, contract warranty, educational training
series, and technical assistance services to businesses, corporations,
educational, governmental, and residential communities in their efforts to
comply with the Americans With Disabilities Act, and other anti-
discrimination accessibility-related laws, standards and codes. Management
includes the supervision of professional consultants and design interns.
1992 to Technical Assistance Coordinator (Promotion)
1994 Three Rivers Center for Independent Living
Business Accessibility Disability Awareness Department
Responsibilities included accessibility evaluation and plan review services of
public and privately owned buildings to determine compliance with Title II
and Title III of the Americans with Disabilities Act (ADA), Section 504 of the
Rehabilitation Act of 1973, and Fair Housing Act. Performed training on
Disability Sensitivity Awareness Etiquette to organizations and employers on
how to effectively interact with people with disabilities, as the public or
employees and co-workers.
1992 to HUD Approved Service Coordinator/Housing Counselor (Promotion)
1990 Three Rivers Center for Independent Living
Center for Independent Living of Southwestern Pennsylvania
Responsibilities included assisting consumers/general public with disabilities
seek out / secure accessible, affordable and public or fair-market housing.
Performed Section 504 accessibility evaluations of federally-funded housing
providers to ensure that each housing property met all applicable accessibility
requirements under the Rehabilitation Act of 1973, and Fair Housing
Amendments Act of 1988. Conducted individual in-home assessments to
assist consumers to remain living in their homes by providing services such as
attendant care, peer counseling, design / product solutions, and housing
counseling services./ Assisted homeless individuals seek immediate
temporary and long-term accessible housing.

EDUCATIONAL BACKGROUND
 Stratford Career Institute (Distance Learning Program–Computer-Aided Drafting
Program (June 2015–present)
 Edinboro University of Pennsylvania—School of Social Work (June 1981–October
1981. Did not complete due to family illness)
TRAINING
Participated in a seminar presented by the U.S. Department of Housing and Urban
Development on the design and construction guidelines for residential facilities as required
under Section 504 of the Rehabilitation Act of 1973.
Participated in the DesignDC 2005 conference sponsored by the Washington DC, Northern
Virginia, and the Patomac Valley Chapters of the American Institute of Architects (AIA),
Winter 2005. Sessions Include:
 What’s New with the ADA
 Building In Maryland
 The Best Defense is a Good Defense (Risk Management)
 A Mighty Fortress (Security Design Strategies)
 Building in DC
 There’s No Place Like Home (Fair Housing Law)
 You’ve Started Your Own Firm, But What’s the Next Step? (Marketing)
Participated in the Ask the Department of Justice Teleconference Training, conducted
Maryland Coalition for Education and the ADA&IT, Winter 2005
Participated in the Annual ADA Update, conducted by Maryland Coalition for Education
and the ADA&IT Information Center for the Mid-Atlantic Region, Fall 2004
Participated in the first annual Conference on Emergency Preparedness for People with
Disabilities conducted the National Organization on Disability, Fall 2004
Participated in Fair Housing and Equal Opportunity Training conducted by the U.S.
Housing and Urban Development, and the Center on Universal Design, St. Paul,
Minnesota, 1993
Participated in the Conference on Barrier-Free Design conducted by the American Society
of Interior Designers, 1993
Participated in Training in the Americans with Disabilities Act, conducted by Three rivers
Center for Independent Living, Pittsburgh PA, Summer 1992

TRAINING (CONTINUED)
ADA Online Series through the U.S. Access Board and ADA National Network:
2009
 June — Prepare for the unexpected: Emergency Preparedness/Evacuation for the
people with Disabilities
2010
 February—Federal Facilities and the ABA Standards
 June—Accessible Sidewalks and Street Crossings
 September—DOJ's 2010 ADA Accessibility Standards
 August—ADA & After School and Daycare Programs for children with disabilities
 December—Accessible Play Areas
2011
 March—Accessible Swimming Pools and Spas
 April—Are My Recreation Facilities Accessible? Where Do I start?
 August—Accessible Health Clubs and Fitness Facilities
 October—Accessible Retail Stores and Spaces
 December—Accessible Schools
2012
 February—Accessible Courthouses and Courtrooms
 May—Accessible Communication Elements and Features
 August—Accessible Detention and Correctional Facilities
 October—Assistive Listening Systems
 November—Accessible Historic Buildings and Facilities
 December—Accessible Medical Diagnostic Equipment
2013
 January—Accessible Amusement Rides
 February—Accessible Means of Egress
 April—Accessible Restaurants and Cafeterias
 May—Accessible Elevators and Platform Lifts
 June—Accessible Fire Alarm Systems
 November—Accessible Playground Surfaces
2014
 July—Accessible Toilet and Bathing Facilities - Advanced session
 August—Accessible Routes - Advanced Session
 November—Accessible Retail Stores and Spaces - "Advanced Session"
 December—Accessible Emergency Transportable Housing

PROFESSIONAL CERTIFICATIONS
 Third Party Agency Certification, Certified by the Commonwealth of Pennsylvania,
Department of Labor and Industry
 International Conference of Building Officials Certification (ICBO), Certified by
ICBO and BOCA as a Building Code Accessibility/Specialist, plans examiner.
Summer 2003
PROFESSIONALAFFILIATIONS
 American Institute of Architects (AIA) / National and Pittsburgh Chapters
 International Codes Council (ICC)
 Southwestern Pennsylvania Engineering Outreach
 Master Builders Association of Western Pennsylvania
PROFESSIONAL / VOLUNTEER ACTIVITIES
 Independent Living Task Force/Transportation Subcommittee
 Southwestern Pennsylvania Transit Coalition
 Port Authority 504 Task Force
 Americans with Disabilities Act Transportation Working Group
 Allegheny County Advisory Committee on Housing for the Homeless
 Mayors Committee On Accessibility, City of Pittsburgh
 Carnegie Mellon University ADA Barrier Removal Committee
 Community College of Allegheny County ADA Barrier Removal Committee

Apostolou Architects, P.C.
Plan Review—Brant Pittsburgh Motor
Speedway
Astorino
Plan Review—UPMC Children’s Hospital
Plan Review—Allegheny County Lab
Plan Review—PNC Park
Plan Review—UPMC Montefiore Hospital
Plan Review—3 PNC Plaza
Plan Review—Edinboro University Cooper
Hall
Plan/Product Review—Mitsubishi Hand Dryer
Bob Evans Restaurant
ADA Review—Restaurant Accessibility
Management Program Checklist
Plan Review—Parking/Carryout Conditions at
Lakewood
Buchannon Ingersol & Rooney
Expert Witness Services
Burns White LLC
Expert Witness Services
Bergman Walls
Plan Review—Majestic Star Casino Site
Review
Carnegie Museums of Pittsburgh
Facility Evaluation—Library
Facility Evaluation—Museum of Natural
History
Carnegie Mellon University - Academic
Plan Review—University Center
Plan Review—Purnell Center for the
Performing Arts Plan
Plan Review—Doherty Hall
Plan Review—Baker Hall
Plan Review—Science Technology Building
Plan Review—Gates Center for Computer
Science
Plan Review—Baker Hall
Plan Review—Baker Hall Science and
Technology
Plan Review—Center Science and Technology
Center
REPRESENTATIVE CLIENT LIST
Carnegie Mellon University - Housing
Plan Review—Doherty Hall
Plan Review—Mudge House
Plan Review—Welch Hall
Plan Review/Facility Evaluation—New First
Year Residence Hall
Chipotle
Plan Review—Restaurant Footprint
City of Coeur d’ Alene, Idaho
Plan Review—City Curb and Pedestrian
Ramps
City of Pittsburgh
Plan Review—Allegheny Riverfront Park
Plan Review—Rachel Carson Riverfront Park
Project
Facility Evaluation—Allegheny County Jail
City of Pittsburgh Housing Authority
Plan Review—Elmore Square/Addison Terrace
Plan Review—Glen Hazel High Rise - Tenant
Bathroom Design
Commonwealth of Pennsylvania
Department of Conservation and Natural
Resources, Bureau of Recreation and
Conservation (BRC)
Document Review—Best ADA Management
Practices for Recreation Facilities
Community Builders, Inc.
Tenant Accommodation Alternatives
Consultation
Plan Review—East Liberty Place South
Controls Link, Inc.
Plan Review—New Office Building
Cope Linder Architects
Plan Review—Pompano Park Casino, FLA
Custom Millcraft Corporation
Plan/Product Review—Check Desk Furniture
Reviews (2)
Design 3 Architects
Plan Review—Applebee's Restaurants

Design Alliance
Facility Evaluation—Engineers' Society
Building
Plan Review—ALCOA Corporate
Headquarters
Plan Review—Rodef Shalom Temple Hill
House Association
Plan Review—GATF Headquarters
DJDC Architects
Facility/Plan Review—Coventry Health Care
Building
Facility/Plan Review—United Steelworkers
Building
IBC-ANSI TA Guidance—UPMC Klinevester
Plan Review—Coraopolis Hts. Road 1555
IBC-ANSI TA Guidance—Chevron Temporary
Water Lab
Duquesne Light Company
Plan Review—Entrance Doors
Plan Review—Office Renovation
EDGE Studio
Plan Review—The New Hazlett Theater
Plan Review—Carnegie Mellon University
Office Building
ESB Bank
Parking Lot Evaluations—25 Locations
First National Bank/Pennsylvania, Ohio,
Maryland
Foreman Group
Plan Review—Plum Senior High School
Gateway Engineers
Plan Review – Kmart Parking Lot, Peters
Township
Gardner + Pope Architects
Plan Review/Lazarus Furniture Store
Plan Review/Greater Pittsburgh Community
Food Bank of the Future
Plan Review/National City Bank
Plan Review /Cancer Care Center,
Wilmington, DE
Hertz Gateway, Inc.
Plan Review/Gateway Unisex Toilet Review
Plan Review/HDR, Engineering Renovation
Plan Review/Gateway Eye Assoc. Ramp
Highmark, Inc.
Plan Review—Data Center
Facility Review—6 Highmark Direct Retail
Stores
Plan Review—Kingswood Plaza
Plan Review—The Shops at Cedar Point
HO+K Sport Architects
Plan Review—PNC Park
IKM, Inc.
Plan Review—Allegheny County Jail
Reuse Project
Plan Review—VA Hospital Patient Room
Alteration
Plan Review—Phipps Conservatory and
Botanical Gardens
Plan Review—Pittsburgh Ballet Theatre
John Ryan Furniture
Plan/Product Review—Check Desk
Plan/Product Review—24-Hour Check Desk
Plan/Product Review—Host/Universal
Workstation
Plan/Product Review—/Coffee Cart
Plan/Product Review—Phone Desk
Kawneer Company, Inc.
Product Regulatory Research—State/Local
Requirements for Doors
Product Review—Door Hardware Prototype
KSBA Architects
Building Evaluation—Lexington Industrial
Park
Plan Review—Ellis School Renovations
Lami - Grubb Architects
Feasibility Study—Carnegie Library of
Pittsburgh
Plan Review—Radisson Hotel

LaQuatra Bonci Associates
Plan Review—Convention Center Riverfront
Park Extension
Lowes Home Improvement Centers
MEDExpress Urgent Care Centers
Plan Review—Jackson, MI Prototype
Maclachlan, Cornelius & Filoni Architects
Plan Review—O'Reilly Theatre
Mars National Bank
Massaro Corporation
Plan Review—ISR Building
Mascaro Corporation
Plan Review—Encore @ 7th Street Apartments
Plan/Product Review—Shower water curb
products
Regulatory Review—Fair Housing
Amendments Act 1988
Mistick Corporation
Plan Review—Munhall Municipal Building
Plan Review—Fairmont Apartments
Michael Graves Architect
Plan Review—O’Reilly Theatre
Michael Van Valkenburgh
Plan Review—Allegheny Riverfront Park—
Phases I & II
National Aviary
Plan Review—FliteZone Theatre
North Fayette Township
Plan/Product Review—New Community Park
Northwest Savings Bank
Parking Lot Evaluations – 92 Locations
Oil City Housing Authority
Plan Review/Century Terrace Family
Parsons Brinkerhoff
Plan Review—Hot Metal Bridge Renovations
Penn Avenue Place
Plan/Product Review—Multi-Story
Conversion to Tenant Space
Perkins Eastman Architects
Plan Review—Sylvania House
Plan Review—Felician Sisters Convent
Dementia Wing
The Pidcock Company
Plan Review—Minor League Baseball League
Exterior Route
Plan Review—Borough of Boyertown Public
Rights-of-way
Plan Review—Upper Saucon Township Public
Rights-of-way
Pitt Dental School
Plan Review—Dental School Renovations
PNC Bank, N.A.
Plan Review—Miracle Mile
Plan Review—Two PNC Plaza
Plan Review—General Services Building
Rafael Vinoly Architects, P.C.
Plan Review—David L. Lawrence Convention
Center
REI
Plan Review—Conshohockhan, PA Employee
Rest Rooms/Shower Room
Plan Review—Texas, Storage Location
Plan/Product Review—Cash wrap
Plan/Product Review—Kiosk
R3A Architects
Plan Review—Edinboro University
Plan Review—Housing Authority City of
Pittsburgh Dwelling Unit Renovations
Plan Review—Addison Terrace
Plan Review—Garfield Heights
Plan Review—Northview Heights

RTKL Architects, Inc.
Plan Review—Highmark Data Center
Plan Review—MILDEP (Military Installation)
Plan Review—3000 Skyline Drive Office Bldg.
Master Plan Dev.—University of Buffalo
Building Condition Report—NARA: Dwight D.
Eisenhower Library and Museum
Building Condition Report—NARA: Harry S.
Truman Library and Museum
U.S. Dept. of Health and Human Services—
Administration for Community Living
Shannopin Country Club
Facility Review - Parking Lot, Route and
Entrance
Senior Care Network, Inc.
Plan Review—Washington County
Developments (3 developments)
SPC Realty Company
Sourceone/Terrytown Estates, NY
Plan Review—Cottages and Sports Facility
St. Anthony's Parish
Facility/Plan Review—Parking Lot and Rest
Rooms
Standard Property Corporation/Highmark -
Blue Cross Blue Shield
Plan Review—Penn Avenue Place
Plan Review—Data Center
Plan Review—Cancer Care Center
Starbucks Coffee
Plan Review—Coffee Station Location
Studio AB
Plan/Product Review—Elm At Calvert Plan
Review—Townhouse Dwelling Units
University of Pittsburgh
Plan/Product Review—U.S. Attorney General
Richard Thornburgh Room
Plan Review—New Residence Hall
Plan/Product Review—Langley Hall
Greenhouse
UPMC Health Services
Plan Review—Magee Women’s Hospital
Patient Room Alterations
Product Research—Review/Magee Women’s
Hospital Medical Equipment
Plan Review—Montefiore Hospital Lobby and
First Floor Alterations
Plan Review—Passavant Hospital
Plan Review—Children’s Hospital of
Pittsburgh
US Homes Corporation, Elk Grove, CA.
Plan Review – Boardwalk at Lakeside Gated
Community
Turkall Associates Architects
Plan Review—City of McKeesport Housing
Authority
Trizec Hahn
Plan Review—Palamino Restaurant
Weber Murphy Fox
Plan Review—Edinboro University/Student
Housing
Westmoreland County Housing Authority
Reasonable Accommodation Consultation
for Tenant Dwelling Unit Modifications
Westin Convention Center Hotel
Limited Evaluation/Plan Review—Accessible
Guest Room Renovations
White Castle Restaurant
Plan Review—White Castle Restaurant
Prototype
WTW Architects
Plan Review—South Side Works Theatre
Wolf Consulting, Inc.
Plan Review—Murraysville Office
United Refining Company
Zamagias Properties

Carol A. Cocuzzi
PROFESSIONAL SPEAKING ENGAGEMENTS
Ms. Cocuzzi has developed the following educational presentations, and training programs
for professionals (architects, attorneys, engineers, developers and organizations), which are
certified for CEU’s and CLE’s.
“The ADA And the Restaurant Industry”
Co-presented with Joan Stein
Chipotle Mexican Grille Restaurant Designers, Contractors and Facilities
Management Staff
“Understanding the Needs of People with Mobility Impairments”
Co-presented with Joan Stein, and Mr. Ray Bloomer of the National Center on
Accessibility
PA Department of Parks and Recreation
“Thinking In the Box”
SPECS 2001 Conference in Nashville, TN—Co-presented with Joan W. Stein
“The ADA and the Small Business”
Allegheny Valley Rotary
“Understanding the Fair Housing Laws and the ADA”
US Department of Housing and Urban Development
Pittsburgh Regional Meeting
“Home Sweet Accessible Home”
Realtors Association of Metropolitan Pittsburgh
“An Ounce of Prevention is worth a Pound of Cure”
Pennsylvania Department Bureau of Managed Care Health Choices Program
Health Care Providers
“HealthyChoices”
Pennsylvania Department Bureau of Managed Care Health Choices Program
Consumers
“Fire and Life Safety Disaster Preparedness Program—Unlocking the Fear”
Co-presented with Mr. William Johnson, Corporate Security
Highmark

(CONTINUED)
Emergency Preparedness Program”
Co-presented with Mr. Frank Butter, Corporate Security
Winthrop Management
“Construction Projects and the ADA”
Lorman
“ADA Update—Then and Now”
Astorino
The Design Alliance
EDGE Studio
Massaro Construction
“2010 ADA Standards for Accessible Design”
Astorino Architects
DJDC Architects
Environmental Planning and Design
“Uniform Construction Code”
City of Pittsburgh Bureau of Building Inspection
Desmone Architects
“Structure Reflects Values”
In-house training offered to design professionals within Southwestern PA
Co-presented with Joan Stein and Clifford Payne
“The ADA - It’s More Involved Than Toilet Rooms”
Burt Hill Kosar & Rittleman
The Design Alliance
KSBA Architects
Perkins Eastman Architects
MacLachlan Cornelius Filoni Architects
IKM, Incorporated
Hansen Architects
HDR Engineering
The Fair Housing Act and Section 504 of the Rehabilitation Act of 1973
Pennsylvania Housing Finance Agency
Carol A. Cocuzzi

(CONTINUED)
“Title II of the ADA: An Educational Experience”
University of Pittsburgh Facility Management Services
“Construction Projects and the ADA”
Lorman
“The ADA—It’s Not a Building Code, It’s Not an Option...It’s the Law”
Massaro Construction
“ADA and the Restaurant Industry”
MS Consultants, Inc.
“Section 504”
Housing Authority of the City of Pittsburgh
Ms. Cocuzzi has developed the following “2010 ADA Regulations and Standards for
Accessible Design Online Training Program Series” attended by more than 450
professionals (architects, attorneys, engineers, developers and organizations), which are
certified for CEU’s and CLE’s.
 AIA DC, AIA Baltimore, AIA Eastern Tennessee, AIA PA
 Housing and Redevelopment Authorities
 State and Local Government
 Retail and Shopping Centers
 Children Day Care
 Elementary, Middle and High Schools
 Secondary Educational Institutions
 Homeless Shelters
 Health Care Providers
 Recreational Facilities
 Religious Organizations
 Outdoor Developed Areas
 Military Housing
Carol A. Cocuzzi

AUTHORED PUBLICATIONS
 Co-authored with Joan Stein “With ADA, It’s `Buyer Beware.’ Building Operating
Management, January 2003
 Co-authored with Joan Stein “ADA: Watching & Waiting”, Maintenance Solutions
magazine, April 2001
 “Focus on Accessibility Will Make PNC Park Everybody's Ballpark”, Pittsburgh
Post-Gazette July 1999
 Barrier-Free Design, Marketplace, Pittsburgh Post-Gazette
Carol A. Cocuzzi

With ADA, It’s
`Buyer Beware’
Avoiding problems with new construction means asking
the RIGHT QUESTIONS of architects and contractors
facilitymanagement
Building owners and facility executives rely on the guidance and knowledge of
architects and contractors when buildings are being constructed or renovated. Confidence in
the architect’s or contractor’s ability to meet all applicable codes and regulations is usually a
given. Just to be safe, of course, contracts include the clause “must comply with all applicable
codes and regulations” to be sure all the bases are covered.
Since passage of the Americans with Disabilities Act (ADA) in 1990 and the
implementation of Americans with Disabilities Act Accessibility Guidelines, or ADAAG,
some building owners and facility executives have inserted specific references to
nondiscrimination and compliance with the ADA into contract language. On the surface, this
seems to offer all the protection needed. ADA is a federal law; it’s easy to assume that all
architects and contractors must comply with it and fully understand it. But in real life, things
aren’t so simple. Consider incidents like these:
 The design professional submits plans for the renovation or construction to the
appropriate regulatory agency for approval. Municipal, city or state officials review the
plans and refuse to approve them because of noncompliant items under ADA, including
significant elements of the project (entrances, interior access, rest rooms, etc.). The
impact on the project timeline and budget is substantial.
 The designer gets approval of the plans, which were designed in accordance with ADA.
However, due to contractor errors or omissions related to ADA, the occupancy permit is
denied following on-site review. Once again, the impact on the project timeline and
budget is substantial.
 Either the architect or
contractor makes errors
related to ADA
requirements, but the
errors are not caught at
either the plan review or
the on-site inspection. The
project is completed on
time and within budget.
But within 10 days, the
ADA complaints begin:
parking problems, stairs

at entrances, doorways and, often, bathrooms. At first, the response to those complaints is that
they can’t be valid. How could a new building be completed if it did not follow “code”?
NOT A CODE
One problem with that response is ADA is not a building code; it is a civil rights law.
Although much of it is predicated on ANSI and other building code formats, the reality is that
complaints of noncompliance can be initiated solely on the perception of discrimination. But most
ADA complaints aren’t just a matter of perception; they involve failure to meet the requirements
spelled out in ADAAG.
Whose responsibility is it to meet those requirements? Ultimately, responsibility falls to
the building owner. Other construction professionals may also be liable, but that doesn’t mean the
building owner has no responsibility. To be an informed buyer of architecture and contracting
services, the best approach to take is “buyer beware.”
QUALIFICATION QUESTIONS
It’s worth investing some time upfront to be sure that the project expected is actually the project
delivered. Here are questions to ask architects and contractors; many apply to product
manufacturers and representatives as well:
 Is the firm knowledgeable in the various disabilityrelated laws and requirements pertinent to
the project?
 What is the firm’s design philosophy, particularly on accessibility and universal design?
 What sets this firm apart from the rest?
 Does the firm involve people with disabilities in the design process?
 How disruptive will construction be to persons with disabilities?
 If the scope of the project changes later, will there be additional fees? How will these fees be
justified?
 Does the firm have a list of past client references for similar accessibility projects that can be
contacted?
The same approach applies to evaluations of product maintenance and warranties:
 What is covered under the product warranty?
 Does it include parts and labor or just parts?
 How long is the warranty in effect?
 Are there extended warranties that may be purchased?
 What is the typical demand-response for repairs?
 Does the vendor keep parts for the product?
 How long does it take for the parts to come in?
 What if parts are no longer available for the product?
 If the product is a lift, can it be operated manually in the event of a power failure or low
battery?
 Do manufacturers offer training in the installation and servicing of this equipment?

For purposes of ADA compliance, the facility executive must make sure that the building
owner’s interests are being protected. Doing that means asking the tough questions and
digging for answers. Make sure design and construction professionals include “errors and
omissions” in their liability coverage. If a complaint is made against the owner or
management of the building, be prepared with the documentation of the process used to
ensure ADA compliance.
Joan W. Stein (jwstein@adaconsults.com) is President and CEO of Accessibility
Development Associates Inc. in Pittsburgh, and Carol Cocuzzi is Vice President of
Design Consulting services for that firm.
Accessibility Development Associates, Inc. is located at Three Gateway Center, 5th
Floor, 401 Liberty Ave., Pittsburgh, PA 15222. 412-471-4156 (Voice/TDD), 412-471-
4348 (Fax).
This article was originally published in the January 2003 issue of Building Operating
Management magazine. Reprinted with permission of Trade Press Publishing Corp.

ADA Experts Discuss 2010 Standards
FacilitiesNet
By Chris Matt, Managing Editor
*Joan Stein, President & CEO, Accessibility Development Associates Inc.,
Pittsburgh
*Peter Berg, Project Coordinator of Technical Assistance, ADA National Network,
DBTAC Great Lakes ADA Center, Chicago
*Carol Cocuzzi, Principal, Accessibility Matters LLC, Pittsburgh
Almost 20 years after its inception, the Americans with Disabilities Act (ADA) has
undergone significant changes. The U.S. Department of Justice (DOJ) published the 2010
ADA standards in the Federal Register on Sept. 15, starting the clock on an 18-month
period maintenance and engineering managers can use to learn about the updated
regulations and their impact on facilities before they go into effect on March 15, 2012.
What are three key technical differences between the 1991 and 2010 standards?
STEIN: First, there's a change in the reach ranges for where you mount anything like a
dispenser, light switches or electrical outlets. Under the 1991 standards, they allowed for
a maximum of 54 inches above the finished floor for a side approach and a maximum of
48 inches above the finished floor for a front approach. The 2010 standards have
basically blended with the ANSI requirements and say it's 48 inches maximum for either
front or side. The second is probably the biggest one we find, and that is, under the 1991
standards, the requirements for the toilet center line — the space from the side wall to the
center of the toilet — is an absolute 18 inches. Under the 2010 standards, they again have
mirrored what's in the ANSI requirements, which is a range of 16-18 inches for a toilet in
a standard, accessible stall. They give the range as opposed to the absolute. Third, they
increased the clear-floor-space requirements for water closets in a toilet room.
BERG: One of the areas where the (U.S.) Access Board and Department of Justice
attempted to make compliance with the standards a little easier is, wherever possible,
they've gone to ranges instead of absolutes. There were fairly significant changes with
reach ranges. The 1991 standards allow for a higher reach range when an element can be
approached by a side or parallel approach. It's 54 inches on the high side and 9 inches on
the low side. The 2010 standards have unified that. So for either a forward or parallel
approach, the reach range is 48 inches on the high side, 15 inches on the low side. The
most significant thing is the new supplemental areas. In the 1991 standards, there were no
scoping or technical requirements for the various types of recreation facilities. Those are
now part of the 2010 standards.

COCUZZI: Facilities now can reduce down (the number of accessible seats in assembly
areas, for example) using the 2010 standards, where a lesser requirement is allowed. The
second is accessible routes. In the 2010 standards, they are requiring that accessible
routes coincide with those of the same areas as the general public, whereas, in the 1991
standards, it was always to the maximum extent feasible. The third one is different
requirements for toilet rooms because those are generally one of the most talked about
when it comes to accessibility. There are going to be new requirements for clear floor
spaces in toilet rooms.
Is there a difference between the 2010 standards and the 2004 ADA/Architectural
Barriers Act Accessibility Guidelines?
COCUZZI: The new ADA standards are based on what was developed in 2004 when the
new guidelines were originally supposed to come out. When the whole process began to
revise the guidelines to include different types of facilities and areas, it was originally
going to be adopted around 2004 or 2005. But they kind of sat there for a while. A major
difference in the 2010 standards is in the regulatory part, where they address ticketing,
service animals, safe harbors and communications, and mobility devices, such as
Segways.
How will the new standards affect compliance efforts?
STEIN: When you talk about the compliance process, it's an 18-year-old process, which
began on Jan. 26, 1992. What the Justice Department is doing with this set of regulations
and time frames is trying to deal with the fact that when they passed the ADA in 1990
and gave the 18-month period for the regulations to be completed — between July 26,
1990 and Jan. 26, 1992 — this was the first time in history companies in private industry
had obligations to address anything related to accessibility. The Justice Department is
trying to put in that same kind of grace or implementation period (with the 2010
standards). They are actually giving managers and everybody else more options because
as of Sept. 15, 2010, you could choose to use either the 1991 standards or the 2010
standards. But when you make that choice, as a colleague of mine said in an e-mail
recently: "You've got to pick that horse and ride that horse."
COCUZZI: Yeah, it will, particularly those that may be (undertaking projects) under new
construction and alterations. They're going to have the ability to use these standards and
reduce down, which will be cost savings to them. It will also enhance accessibility in
certain areas.
BERG: For some venue types, it may make sense or (managers) may want to use the
2010 standards. For example, I'll use assembly areas. For large assembly venues (such as
sports arenas), in the 2010 standards there are fewer wheelchair-seating locations
required. There is a reduction in the number of accessible wheelchair-seating locations.
For a larger venue, you can use the 2010 standards and actually remove some wheelchair-
seating locations and put in standard seats.

Can you explain the safe harbor?
COCUZZI: If you have a facility that you are in total compliance with under the 1991
standards, you're not going to need to have to modify anything until you decide to make
alterations after the 18-month period. Even beyond that, if you choose not to (make
alterations), and you're in compliance, you're fine.
BERG: The safe harbor becomes effective March 15, 2012. That's the date the 2010
standards are the only standards that can be used. At that point, if a building or facility
was constructed or altered in compliance with the 1991 standards or, if it was a state or
local government entity and they used UFAS (Uniform Federal Accessibility Standards),
they do not have to touch those areas. They fall into that safe harbor because they were
constructed or altered in compliance.
STEIN: Facilities have a period of time now where, if you are confident that your facility
is compliant — you've identified all of your barriers and have completed all readily
achievable barrier removal, or you altered or newly constructed since 1992 and you are
100 percent confident your design professionals really did understand (ADA) is a civil-
rights law and not a building code — then those can be your safe harbors. The safe harbor
means you will not have to do anything until the next time you touch that area — make
modifications that are structural in nature and affect primary function of the space.
When planning retrofits or new construction projects, how do managers balance the
need to comply with both ADA standards and building codes?
STEIN: It's important to understand that the ADA is a civil-rights law, not a building
code. The ADA does have a provision that, if there's a state or local code that provides
for a greater degree of accessibility or is more stringent, that will supersede the federal
standards. That is the only time they will supersede the federal standards.
BERG: It's the federal government that enforces ADA. Local building-code officials don't
have authority. They only have the authority to enforce the state building code or local
municipal code. ADA standards clearly state that wherever there is a conflict between the
federal code and a state code, you must comply with whichever provides greater access
or is least restrictive.
COCUZZI: Sometimes, if you comply with ADA and you don't comply with the building
code, you're not going to get your occupancy permit. We're hoping with these new
standards — which are actually based on ANSI A117, which deals with accessible
buildings and facilities — will reduce compliance issues between (ADA and ANSI). Up
until then, there were significant differences in the technical and scoping requirements
versus ANSI, and, a lot of times, significant confusion. That really caused great havoc
between the building-code inspectors and building managers that have these two
documents they have to comply with.

Why did the changes focus on recreational facilities, detention facilities,
courthouses, etc.?
BERG: Areas where there were no scoping or technical requirements in the 1991
standards, there are no safe harbor for those come March 15, 2012. The Access Board, in
its development of guidelines, recognized that there were certain facility types that
presented unique accessibility issues. Therefore, they felt that there needed to be specific
scoping, and more importantly, technical requirements for providing access at these
various types of facilities. Recreation facilities, courthouses, penitentiaries, holding cells,
for example, have different features that weren't really addressed in the 1991 standards.
COCUZZI: Up until this point, there were no technical or scoping regulations for those
specific areas. You had to think outside the box and say, "What can I do to make these
specialty areas more user friendly?"
STEIN: There are completely new areas in 2010 that were never addressed in 1991 —
children's environments, outdoor recreation, golf courses, boats, etc. There are new rules
that address those issues, and there is more specification and more detailed requirements
for things that were not clearly defined in 1991 but created quite a lot of litigation. There
are now technical and scoping requirements. Before (the new regulations), if you were
evaluating a child-care center under ADA, you didn't have anything that said a toilet can't
be any higher than X inches, or that a table where kids work can't be X inches. There
were no enforceable standards.
Can you talk about the effective communication portion of the changes?
STEIN: There is a lot more available now in terms of technology for effective
communication. It doesn't just say, "Effective communication dependent on the scenario
and the extent, duration, and importance of the communication." What (the DOJ) found
was there were too many lawsuits. People just weren't using common sense. When you're
installing (effective-communication measures) from the beginning, the cost is nothing.
It's when you didn't do it and you have to retrofit it (where it gets expensive). The
technology explosion — smart phones, video conferencing, etc. — that everyone is using
is also extremely effective for individuals with disabilities.
COCUZZI: Under the new regulations, a public accommodation is going to need to
include what is called video remote interpreting, which can be used as a means of
effective communication. For example, where they may have had to bring in a sign-
language interpreter, which is expensive, now they can do it real time through full-motion
video and interpreting. It probably in the long run will allow for a cost savings.

Carol A. Cocuzzi, Principal, Accessibility Matters, LLC

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