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Is the Oasis / MAX lavatory Air Carrier Access Act / ACA compliant?

Is the Oasis / MAX lavatory Air Carrier Access Act / ACA compliant?

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Old Apr 10, 21, 6:04 am   -   Wikipost
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The new 737 MAX 8 is equipped with new Rockwell Collins Interior Design “advanced“ ultra slimline lavatories (29” in F, 24” in Y) (link). Under Project Oasis, 737-823 and two class Airbus A321 aircraft will be refitted with these lavatories and the Rockwell Collins Meridian ultra slimline seats.


Airlines must comply with the Air Carrier Access Act (not the Americans with Disabilities Act), which states single aisle aircraft are not required to have ACAA compliant accessible lavatories.

CFR › Title 14 › Chapter II › Subchapter D › Part 382 › Subpart E › Section 382.63 (link)

§ 382.63 What are the requirements for accessible lavatories?
(a) As a carrier, you must ensure that aircraft with more than one aisle in which lavatories are provided shall include at least one accessible lavatory.

(1) The accessible lavatory must permit a qualified individual with a disability to enter, maneuver within as necessary to use all lavatory facilities, and leave, by means of the aircraft's on-board wheelchair.

(2) The accessible lavatory must afford privacy to persons using the on-board wheelchair equivalent to that afforded ambulatory users.

(3) The lavatory shall provide door locks, accessible call buttons, grab bars, faucets and other controls, and dispensers usable by qualified individuals with a disability, including wheelchair users and persons with manual impairments.

(b) With respect to aircraft with only one aisle in which lavatories are provided, you may, but are not required to, provide an accessible lavatory.
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Old Jul 10, 18, 6:16 pm
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Is the Oasis / MAX lavatory Air Carrier Access Act / ACA compliant?

Hi-

Hearing that they are only 24 inches wide got me thinking this must be a violation of the (American's With Disabilities Act?) I'm pretty sure the standard width for a door is 30 inches in a public or commercial building. I don't see how airplanes can be exempted since disabled people fly all the time and are allowed to board sometimes before anyone else.

I'm hoping a law-suit gets the bathroom size back to more usable standards for all of us. I'm not Disabled but I'm 6' 5" and 290lbs. When sitting down my hips are about 23 inches wide! I'm going to have to make sure to never fly on one of these awful planes.

-Paul

Last edited by JDiver; Jul 10, 18 at 6:43 pm Reason: Restore original post title
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Old Jul 10, 18, 6:26 pm
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https://www.law.cornell.edu/cfr/text/14/382.63
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Last edited by JDiver; Jul 10, 18 at 6:44 pm Reason: Activate link
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Old Jul 10, 18, 6:31 pm
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The Air Carrier Access Sct applies, not ADA.

I assume they are compliant. They likely would not have gotten designed, certified and installed otherwise.
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Old Jul 10, 18, 6:39 pm
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It’s a single aisle so there doesn’t need to be an accessible lav. 382.63(b)
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Old Jul 10, 18, 8:10 pm
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Originally Posted by Paul510 View Post
I'm pretty sure the standard width for a door is 30 inches in a public or commercial building. I don't see how airplanes can be exempted
Hint - an airplane is not a public or commercial building.

In general, it's a pretty good guess that any commercial aircraft that has been through the extremely rigorous certification process actually meets the certification requirements.
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Old Jul 10, 18, 8:42 pm
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Originally Posted by CPRich View Post
Hint - an airplane is not a public or commercial building.

In general, it's a pretty good guess that any commercial aircraft that has been through the extremely rigorous certification process actually meets the certification requirements.
https://www.transportation.gov/acces...sory-committee


<redacted> it seems the DOT and the ACCESS Advisory Committee has to an agreement on bathroom standards for single aisle aircraft with more than 125 seats. <redacted>the ground based standard for a doorway is 32 inches, so I would expect some new rule where at least one bathroom door has to be at least 32 inches wide.

-Paul

Last edited by JDiver; Jul 11, 18 at 12:06 am Reason: Redacted ad hominem
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Old Jul 10, 18, 9:00 pm
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Originally Posted by Paul510 View Post
https://www.transportation.gov/acces...sory-committee


<redacted> it seems the DOT and the ACCESS Advisory Committee has to an agreement on bathroom standards for single aisle aircraft with more than 125 seats. <redacted> the ground based standard for a doorway is 32 inches, so I would expect some new rule where at least one bathroom door has to be at least 32 inches wide.

-Paul
Hint: it's pretty hard for an aircraft to be held responsible for certification to a potential future rule which doesn't exist now and might possibly exist at some unspecified time in the future.

In the meantime it's a pretty safe bet that, given the extensive regulatory and certification process that commercial airlines are subject to in the US, AA isn't flying around with illegal lavs.
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Last edited by JDiver; Jul 11, 18 at 12:07 am Reason: Edited out previously deleted post content
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Old Jul 10, 18, 9:01 pm
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Originally Posted by Paul510 View Post
https://www.transportation.gov/acces...sory-committee


<redacted> it seems the DOT and the ACCESS Advisory Committee has to an agreement on bathroom standards for single aisle aircraft with more than 125 seats. <redacted> the ground based standard for a doorway is 32 inches, so I would expect some new rule where at least one bathroom door has to be at least 32 inches wide.

-Paul
Sure but this would be for future rule making only. Any currently certified configuration would continue to be certified forever as long as nothing changed. This is just an industry group recommendation we will see what actually gets adopted.

Last edited by JDiver; Jul 11, 18 at 12:08 am Reason: Edited out previously deleted post content
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Old Jul 11, 18, 12:11 am
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Old Jul 11, 18, 6:59 am
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Whatever the minimum legal requirements, it is a shame that, when ordering new equipment, AA hasn't aspired to meeting the foreseeable needs of passengers with disabilities.
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Old Jul 11, 18, 7:52 am
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There's still a (slightly) larger lav in front of F. Since AA does not have a policy strictly against Y pax using the F lav, any special needs pax (disability or oversized person) could use the forward lav.
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Old Jul 11, 18, 1:24 pm
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Originally Posted by econometrics View Post
There's still a (slightly) larger lav in front of F. Since AA does not have a policy strictly against Y pax using the F lav, any special needs pax (disability or oversized person) could use the forward lav.
That's my backup plan if I get equipment swapped onto something with the "Oasis" config. Which for now is fairly easy to avoid.
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Old Jul 11, 18, 5:28 pm
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Originally Posted by jlsw7 View Post
Whatever the minimum legal requirements, it is a shame that, when ordering new equipment, AA hasn't aspired to meeting the foreseeable needs of passengers with disabilities.
“American Airlines” and “aspire” sometimes do not belong in the same sentence. AA has prioritized seat density on its narrowbodies aircraft going forward - in Economy, denser than on Southwest. Perhaps when the 7M8 and Project Oasis include most of the AA narrowbodies, it will bring about the passengers’ “Project Awaysis”?
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Old Jul 11, 18, 6:33 pm
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Originally Posted by jlsw7 View Post
Whatever the minimum legal requirements, it is a shame that, when ordering new equipment, AA hasn't aspired to meeting the foreseeable needs of passengers with disabilities.
AA thinks it's in an era where compliance alone is good enough for the people in back. AA configures Max 8s with 172 seats; there's a Max 8 version with additional exits that is certified for 200. Things can get much, much worse.

If there is a new lav size rule that goes into effect surely carriers will negotiate a generous transition period and then rip out a few seats where required. Until then...
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Old Jul 11, 18, 8:52 pm
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If you look inside an AA MAX 8, there is not much differentiating it from the inside of a Spirit/Frontier/Allegiant aircraft. In fact, service might be better on the latter as well.
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