The Architectural and Transportation Barriers Compliance Board, commonly known as the Access Board, published an Advance Notice of Proposed Rulemaking (ANPRM) in the Federal Register on February 18, 2026. This document initiates the process of developing accessible design standards for universal changing tables and the rooms housing them in medium and large hub airports. Mandated by the FAA Reauthorization Act of 2024, the standards aim to ensure privacy, accessibility, and sanitation for individuals with disabilities who require assistance with personal care. The ANPRM seeks public comments by April 20, 2026, to inform a future proposed rule. This development addresses a critical gap in airport infrastructure, promoting dignity and safety for travelers with disabilities and their caregivers, while aligning with broader federal accessibility goals.
Background and Legal Mandate
The FAA Reauthorization Act of 2024, codified at 49 U.S.C. 47107(y), directs the Access Board to create comprehensive standards for universal changing tables and the privacy, accessibility, and sanitation features of their enclosing rooms. Starting in fiscal year 2030, medium and large hub airports applying for airport development project grants must assure the installation or maintenance of at least one private single room with a universal changing station per passenger terminal. As the ANPRM notes, 'these standards are to be used by sponsors of medium and large hub airports that are seeking airport development project grants.' This requirement does not extend to other locations, and the Access Board emphasizes that its forthcoming rulemaking will focus solely on technical standards, not on expanding the scope beyond what the statute specifies.
The Access Board, an independent federal agency established under the Rehabilitation Act of 1973, develops accessibility guidelines that form the basis for standards under laws like the Americans with Disabilities Act (ADA) and the Architectural Barriers Act (ABA). Key players include the Board's staff, such as Josh Schorr for technical information and Wendy Marshall for legal details, as well as stakeholders like disability advocates, manufacturers, and airport operators. The Act reflects growing recognition of accessibility needs, building on advocacy from groups highlighting the indignity and risks of lacking such facilities, such as individuals being changed on bathroom floors.
Understanding Universal Changing Tables
Universal changing tables, also called adult changing tables, are designed for individuals with disabilities who need caregiver assistance for toileting tasks, such as changing incontinence garments, colostomy bags, or catheters. These tables serve a diverse group, including wheelchair users, older adults, and people with developmental disabilities. As the ANPRM explains, they are 'larger and sturdier than baby changing stations and are designed to promote dignity and privacy.' Without them, users often resort to unsanitary and unsafe alternatives, risking injury to both individuals and caregivers. The document underscores the tables' role in providing 'a safer and easier way for caregivers to provide assistance with toileting and dressing.' This focus aligns with federal priorities on inclusive design, though the ANPRM does not reference specific case law, it echoes principles from ADA precedents like Olmstead v. L.C. (1999), which emphasized community integration and dignity for people with disabilities.
Existing Standards and Their Relevance
The ANPRM reviews federal and industry standards that could inform the new rules. Federally, the ADA and ABA Accessibility Guidelines (36 CFR part 1191), last updated in 2004, address toilet rooms, compartments, sinks, and work surfaces but lack specific provisions for adult changing tables. These guidelines, enforced by agencies like the Department of Justice and Department of Transportation, would apply to airport toilet rooms under Title II of the ADA for state and local facilities.
On the industry side, Section 613 of the ICC A117.1-2017 with Supplement 1, an American National Standard approved by ANSI and incorporated into the 2024 International Building Code, provides detailed criteria for universal changing tables. Developed by a working group including Access Board representatives, disability advocates, and manufacturers, this standard emerged from a nine-month process reviewing state laws and caregiver input. It specifies table features like size, weight capacity, height adjustability, maneuvering clearances, and side rails, as well as room elements. The ANPRM encourages public review of this publicly available standard, noting its balanced development through hearings and comments.
Perspectives vary: advocates praise the standard for addressing real-world needs, while some manufacturers highlight compliance costs. Politically, this builds on state-level initiatives in 12 U.S. states and one Canadian province, reflecting a grassroots push for accessibility that influenced the federal Act.
Proposed Approaches and Public Input
The Access Board outlines potential paths for standards on tables and rooms. For tables, it considers incorporating by reference Section 613.4 of ICC A117.1-2017 with Supplement 1, which covers surface criteria, possibly with modifications. Alternatively, it could derive new standards from ADA/ABA guidelines and the Medical Diagnostic Equipment Standards (36 CFR part 1195), potentially requiring continuous height adjustability from 17 to 38 inches to accommodate diverse users and caregivers. The ANPRM poses questions on height ranges, sanitation (e.g., non-porous surfaces), and market availability of adjustable tables.
For rooms, the Board leans toward using ADA/ABA guidelines for elements like doors, turning space, and sinks, requiring essentials for assisted toileting such as toilets, soap dispensers, and waste receptacles. It could reference ICC A117.1-2017 Section 613.2.1 or add privacy features like lockable doors. Questions seek input on necessary elements, sanitation equipment, and costs, including installation expenses and the number of affected airports (estimated based on grant applicants).
Short-term implications include public comments shaping the notice of proposed rulemaking, potentially leading to standards by 2030. Long-term, this could enhance airport inclusivity, reduce barriers for disabled travelers, and set precedents for other public spaces. Challenges include balancing costs—airports may face expenses for retrofitting terminals—against benefits like injury prevention. Different views emerge: disability groups emphasize equity, while operators focus on feasibility.
In summary, this ANPRM marks a foundational step toward mandated accessibility in airports. Potential next steps include analyzing comments, drafting a proposed rule, and further regulatory review. Ongoing debates may center on technical details, economic impacts, and integration with existing standards, highlighting the tension between innovation and uniformity in accessibility policy.
