Where are accessible benches required?

Compliance with ADA Section 903 (Benches) shall be required only when specifically referenced in the 2010 ADA Standards for Accessible Design. This also applies to Texas 2012 Texas Accessibility Standards. There is no specific scoping for benches, except when they are required in the the different sections of the ADA Standards. Because the ADA Standards only deals with fixed or built in elements, benches must be fixed or built in as well.

Benches complying with section 903 are only required at the following spaces:

• Saunas (per section 612)
• Locker Rooms (per section 803)
• Dressing Rooms (per section 803)
• Fitting Rooms (per section 803)
• Holding Cells (807)

And all those benches must follow the requirements in section 903:

903.2 A Clear Floor or Ground Space next to the short axis.

The bench shown in the figure above is inside a dressing room which requires that the bench have back support as well as the 30″x48″ clearance parallel with the short axis of the bench

903.3 Size should be 42″ long and between 20″ and 24″ deep

903.4 Back Support.

903.5 Height should be 17″-19″

903.6 will holds 250 lbs

903.7 at Wet Locations the seat shall be slip resistant and does not accumulate water.

Saunas and Steam Rooms ADA 612.2

The sauna has a bench with back support, the proper length of 42″ and depth of 24″ with a 30″ x 48″ space next to its short axis

Dressing, Fitting, and Locker Rooms ADA 803.4

Dressing rooms are typically private rooms in doctor’s offices, imaging centers etc. which are provided for the purpose of changing out of clothes and into other garments

This dressing room does not have a compliant bench because the bench is movable, the door swings into it and no 30″ next to its short axis .

Fitting rooms are private rooms provided at retail stores for the purpose of trying on clothing for purchase.

This dressing room does not have a compliant bench in the room.

This fitting room does not have a compliant bench because it doesn’t have a 30″ space next to the short axis

Locker rooms are also considered “dressing rooms” if the lockers are used to keep uniforms or clothing like at a gym or a medical building where people will change into clothes for a specific purpose.

This bench is located up against the wall in a locker room and therefore has back support. Note that the 30″x48″ clear floor space is in front of the door which (although not recommended) it is allowed

This locker room does not have a compliant bench. It lacks back support and it is not a minimum of 20″ deep.

This is a bench that is not up against the wall so back support per figure 903.4 was provided, but they did not provide the 30″ x 48″ space next to the short axis. The lockers were in the way reducing the clearance to 21″ (see next photo)

This photo is the dimension of 21″ between the edge of the bench and the edge of the lockers next to it. The clearance should have been 30″ minimum

Holding Cells and Housing Cells ADA 807.2.2

This holding cell has a bench with back support, but it does not have a 30″ clearance next to the short side.

Other Bench locations

There may be other locations where benches are used. If a fixed bench is provided in other spaces besides the ones specifically listed in the Standards, they do not have to comply with section 903. Below are other locations where benches may be provided, but do not have to comply with the standards or be on an accessible route.

Benches on the exterior

What about fixed or built in benches at courtyards, amphitheaters or or even at parks? If they are part of an assembly area (with four or more benches for the use of an audience or seating for spectators) then it would have to comply only with assembly seating per section 221 and 802.

Otherwise, these benches are not scoped and do not have to comply with the requirements in section 903.

The benches shown in the photos above are located in a park. These benches are not required to comply. Even the one at the basketball court is not considered assembly seating unless there are four or more and meant to be part of the spectator seating.

Benches at shower rooms

Shower rooms often have benches, but those are not required to comply because a shower room is not technically a “dressing” room even though dressing and undressing might occur inside.

Benches are different than shower seats. The photo below shows a shower with a bench but no seat.

The bench shown in the photos above are located in a shower room. It is not inside the shower and therefore not considered a shower seat. Benches are not required in shower rooms and therefore do not have to comply with the Standards.

Bus stops also might have a bench

The bench adjacent to the bus stop and the one located inside the bus stop are not required to comply with either section 903 or section 802.

ADA only requires compliance in dressing rooms, fitting rooms, locker rooms, saunas, and holding cells. The spaces shown above are not required to provide a bench, therefore if a bench is provided it will not have to comply.

TDLR has a Technical Memo that explains this fact.