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Senior Housing in California

Janis Kent, FAIA, Architect, CASp © April, 2022

As the Silver Tsunami increases with the aging of the baby boomer generation we will see more and more senior housing. In California with the Unruh Civil Rights Act, Section 51.2 thru 51.4 there are specific stipulations of what to provide for senior housing. Section 51.3.5 has specific requirements for senior living in intergenerational housing as well.

There are a handful of requirements that need to be included within any senior housing project built from January 1, 2001 and onwards according to 51.2 and 51.3 regardless of the funding. Also be aware that these requirements do not apply to senior housing in the County of Riverside.

1. Entries, walkways, and hallways in common use areas are to meet the requirements for wheelchair access as well as doorways and circulation paths to and within the dwelling units.

2. Walkways and hallways in common use areas are to have railings or grab bars to assist people who have difficulty walking.
3. Walkways and hallways in common use areas are to have sufficient lighting to assist people who have difficulty seeing.
4. All common-use areas and dwelling units are located on an accessible route
5. One common-use room is to be provided and some common-use open space to encourage interaction
6. Trash collection should be provided that requires minimal physical effort by residents

Implementing the above requirements is somewhat straight forward. 

• Using 11B for wheelchair access for common-use space hallways, corridors, and doors is more appropriate than 11A, since 11A is for adaptability, not necessarily accessibility. Inside the dwelling units, though, it would depend upon whether the unit is a mobility dwelling unit or an adaptable unit, although an adaptable unit requires less space for door clearances and may not be as accessible. 
• Installing handrails in common-use space walkways and hallways should also follow 11B for accessibility, not adaptability. As a note, according to both the ADA and CBC, two handrails are only required on a stairs or a ramp. By inverse, only one handrail is required along walkways and hallways, not two.

11B-505.2 Where required. Handrails shall be provided on both sides of stairs and ramps.

Generally someone who is using a walkway or corridor handrail also would have a cane or a walker. They may be using the railing to lean against as well, but it is not the same as mobility on a vertical rise such as a ramp or stairs which may affect stability.

• Providing sufficient lighting would require a higher amount then used by younger people. According to an AARP study, generally about 50% more ambient light would be considered good – so 30 fc or 300 lux for ambient light in living environments. Transitional spaces such as hallways and foyers should not have much less illuminance than the adjacent spaces since it takes longer for the elder eye to adapt, although entries should have intermediate levels from outside to inside to ease the transition.

  • Note that sufficient light is not specifically stated under the Unruh Act, but AARP Andrus Foundation supported a study and article by Mariana Gross Figueiro, “Lighting the Way: A Key to Independence“

• Having all common-use areas on an accessible route provides for more access than 11B. Generally under 11B, if there are 2, let’s say laundry rooms, that everyone can use, only one needs to be accessible, although under HUD’s Deeming Notice all are to be accessible.
• Providing a proscribed common-use space is not under 11B, so be sure to provide at least one common-use space on the interior and other open common-use spaces that encourage social interaction.
• And trash collection may be more of a facility management type of issue. If there is a trash collection or trash chute on each floor that would be less effort than having to walk the trash outside to a trash enclosure. A judgment call here.

The other aspect for senior housing is that it pertains to a development with 35 or more dwelling units. A qualifying resident or senior citizen is considered someone who is 62 years or older or who is 55 years or older and living in a senior housing development. There are also requirements for a qualified permanent resident depending upon their relationship to the qualifying resident or senior citizen, ie spouse, caretaker, etc, and can include a child or grandchild who has a disability. If a project has an Allotment letter for California TCAC for seniors, there are other requirements as well over and above the Unruh Act.

Nothing in this article constitutes legal or design advice for a particular project or circumstance. Be aware that your local City or County may have additional requirements that are different or more restrictive than the State or Federal requirements. Also, this article is an interpretation and opinion of the writer which may vary for a particular project or due to other circumstances. It is meant as a general summary – current original regulations should always be reviewed when making any decisions and specific advice by a qualified professional should be secured for a particular project or circumstance.

© Janis Kent, FAIA, Architect, CASp 2022