Department of Justice Response for Proposed Rulings for Fitness Equipment

Over the past years individuals with disabilities have expressed concerns about the inability to use exercise equipment and furniture in health clubs, fitness centers, public recreation centers, and other establishments that offer exercise facilities. In response to these concerns, the Department of Justice sought public input in January 2011 on issues relating to possible revisions of ADA regulations which would ensure the accessibility of related fitness equipment and furniture. The Department also sought background information for the regulatory assessment needed to revise the ADA regulations.

Beneficial Designs, in conjunction with the RERC on Recreation Technology (RecTech), is currently working on a standard for Universally Designed Fitness Equipment. A summary of the comments submitted to the Department of Justice (DOJ) for best practices are provided below:

The minimum required pieces of accessible equipment should include one of each of the following types of universally designed fitness equipment or a minimum of 10% of each type of equipment, whichever is greater:

  • Bicycle (recumbent  or upright)
  • Elliptical
  • Treadmill
  • Upper body ergometer
  • Upper body strength equipment, such as a pulley machine, lat pulldown, chest press, rear delt/pec fly, bicep curl, triceps extension, etc.
  • Lower body strength equipment, such as a pulley machine, leg extension/flexion, leg press, hip abduction/adduction, hip extension/flexion, etc.
  • Torso strength equipment, such as abdominal crunch, rotary torso, lower back, etc.

Universally designed fitness equipment allows for access to a greater population of users, including people with a range of disabilities and/or impairments including: mobility, vision, hearing, cognitive, and intellectual. For a piece of equipment to be accessible it would need to meet the specifications listed on the following pages.

Note that there is a draft standard being developed within the ASTM F08.30 Fitness Products Committee that contains specific criteria for all of the universal design principles listed below: ASTM WK19803 – New Specification for Additional Requirements for Universal Design of Fitness Equipment Optimization for Inclusive Use for Persons with Functional Limitations and Impairments.

Universally designed equipment is defined as having the following minimum universal design principles:

General (applies to all applicable equipment)


  • Easy access, egress, and transfer free of obstruction to get into and out of the correct start position
  • Multiple access points to get on/off equipment
  • Minimum step-on or step-over heights
  • Seats/sitting surfaces shall be sufficiently wide with enough depth to adequately support user with trunk instability
  • For seats used in conjunction with a back support, the front edge of the seat shall be slightly higher than the rear providing some rearward angle (dump)
  • Seat heights should be adjustable across an adequate range to accommodate different user sizes
  • Seated upper body equipment shall have a removable/movable seat that allows clearance for use with wheelchair or other mobility devices
  • Removable/movable seats shall have appropriate mechanisms, e.g., wheels or skids and handles or gripping surfaces, to enable the seat to move easily over different floor surfaces
  • All postural supports should be a non-porous material, padded, and slip resistant
  • Adjustment mechanisms required for set up shall be visible in a clear line of sight to the user when approaching the equipment and/or from the primary exercise position
  • Adjustment mechanisms required for set up shall not require the simultaneous use of two hands and avoid left/right bias, and not require fine finger control, excessive wrist rotation, tight grasp, or a pinch grip or high activation force
  • Adjustment mechanisms shall function in a controlled manner and not free fall when being adjusted
  • Detachable controls and adjustments shall be tethered
  • Static handles or other appropriate structural components shall be provided in proximity to sitting surfaces to assist with transfer
  • Intended gripping surface of all handles shall be a non-slip surface and have an ergonomic gripping diameter
  • Handles used dynamically during exercise should be round or oval in design
  • Text and fonts shall be in accessible format, i.e., larger, non-serif, tactile, color contrast
  • Universal iconography should be used on instruction labels
  • The material(s) used for the instruction panel(s) shall be printed on a matt or non-glare finish and be heavy enough to prevent ‘show through’ of housing details such as seams or fixings
  • Sentence case (not block capitals), sans serif, and non-italic fonts of legible size shall be used
  • All text shall be aligned left and unjustified
  • The spacing between words and characters shall be legible
  • If an arrow is used to provide direction to a specific component, then the arrow shall be positioned in between the instructions and the component, with the arrow pointing to the component
  • All safety stops should be centrally located and available for emergency third party operation
  • All emergency/safety stops shall be of a color, shape, and size that is easily distinguishable from other available controls
  • All key mechanisms and parts of the equipment shall have a minimum value (color) contrast, including moving parts, gripping surfaces, support surfaces, adjustment mechanisms, text/markings

Consoles (applies to all applicable equipment)


  • Control panels/consoles main operational controls shall have grouping/pairing of similar main operational controls
  • Control panels/consoles shall be centrally located
  • All start controls shall incorporate the color green into either the background or text and all stop controls shall incorporate the color red
  • Individual buttons shall be used for all available main controls
  • All main controls shall have a tactile border or the whole button shall be raised
  • Tactile or kinesthetic feedback, e.g., a click or responsive feel to the actuation, and/or audio feedback shall be provided on main controls
  • A quick start button shall be provided
  • Power driven equipment shall be activated by means of a single push/press of a start button that shall start the equipment in manual mode at the lowest default speed or equivalent

Upper Body, Torso and Lower Body Strength (Selectorized) Equipment


  • Allow the joint(s) being used to work within a non-stressed range of motion
  • Adjustable or alternative start position(s), e.g., multiple grip options on handles or pads
  • Positions shall be capable of being pre-set before commencing the exercise or self-adjusting to the user’s size and range of motion
  • Upper body equipment shall not require the use of the lower limb(s) to achieve appropriate start position
  • Seats shall have an integral back support where pressing and pushing movements are required
  • Seated pulling movements shall have a chest pad, knee support, or similar method of stabilizing the user
  • Back supports shall have adequate height from the top edge of the seat base
  • If the first weight selection position does not require the selection mechanism, e.g., pin or similar, to be used, a method of storing the pin that does not interfere with operation of the remaining weights shall be provided
  • Exercise handles shall be equipped with a mechanism or storage facility that allows a fixed start position(s) within the range of seated users and standing users
  • Instructions for use shall be provided on all selectorized strength equipment within clear line of sight of the user when in the primary exercise position
  • For people that use mobility aids while operating fitness equipment, information should be posted within the fitness facility warning of the maximum loading requirements and stability issues during exercise
  • The user’s manual shall contain a warning section regarding maximum loading and stability information when using mobility aides during exercise, e.g., by using brakes or other means
  • If the equipment is movable, it needs to be lightweight and move with minimal force
  • Instructions for use shall depict graphically clear start and end exercise positions which shall be labeled
  • All weights including incremental weights shall be integral to the equipment, i.e., not removable loose weights
  • Start resistance and incremental resistance shall be sufficiently low
  • A single numbering system, e.g., kg, lb or 1-20, shall be provided on both main and incremental weights



  • Slow maximum default start/increment speed
  • Power equipment shall have a hands free pull (kill) cord that is attachable to clothing and accessible by 3rd party assistant
  • Moving decks or surfaces shall have markings with significant color contrast that remain visible at all times
  • Foot platforms of a non-slip material with sufficient stepping space shall be provided on either side of the moving surface
  • Handrails strong enough to enable mount/dismount (emergency dismount) and stabilization during activity shall extend throughout the useable length of the running surface on both sides of the treadmill and the full width of the front of the treadmill

Bicycles (recumbent or upright)


  • Recumbent cycles shall have an adjustable height seat (that adjusts forwards and backwards)
  • Recumbent cycles shall be walk through, with low step over height from the floor
  • Upright cycles shall have an adjustable height seat that allows for easy egress
  • Upright cycles shall have a front static handlebar
  • Saddles on upright cycles shall be wide enough to adequately support user with trunk instability
  • Pedals shall have adjustable toe straps and heel lips to retain the foot in a stable position and prevent the foot from slipping off the pedals when exercising
  • An element of the part of the equipment where the user is required to step over shall have significant color contrast from the adjacent surface



  • Foot platforms shall be of sufficient size and have a raised lip along front/inside/outside edges.
  • The foot platforms shall have a slip resistant surface

Example of a non-accessible versus an accessible piece of equipment

9 - equipment