Uniform Federal Accessibility Standards: UFAS Rules and Waivers

The Uniform Federal Accessibility Standards, known as UFAS, are the 1984 technical rules issued under the Architectural Barriers Act of 1968 for making federally funded buildings usable by people with disabilities. They originally governed the four standard-setting agencies: the General Services Administration (GSA), the Department of Defense (DOD), the Department of Housing and Urban Development (HUD), and the United States Postal Service (USPS). Three of those four have since moved to the newer ABA Accessibility Standards, so today UFAS is essentially a HUD document, kept alive as one compliance option for federally assisted housing.¹

Which Standard Actually Applies to Your Project

Before reading any UFAS provision, confirm that UFAS is still the right book. Between 2005 and 2008, three of the four standard-setting agencies replaced UFAS with the updated ABA Accessibility Standards (ABAAS). USPS adopted ABAAS in May 2005, GSA followed in November 2005, and DOD adopted them in October 2008.¹ Projects under any of those three agencies follow ABAAS, not UFAS.

HUD is the holdout. For federally assisted housing and other HUD-funded facilities, UFAS remains a compliance option. Since May 2014, HUD has also allowed recipients to use the 2010 ADA Standards for Accessible Design, with roughly 11 HUD-specific modifications, as an alternative.² So a HUD-funded project can choose between UFAS and the modified 2010 ADA Standards. UFAS itself has not been updated since 1984, which is why designers often compare the two options before committing. Switching standards partway through design is expensive.

Who Has to Comply

UFAS compliance obligations fall on any entity that receives HUD financial assistance for construction or alterations. Under 24 CFR Part 8, that includes state and local government agencies, public housing authorities, private developers, and nonprofit organizations that accept HUD grants, loans, or other federal funding.³ A local housing authority building apartments with HUD dollars, or a private developer partnering with HUD on affordable housing, is on the hook.

Federal agencies that lease private space also have to ensure accessibility in what they rent. GSA’s Federal Management Regulation requires all new leases to meet accessibility standards, with limited exceptions for emergency disaster-response leases and short-term leases of 12 months or less that cannot be renewed.⁴ Leased federal space now falls under ABAAS rather than UFAS, but the underlying principle carries: renting is not a way around the rules.

Noncompliance is not a paperwork issue. HUD can suspend or terminate federal financial assistance, refuse future grants, refer the matter to the Department of Justice, or start debarment proceedings that block an entity from future federal contracts.³

What Construction Activities Trigger UFAS

UFAS covers all new construction and any additions to existing structures built with applicable federal funds. Smaller alterations must also comply if they affect the usability of the facility. The most important trigger to understand is the “substantial alteration” rule: when total renovation costs within any 12-month period reach 50 percent or more of the building’s full and fair cash value, the entire building must be brought up to current accessibility standards, not just the renovated portion.⁵

“Full and fair cash value” for that 50 percent calculation can be determined three ways: the assessed valuation equalized at 100 percent, the replacement cost, or the fair market value.⁵ The chosen method can decide whether a renovation crosses the threshold. A building assessed well below market value might stay under the line by assessed valuation but blow past it under replacement cost. Get the math wrong and an entire building can end up out of compliance.

Covered facilities range widely: federally funded public housing, community centers, post offices, military installations, and residential complexes. Projects under GSA, DOD, or USPS use the same general scoping framework, but under ABAAS.

Core Technical Requirements

UFAS sets hard numeric requirements that inspectors measure during compliance reviews. These are the specifications that come up most often in design review.

Circulation, Doors, and Ramps

Accessible routes must maintain a minimum clear width of 36 inches continuously, though doorways may narrow to 32 inches measured with the door open to 90 degrees. Ramps cannot exceed a slope of 1:12, meaning 12 inches of run for every inch of rise. Multi-story buildings need at least one passenger elevator with enough floor space for a wheelchair user to enter, turn, and reach the controls. Floor buttons cannot be mounted higher than 48 inches above the floor, or 54 inches if the lower height would cause a substantial increase in cost.⁵

Objects protruding from walls are regulated for people with visual impairments. Anything mounted between 27 and 80 inches above the floor cannot stick out more than 4 inches into corridors or walkways.⁵ Minimum headroom clearance along circulation paths is 80 inches, and where clearance drops below that, fixed barriers with leading edges no higher than 27 inches must be installed so a person using a cane can detect the hazard.⁶

Restrooms

A clear floor space of at least 30 by 48 inches is required at each fixture so a wheelchair user can approach and use the sink or toilet. Grab bars must withstand 250 pounds of force without the bending stress exceeding the allowable stress for the bar’s material. Their exact positioning is governed by detailed diagrams in the standard, so designers need to consult the specific figures rather than rely on a general height. Floor surfaces throughout restrooms must be stable, firm, and slip-resistant.⁵

Signage

Interior signs identifying rooms and spaces must include both raised characters and Grade 2 braille. Tactile characters must be uppercase, sans serif, and raised at least 1/32 of an inch. Character height ranges from 5/8 inch minimum to 2 inches maximum. Signs are mounted so the lowest tactile character sits at least 48 inches above the floor and the highest sits no more than 60 inches above the floor, with an 18-by-18-inch clear floor space centered on the characters.⁷ Signs at doors go on the latch side and must sit outside the arc of the door swing.

Parking, Curb Ramps, and Entrances

The number of accessible parking spaces scales with lot capacity, and at least one of every six accessible spaces must be van-accessible, with an access aisle at least 96 inches wide to accommodate wheelchair lifts.⁸ Accessible spaces must connect to the building via the shortest accessible route.

Where an accessible route crosses a curb, a curb ramp is required. Under UFAS the ramp slope follows the same 1:12 maximum as interior ramps, with a minimum width of 36 inches not counting flared sides. Flared sides top out at a 1:10 slope where pedestrians might cross, dropping to 1:12 where the area beside the ramp is narrower than 48 inches.⁵

At least one principal entrance at each grade floor level must be fully accessible. When a building has entrances serving specific functions such as transportation facilities, passenger loading zones, or accessible parking, at least one entrance serving each function must also be accessible. A service entrance cannot be the only accessible entrance unless it is the building’s sole entrance. Door hardware at accessible entrances must be operable with one hand and cannot require tight grasping or twisting of the wrist.⁵

Exceptions and Waivers

Not every building or feature must meet every UFAS requirement. The standards carve out specific exceptions, and the Architectural Barriers Act allows the four standard-setting agencies to grant waivers on a case-by-case basis when compliance is “clearly” not feasible.¹

Under HUD’s regulations, recipients are not required to make alterations that have little likelihood of being accomplished without removing or altering a load-bearing structural member.² This structural impracticability exception is narrow. It applies only to the specific element that would require structural demolition, not to all other feasible accessibility improvements on the project.

UFAS Section 4.1.4(2) exempts certain military facilities designed exclusively for able-bodied personnel, including unaccompanied personnel housing, closed messes, and vehicle or aircraft maintenance facilities where all work is performed by able-bodied service members.⁵ Portions of Reserve and National Guard facilities used primarily by able-bodied personnel fall under the same exemption. Any portion open to the public, used during normal business hours by the public, or used by employees with disabilities must still be accessible.

Buildings listed on or eligible for the National Register of Historic Places do not get a blanket exemption. Before altering a qualified historic building, the project must obtain comments from the Advisory Council on Historic Preservation when required under Section 106 of the National Historic Preservation Act. The Advisory Council decides case by case whether specific accessibility features would threaten historic significance. Where standard requirements would damage historic integrity, modified provisions apply. A ramp slope as steep as 1:6 may be allowed for runs of 2 feet or less at an entrance. If no public entrance can be made accessible, access can be provided through a non-public entrance kept unlocked, with directional signs at the main door. A single unisex accessible restroom can satisfy restroom requirements, and horizontal displays should be positioned no higher than 44 inches above the floor.⁵

Filing a Complaint About a Federal Building

The U.S. Access Board enforces the Architectural Barriers Act and handles complaints about inaccessible federal buildings. Barriers at facilities covered by the ABA (federal office buildings, post offices, VA medical facilities, national parks, Social Security offices, courthouses, and federal prisons) can be reported directly to the Access Board.⁹

Complaints can be submitted through the online ABA Complaint Form, by email to enforce@access-board.gov, by fax to 202-272-0081, or by mail to the Access Board at 1331 F Street NW, Suite 1000, Washington, DC 20004. Phone complaints are not accepted, though callers who cannot file electronically due to a disability may call 202-272-0050 for assistance.⁹

Once filed, the Access Board must resolve the complaint within 180 days. The process starts with a preliminary analysis to confirm the facility is covered by the ABA, then moves to investigation and fact-finding by the responsible agency. That agency produces a response with findings and a corrective action plan that includes milestones. After the Access Board reviews the response, the complainant has 15 days to raise any outstanding issues before the case is closed.¹⁰

Concerns about a state or local government building, or a private business like a restaurant or hotel, do not go through the ABA process. Those facilities fall under the Americans with Disabilities Act, and complaints go to the Department of Justice through its Civil Rights Reporting Portal.⁹

How UFAS Interacts With the ADA

The Architectural Barriers Act and the Americans with Disabilities Act are separate laws with different scopes. The ABA covers buildings built, altered, or leased with federal funds. The ADA covers state and local government facilities under Title II and private businesses open to the public under Title III. A building can be subject to both laws if it receives federal funding and also operates as a place of public accommodation.

When both laws apply to the same project, the more stringent requirement controls. The Federal Register has stated that a property subject to multiple accessibility laws “must be designed and built in accordance with the accessibility requirements of each law,” and where requirements for the same feature differ, the law imposing greater accessibility must be met for both scoping and technical specifications.¹¹

For a HUD-funded project, the practical choice is between UFAS and the 2010 ADA Standards with HUD modifications. Because UFAS is less detailed than the 2010 ADA Standards in some areas, that choice deserves attention early in design. Departures from specific UFAS technical requirements are permitted where the alternative method provides substantially equivalent or greater access.²

1
U.S. Access Board. ABA Standards
2
eCFR. 24 CFR 8.32 – Accessibility Standards
3
eCFR. 24 CFR Part 8 – Nondiscrimination Based on Handicap in Federally Assisted Programs and Activities of the Department of Housing and Urban Development
4
U.S. General Services Administration. Accessible Facility Design
5
U.S. Access Board. Uniform Federal Accessibility Standards
6
U.S. Access Board. Chapter 3: Protruding Objects
7
U.S. Access Board. Chapter 7: Signs
8
U.S. Access Board. ADA Accessibility Standards – Chapter 5: Parking
9
U.S. Access Board. File an Architectural Barriers Act Complaint
10
U.S. General Services Administration. National Accessibility Program Standards, Policies and Procedures
11
Federal Register. Fair Housing Act Design and Construction Requirements; Adoption of Additional Safe Harbors