# 147

III-7.3000
III-7.5105                              September 30, 1994


Mr. Gene Colin
Mr. Kermit Robinson
State of Washington
State Building Code Council
906 Columbia Street, SW
P.O. Box 48300
Olympia, Washington  98504-8300

Dear Mr. Colin and Mr. Robinson:

     This is in response to your letter regarding the application
of title III of the Americans with Disabilities Act (ADA) to
self-storage businesses that rent storage units to people who
wish to store personal goods.  

     The ADA authorizes the Department of Justice to provide
technical assistance to individuals and entities that have rights
or responsibilities under the Act.  Pursuant to that authority,
this letter provides informal guidance to assist you in
understanding the ADA.  However, this technical assistance does
not constitute a legal interpretation of the statute, and it is
not binding on the Department.

     Your letter asks whether, in newly constructed or altered
self-storage businesses, each individual storage locker or room
must be constructed to be accessible or whether only a certain
percentage may be accessible.  Self-storage areas may be covered
by several different ADA provisions, depending on their placement
and purpose.  For example, if each self-storage facility is an
independent building, then each separate facility will be covered
by 4.1.3 of the ADA Standards for Accessible Design (Standards). 
Therefore, each such facility must comply with all applicable
requirements of the ADA Standards, including the requirement to
provide an accessible entrance that is located on an accessible
route.

     On the other hand, if self-storage lockers are part of a
larger building, that building must provide accessible
entrance(s) to the building, accessible routes to the accessible
storage lockers, and other accessible elements addressed in
4.1.3 of the ADA Standards.  However, the storage lockers,
themselves, would not all be required to be accessible.  Rather,
under 4.1.3(12), at least one of each type or size of storage
facility must be accessible.  The requirements for accessibility
of such storage lockers will vary depending on the types of 
storage lockers provided.  If storage lockers are intended for
people to enter, the accessible locker will have to provide an
accessible entrance, accessible interior controls, and accessible
interior space, as well as accessible storage spaces.  If, on the
other hand, storage lockers are not intended for people to enter,
they need not provide an accessible entrance or accessible
interior space, but rather they must simply provide clear floor
space at the locker, accessible door opening and closing
mechanisms, and reachable storage space, as provided in 4.25 of
the ADA Standards.

     I hope that this information is helpful to you.


                                      Sincerely,

                                        

                                   John L. Wodatch
                                        Chief
                                Public Access Section