HUD notice FR-5784-N-01 (May 23, 2014)
GCHS staff work under UFAS every day, but almost every other accessibility reference in circulation, code books, design guides, other agencies' requirements, is written to the 2010 ADA Standards for Accessible Design or its ABA counterpart. HUD lets recipients use the 2010 ADA Standards as an alternative to UFAS, but only with a specific list of exceptions attached. Mixing up which standard applies, or assuming the 2010 ADA Standards can be used without HUD's exceptions, is one of the easiest ways for a HUD-funded rehab project to end up out of compliance without anyone noticing until an inspection.
Lesson 1 covered why UFAS, published in the Federal Register on August 7, 1984, is still HUD's standard under 24 CFR 8.32: conformance with sections 3 through 8 of UFAS "shall be deemed to comply" with HUD's design, construction, and alteration requirements in 24 CFR 8.21, 8.22, 8.23, and 8.25. The 2010 ADA Standards are a separate document, published by the Department of Justice, that took effect for most private and state and local government facilities in March 2012. HUD did not adopt the 2010 ADA Standards as its primary standard. Instead, HUD created a narrower path: a recipient may choose to use the 2010 ADA Standards on a HUD-assisted project instead of UFAS, but only if it also follows a list of HUD-specific exceptions that keep certain UFAS-level protections in place.
That path was set out in a Federal Register notice, "Instructions for Use of Alternative Accessibility Standard," docket FR-5784-N-01, published May 23, 2014. The notice does not repeal or replace UFAS. It gives HUD recipients the option to design, construct, or alter a covered facility to the 2010 ADA Standards instead of UFAS, on the condition that the project also complies with the exceptions the notice lists. A recipient cannot pick and choose individual 2010 ADA provisions while ignoring the rest of the standard, and it cannot use a 2010 ADA exception that HUD's notice has switched off. The choice is between UFAS in full, or the 2010 ADA Standards in full, with HUD's exceptions layered on top of the latter.
The May 23, 2014 notice lists exceptions that keep the 2010 ADA Standards from weakening protections UFAS already provides. A recipient using the 2010 ADA Standards instead of UFAS cannot rely on: the 2010 ADA's structural-impracticability exception for unique terrain; the 2010 ADA's own alteration-scoping language, in place of HUD's "substantial alterations" and "other alterations" definitions in the Section 504 regulation; the 2010 ADA's addition-scoping section in place of HUD's own rules for additions, including UFAS 4.1.5; the 2010 ADA's exemption of residential dwelling units from accessible-route obligations when altering a space that affects a primary function; the 2010 ADA's exemption of common use areas that do not serve dwelling units with required mobility features from accessibility and route obligations; the 2010 ADA's exceptions letting site arrival points, or routes between site elements, go unserved wherever the only connection is a vehicular way; the 2010 ADA's limits on accessibility in employee work areas; the 2010 ADA's exemption of private buildings under three stories from elevator requirements; and the 2010 ADA's narrower visible-alarm trigger, which would otherwise require visible alarms only when a fire alarm system is newly installed or upgraded. One more exception is narrow and technical rather than scoping-related: HUD recipients using the 2010 ADA alternative must still follow UFAS 4.34.7 for common-use washing machines and clothes dryers, covered below, rather than the 2010 ADA's own laundry-equipment section.
Even where the two standards cover the same feature, the numbers are not always the same, and GCHS should never assume a 2010 ADA dimension can stand in for a UFAS one. Side reach is a clear example. UFAS 4.2.6 sets the maximum high side reach, for a person using a wheelchair with an unobstructed parallel approach, at 54 inches, with a minimum low side reach of 9 inches above the floor. The 2010 ADA Standards, Section 308.3.1, set the same unobstructed high side reach at 48 inches maximum, with a minimum low side reach of 15 inches. That is a real difference on both ends of the range, not a rounding difference, and it changes where a light switch, thermostat, or shelf can sit depending on which standard governs the job. Forward reach is not affected the same way: both UFAS 4.2.5 and the 2010 ADA Standards cap unobstructed high forward reach at 48 inches and allow a reduced 44-inch maximum when the reach is over an obstruction 20 to 25 inches deep, so that figure carries over unchanged between the two standards. (UFAS draws the 44-inch value in Figure 5(b); the 2010 ADA Standards state it in Section 308.2.2.)
UFAS 4.34.7.2 requires that washing machines and clothes dryers in common-use laundry rooms be front loading. The 2010 ADA Standards, Section 611, allow either type: a top-loading machine with its laundry-compartment door no higher than 36 inches above the floor, or a front-loading machine with its opening between 15 and 36 inches above the floor. This is one of the exceptions HUD's 2014 notice calls out by name: a recipient using the 2010 ADA Standards instead of UFAS must still follow UFAS 4.34.7 for common-use laundry equipment, so a top-loading washer that would satisfy the 2010 ADA Standards on its own does not satisfy a HUD-funded project's common-use laundry room under either standard.
Not every number differs, and GCHS should not assume a difference exists where the standards actually agree. The 60-inch circular or T-shaped turning space, the 1:12 maximum ramp slope for new construction (both standards allow steeper slopes in existing buildings within set limits), and the 60-inch by 56-inch (wall-hung) or 59-inch (floor-mounted) standard accessible toilet compartment size are the same in UFAS and the 2010 ADA Standards. UFAS states the 56-inch depth in the text of 4.17.3 and draws the 60-inch width in Figure 30(a). When in doubt about a specific dimension, verify it directly in the applicable standard rather than assuming either agreement or difference.
HUD has been examining whether to update its Section 504 regulations and accessibility standard for several years, and the official notices checked for this course, as of September 2026, show no new standard adopted and UFAS not replaced. HUD published an Advance Notice of Proposed Rulemaking, "Nondiscrimination on the Basis of Disability: Updates to HUD's Section 504 Regulations," on April 25, 2023, with a public comment period that closed July 24, 2023. That notice sought input on possible changes, including whether HUD should adopt an updated accessibility standard in place of UFAS; it did not itself change anything. No Notice of Proposed Rulemaking or final rule updating 24 CFR Part 8 or the accessibility standard turned up in those sources, so confirm the current status in the Federal Register before relying on this. Until HUD issues and finalizes a further rule, UFAS remains the governing standard under 24 CFR 8.32, and the May 23, 2014 notice remains the only route to using the 2010 ADA Standards instead, with its exceptions intact.
| Item | UFAS | 2010 ADA Standards |
|---|---|---|
| High side reach, unobstructed (4.2.6 / 308.3.1) | 54 in. max | 48 in. max |
| Low side reach, unobstructed (4.2.6 / 308.3.1) | 9 in. min | 15 in. min |
| High forward reach, unobstructed (4.2.5 / 308.2.1) | 48 in. max | 48 in. max |
| Common-use laundry equipment (4.34.7.2 / 611) | Front-loading required | Front- or top-loading permitted |
| Elevator exemption, private buildings under 3 stories | Not part of UFAS | Available in 2010 ADA, but not usable by HUD recipients under the 2014 notice |
In practice, most GCHS single-family rehab work is not a candidate for the 2010 ADA alternative in the first place, since the notice is aimed at recipients who want to design and build to the more familiar 2010 ADA Standards on larger or multifamily projects. When a project team is considering that alternative, GCHS's role is to confirm two things before signing off: that the project will follow the complete 2010 ADA Standards rather than a mix of the two documents, and that every exception in HUD's 2014 notice is being honored on top of it, especially the ones most likely to get missed in the field, the elevator exemption, the visible-alarm trigger, and the front-loading laundry requirement. When UFAS alone is being used, as it is on the great majority of GCHS's HUD-funded work, none of this applies, and the UFAS numbers in Lessons 3 through 8 govern directly.
Why this matters for GCHS
Almost every accessibility reference a GCHS staffer finds online, in a manufacturer spec sheet, or in a general contractor's own checklist, is written to the 2010 ADA Standards, not UFAS. A 48-inch side reach maximum copied from one of those sources into a UFAS-governed HUD project would actually be more restrictive than UFAS requires at both ends of the range (48 inches against 54 for the high reach, 15 against 9 for the low reach) and could mean rejecting a perfectly compliant 54-inch installation, or worse, approving a top-loading washer in a common laundry room that UFAS 4.34.7 does not allow. Knowing exactly where the two standards match and where they do not is what keeps a HUD-funded rehab project compliant with the standard HUD is actually going to apply.
1. Under UFAS 4.2.6, what is the maximum height for an unobstructed high side reach?
2. Under the 2010 ADA Standards, Section 308.3.1, what is the maximum height for an unobstructed high side reach?
3. Under UFAS 4.2.6, what is the minimum height for a low side reach?
4. Under the 2010 ADA Standards, Section 308.3.1, what is the minimum height for a low side reach?
5. For unobstructed high forward reach, how does UFAS 4.2.5 compare to the 2010 ADA Standards?
6. What does UFAS 4.34.7.2 require for washing machines and clothes dryers in a common-use laundry room?
7. What does Section 611 of the 2010 ADA Standards allow that UFAS does not?
8. What is the title and docket number of HUD's May 23, 2014 Federal Register notice on using the 2010 ADA Standards instead of UFAS?
9. A GCHS-funded rehab of a two-story private multifamily building elects the 2010 ADA Standards under HUD's 2014 notice. Can the project skip installing an elevator by citing the 2010 ADA's exemption for private buildings under three stories?
10. A HUD-funded project electing the 2010 ADA Standards is only replacing some existing smoke detectors, not installing a whole new fire alarm system. Can it use the 2010 ADA's exception limiting visible alarms to newly installed or upgraded systems?
11. When a HUD recipient elects the 2010 ADA Standards instead of UFAS, which definitions govern "substantial alterations" and "other alterations" on a multifamily housing project?
12. As of September 2026, has HUD finalized a new accessibility standard to replace UFAS?
13. A GCHS project elects the 2010 ADA Standards for a HUD-funded multifamily rehab and installs a top-loading washer in the common laundry room, meeting Section 611's 36-inch door-height limit. Is the common laundry room compliant?
14. A GCHS design drawing sets a light switch at 48 inches above the floor with an unobstructed parallel (side) approach, on a project governed by UFAS alone. Does that placement meet UFAS 4.2.6?