DA DB-SUA / 2 – Effective Accessibility Adaptation in Existing Buildings
The DA DB-SUA / 2 is a Supporting Document (Documento de Apoyo) issued by the Ministerio de Fomento through the Dirección General de Arquitectura, Vivienda y Suelo in Spain. It serves as a technical supplement to the Código Técnico de la Edificación (CTE), specifically supporting the Basic Document on Safety of Utilization and Accessibility (DB-SUA). The edition dated June 29, 2018, updates and replaces previous versions to provide criteria for the effective adaptation of existing buildings and establishments to the basic conditions of accessibility and non-discrimination for persons with disabilities.
This regulatory framework applies to buildings whose building permit application was submitted prior to September 12, 2010. For these structures, the document defines Criterios de flexibilidad (flexibility criteria) and Tolerancias admisibles (admissible tolerances) that may be applied when full compliance with new construction standards is technically or economically unviable. The scope encompasses various architectural elements, including Itinerarios accesibles (accessible routes), ramps, stairs, lifts, and Servicios higiénicos accesibles (accessible toilets), as well as specific annexes for mechanical elevation devices and collective housing elevators.
The document categorizes requirements into basic conditions that must be maintained and specific tolerances that allow for deviations in existing contexts. It emphasizes the responsibility of the project designer to justify the necessity of these flexibilities based on urban, technical, or economic constraints, or when interventions conflict with the protected status of a building.
Application Criteria and Justification
The criteria established in this document are intended for buildings that cannot strictly meet the requirements of DB SUA and DB SI. Application of these flexibilities is permitted when the designer justifies that reaching full compliance is not viable due to specific constraints:
- Technical or Economic Viability: Cases where the cost or technical complexity exceeds reasonable limits.
- Building Protection: Situations where adaptations are incompatible with the nature of the intervention or the building's protected status.
- Alternative Solutions: Use of management-based solutions or support products when structural changes are impossible.
Admissible Tolerances for Accessible Routes
Table 2 of the document specifies the limits within which the current state of an existing building is considered admissible. These tolerances apply to specific elements of the Itinerario accesible:
- Ramps: Slopes up to 12% are permitted for lengths up to 3 m, and 10% for lengths up to 10 m.
- Passage Width: A minimum clear width of 0.90 m is allowed in straight sections and between handrails.
- Turning Circles: Where a 1.50 m diameter circle is standard, a minimum of 1.20 m is accepted in existing buildings, provided they are free of obstacles.
- Level Changes: Small differences up to 5 cm in access points are admissible if the slope does not exceed 25%.
Vertical Mobility and Elevator Installation
Annex B details solutions for integrating elevators into existing collective housing. It outlines several intervention types based on legal and structural feasibility:
- Interior Common Areas: Installation within stairwells or landings.
- Interior Courtyards: Utilizing light wells (patios de luces), subject to administrative authorization.
- Facades: Placing elevators on the building exterior, which may involve occupation of public domain.
- Private Areas: Installation within private terraces or courtyards, requiring owner agreement or expropriation procedures.
Cabin dimensions for users in wheelchairs are standardized. For elevators with adjacent doors, a minimum of 125 x 125 cm or 120 x 140 cm is required. For opposite or single doors, 100 x 125 cm is the minimum for a Type A manual wheelchair without an attendant.
Hygienic Services and Toilets
Annex C provides criteria for Servicios higiénicos accesibles in small premises or where structural modifications are restricted:
- Reduced Dimensions: Establishments with less than 100 m² of public use area and occupancy under 50 people may share accessible toilets between sexes.
- Manoeuvring Space: A diameter of 1.20 m is permitted if 1.50 m is impossible. This space can include the area under a washbasin up to 20 cm deep if it lacks a pedestal.
- Transfer Space: If space for lateral transfer on both sides is unavailable, transfer on a single side is permitted if properly signed.
Frequently Asked Questions
Which buildings are considered 'existing' under DA DB-SUA / 2?
Buildings and establishments whose building permit application was submitted before September 12, 2010.
What is the maximum admissible slope for a 3-meter ramp in an existing building?
According to the admissible tolerances, a maximum slope of 12% is permitted for ramp sections up to 3 meters in length.
Is an accessible toilet mandatory for staff in private areas?
It is not required if the private area for workers does not exceed 100 m² and the number of workers is 10 or fewer.
What are the minimum dimensions for an elevator cabin in an existing building?
For a single door or opposite doors, the minimum dimensions are 100 x 125 cm to accommodate a Type A manual wheelchair.
Can a platform lift be used as a primary accessibility solution?
A vertical elevating platform is considered the first alternative option when a level route or ramp is technically or economically unviable.
What is the minimum permitted stair width when installing an elevator?
Stair width can be reduced to 0.80 m for evacuation purposes, provided compensatory measures are adopted.
Are mobile ramps or stair-climbing mats considered accessible solutions?
No, mobile ramps and mobile mats are not considered part of an accessible route under this regulation.
What is the minimum width for a corridor in an existing building?
A minimum width of 0.90 m is considered sufficient for straight-line circulation and turns up to 90 degrees in private use or small establishments.
