Los Angeles . Washington D.C.
BUILDING                                      528 STATE STREET
ANALYTICS                                     GLENDALE, CALIFORNIA 91203
Building/Environmental Evaluations            (818) 500-1898
                                              (818) 246-8195 FAX
June 23, 1992

Office of Americans with Disabilities Act                   File No.: 92115
Civil Rights Division
U.S. Department of Justice
Post Office Box 66118
Washington, D.C. 20035-6118

Reference:   Request for clarification on specific requirements of
             the Americans with Disabilities Act
Dear Sirs:

The Los Angeles office of Building Analytics has contracted with the 
California State University system to prepare a Transition Plan for all 
campus facilities in accordance with the Americans with Disabilities Act. It 
is our understanding of the ADA regulations that under Title II, public 
entities such as the state university system should utilize the UFAS 
regulations to identify the existence of architectural barriers. Corrective 
work to undertaken to remove barriers should follow either the UFAS 
regulations or Title 24, the California State Building Code whichever is 
most stringent. Please advise if our understanding of the regulations is 
correct.

In addition, our understanding of the subparagraph section 4.1.6 Accessible 
Buildings: Alterations, is that if the building was constructed before 1984, 
and meets the requirements of ANSI 1961/1971, than no corrective action 
would be required to make the building accessible. However, if the building 
did not comply with the requirements of the ANSI Standard, then corrective 
action should be undertaken to comply with the requirements of UFAS. If the 
building was constructed after 1984, and meets the requirements of UFAS, 
than no corrective action would be required. However, if the building did 
not comply with the requirements of UFAS corrective would be required at the 
current time to comply. 
Again,
any corrective action would have to comply with Title 24 of the California 
Administrative Code in addition to UFAS, whichever is more stringent.

Please advise if our understanding of the intent of the regulations is 
correct.

Sincerely,
BUILDING ANALYTICS

(Signature)
Richard Buchanan, AIA
Vice President

cc: Legal Department, California State University System   (Stamp)Jul 8, 1992  
    Long Beach, California                           (handwritten)202-PL-232   
        
102338