ADA Requirements on Grab bars

The 2010 ADA Standards has requirements for grab bars position gives a range on section 609.

• For adults the top of the gripping surface of the grab bar should be between 33″ to 36″ a.f.f.
• For children, the top of the gripping surface is required to be installed between 18″ and 27″ a.f.f.

609.4 Position of Grab Bars. Grab bars shall be installed in a horizontal position, 33 inches (840 mm) minimum and 36 inches (915 mm) maximum above the finish floor measured to the top of the gripping surface, except that at water closets for children’s use complying with 604.9, grab bars shall be installed in a horizontal position 18 inches (455 mm) minimum and 27 inches (685 mm) maximum above the finish floor measured to the top of the gripping surface. The height of the lower grab bar on the back wall of a bathtub shall comply with 607.4.1.1 or 607.4.2.1

But what it doesn’t state or require is that the grab bars must be at the same height. Below is a photo of an inspection where the grab bars were both installed at the children’s height, but one was at the 18″ range and the rear on was at the 27″ range. According to TDLR and The US Access Board, this is not a violation of the Standards.