When Elevators Are Required Under the 2010 ADA Standards
- Corey Taylor
- 2 days ago
- 4 min read
2010 ADA Standards, Section 206.2.3
Understanding when elevators are required in buildings can be complex, but the 2010 ADA Standards provide clear guidance through specific rules and exceptions. This guide breaks down the requirements in straightforward terms with practical examples to help you determine when your facility needs an elevator.
The General Rule
At least one accessible route shall connect each story and mezzanine in multi-story buildings and facilities. This means elevators are typically required to connect different floors in multi-story buildings.
The Primary Exception: The "3 and 3,000" Rule
The most important exception to understand is found in Section 206.2.3, Exception 1 of the 2010 ADA Standards:
Elevators are NOT required in private buildings or facilities that are:
Less than three stories
OR
Have less than 3,000 square feet per story
This is an "either/or" rule - you only need to meet one of these conditions to qualify for the exemption.
Examples of Buildings That DON'T Need Elevators:
Two-story office building with 40,000 square feet per floor - No elevator required because it's less than three stories.
Four-story building with 2,900 square feet per floor - No elevator required because each floor is under 3,000 square feet.
Five-story building with floors under 3,000 square feet each - No elevator required because all floors are under 3,000 square feet.
Critical Exceptions: Buildings That ALWAYS Need Elevators
Even if a building qualifies for the general exemption, elevators are always required in these facility types:
1. Shopping Centers and Shopping Malls
Definition: A building housing five or more sales or rental establishments OR a series of buildings on a common site with five or more sales or rental establishments.
Example: A two-story shopping center with 40,000 square feet per floor requires an elevator, even though it's less than three stories.
2. Professional Office of a Health Care Provider
Definition: A location where a person or entity regulated by a State provides professional services related to physical or mental health.
Example: A three-story dental office building must have an elevator, regardless of floor size.
3. Public Transportation Terminals
Definition: Terminal, depot, or other station used for specified public transportation.
Example: A bus station requires an elevator regardless of size or number of stories.
4. Airport Passenger Terminals
Definition: Any area housing passenger services, including boarding, baggage claim, dining facilities, and other common areas.
Example: An airport terminal must have elevators no matter how small or how many stories.
Additional Exemptions for Specific Building Types
Two-Story Public Buildings
A two-story public building or facility doesn't need an elevator if one story has an occupant load of five or fewer persons and does not contain public use space.
Example: A municipal office building where the upper floor has only 3 employees and no public access areas.
Detention and Correctional Facilities
Elevators are not required if cells with mobility features, common use areas serving those cells, and all public use areas are on an accessible route.
Residential Facilities
Elevators are not required if residential dwelling units with mobility features, common use areas serving those units, and public use areas are on an accessible route.
Multi-Story Transient Lodging
Within guest rooms, elevators are not required if accessible spaces are on an accessible route and sleeping accommodations for two persons minimum are provided on a story served by an accessible route.
Air Traffic Control Towers
Elevators are not required to serve the cab and the floor immediately below the cab.
Qualified Historic Buildings
Special exceptions apply for alterations to qualified historic buildings.
Important Notes for Existing Buildings
For existing buildings constructed before the ADA, the requirements differ slightly. Readily achievable barrier removal is required, which means modifications that can be easily accomplished with little difficulty or expense. If installing an elevator would create an undue burden, alternative accommodations must be provided.
New Construction vs. Alterations
The elevator requirements apply to:
New construction starting after March 15, 2012
Alterations where accessibility improvements are being made
What Qualifies as a "Story"?
A story is occupiable space designed for human occupancy with means of egress, light, and ventilation. Basements designed for occupancy count as stories, but mezzanines do not count as separate stories.
Key Takeaways
The "3 and 3,000" rule is your starting point - buildings under 3 stories OR under 3,000 square feet per story generally don't need elevators.
Four building types always need elevators: shopping centers/malls, health care provider offices, public transportation terminals, and airport terminals.
All floors must be under 3,000 square feet to qualify for the size exemption - if even one floor exceeds 3,000 square feet, an elevator is required.
Single-story buildings never need elevators for vertical access.
When in doubt, consult the specific section 206.2.3 of the 2010 ADA Standards for your particular situation.
Remember: Even if your building is exempt from elevator requirements, all other ADA accessibility requirements still apply to each floor and space within your facility.
DISCLAIMER: The information provided in this post is for informational purposes only and does not constitute legal advice. Please consult a qualified attorney or consultant for advice tailored to your situation.
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