It’s been a while since I have done an “Inspector’s Corner”….It was actually last April…must be an April Fools thing…but it is not. I go to many inspections and see some really interesting violations (amid all the common ones). I even learn from them. Here are three that I saw that are good to learn from:
Ambulatory Toilet compartments
There are two types of toilet compartments required by the ADA: one for wheelchairs and another for other mobility devices such as walkers, crutches, knee scooters etc. Those are called Ambulatory and the requirements are found in section 604.8.
Since they are for different types of disabilities they do have different configurations.
Some of the obvious things that are different is the width. The wheelchair toilet compartment is required to be 60″ min. wide while the ambulatory must be between 35″-37″. Also the location of the grab bars are different. But one of that was missed during my inspection was the length of the ambulatory.
If you see the size of the wheelchair toilet compartment you will notice that the depth can be between 56″ to 59″ depending on the type of toilet used.
The Ambulatory toilet compartment must be 60″ minimum.
So if you are designing the wheelchair toilet compartment to its minimum depth and the ambulatory is built the same, there will be a violation since the depths are slightly different
The ambulatory compartment was located next to the wheelchair compartment which was only 58″ long
Cane detectable aprons at Electric Water Closets
As we have learned, persons who are visually impaired will require feeling their way through the built environment rather than seeing. So if there are any objects along the path that they will use to circulate that might be mounted above 27″ a.f.f. (which is the height where they cannot detect the object with their cane), then the object should not be deeper than 4″ or it will be considered a “protruding object” and will violate the standards.
One object that is typically considered protruding objects are electric water cooler (EWC) or drinking fountains.
The drinking fountain shown above if mounted along a circulation path the high one will not be detectable and will be considered a protruding object
A good solution for drinking fountains that are protruding onto the circulation path is to create “cane detection” by using a cane detectable apron which most manufactures have as an accessory that can be added after market. The apron should be located under the “protruding object” which is typically the high drinking fountain. If mounted correctly it will reach the 27″ a.f.f. which provides cane detection and will resolve the violation.
The issue becomes when the use of the cane detectable apron is misunderstood. Some contractors do not understand why they are being installed and will mount them to the wrong drinking fountain.
The drinking fountain shown above has a cane detectable apron mounted under the wheelchair accessible drinking fountain. That drinking fountain was not the protruding object but in addition not the wheelchair drinking fountain does not have a knee clearance due to the apron.
the cane detectable apron was mounted under all the drinking fountains. In addition, the cane detectable apron was not required since the wing walls that were installed would have been used as cane detection as well.
Changes in Level
The ADA Standards has a chapter called “Changes in Level” which states that along the accessible route you may not have any changes in level greater than 1/4″ or 1/2″ with a bevel.
One of my inspections had a roll in shower inside a restroom. The turning space of the restroom was partially located inside the roll in shower. The roll in shower had a collapsable curb which reached 1/4″ of heigh once the wheelchair would rolll on it.
The drawing is showing the location of the turning space which overlaps inside the roll in shower.
This was a photo of the collapsable curb at the roll in shower.
Based on the advisory of section 304 which discusses turning spaces, this is acceptable:
Advisory Advisory 304.2 Floor or Ground Surface Exception.
As used in this section, the phrase “changes in level” refers to surfaces with slopes and to surfaces with abrupt rise exceeding that permitted in Section 303.3. Such changes in level are prohibited in required clear floor and ground spaces, turning spaces, and in similar spaces where people using wheelchairs and other mobility devices must park their mobility aids such as in wheelchair spaces, or maneuver to use elements such as at doors, fixtures, and telephones.
ADA Section 213 Toilet Facilities and Bathing Facilities
Section 213.2 of the ADA explains that where toilet room and bathing rooms are provided, each one must comply with the Standards.
There are a few exceptions that allow some toilet rooms and bathing rooms not to have to comply. This newsletter will explain those exceptions and when they can be taken.
ADA Section 213.2 Exceptions
Exception #1 explains that not all restrooms would be required to comply in an alteration when it is technically infeasible to comply and cannot be made compliant due to existing conditions, they do not all have to comply and a the owner must apply for a variance with the AHJ. In such cases, a single user restroom can be used instead.
Exception #2 In a Historic facility (a facility regsitered with the National Register or Landmark Commission) is not required to have all toilet rooms accessible. One unisex restroom will be allowed to be used.
Exception #3 if there are multiple single user portable toilet or bathing rooms that are clustered at a single location, no more than 5% of each must comply.
This is a single user portable toilet room
Exception #4 Where multiple single user toilet rooms are clustered at a single location, no more than 50% of the single user toilet rooms for each use at each cluster shall be required to comply. This section only gives the exception to toilet rooms (even though it is part of the same section that also discusses bathing rooms)
The above image is of two single user restrooms clustered together. Only one must comply
The above image is of two single user restrooms that are not in a cluster because the doors open to separate areas. In the Advisory it explains that a cluster are “within sight of or adjacent to one another”. Both of these toilet rooms must comply
The above image is of multiple single user toilet rooms and multiple single user bathing rooms in a cluseter. In this plan only restroom 117 and 119 can take the exception because they are toilet rooms in a cluster and they are of the same kind.
All the other toilet rooms have showers and therefore are considered bathing rooms. Even though they are in a cluster, there is no exception for bathing rooms that are in a cluster, so all of the bathing rooms must comply.
Section 213.2.1 Unisex or single user restroom or Family restroom and unisex bathing rooms is defined as containing no more than one lavatory,and two water closets without urinals or one water closet, one urinal and one urinal. In addition, a unisex bathing room is considered unisex when it has one shower or one shower/tub, one lavatory and one water closet.
Even though these individual toilet compartments have a lavatory and a water closet, they are located inside a multi-user toilet room and therefore only one compartment is required to comply. These are not single user toilet rooms. These are toilet compartments inside one multi-user toilet room.
Even though these individual shower compartments, they are located inside a multi-user toilet room and therefore only one compartment is required to comply.
Before we start designing…..
Before starting to design operable parts by looking in section 309, we should begin in section 106.5 Defined Terms. This section will give us guidance on what is defined as an operable part:
Operable Part. A component of an element used to insert or withdraw objects, or to activate, deactivate, or adjust an element.
Now that we know what is defined as an “operable part” we can then go to Section 205 which gives us information on how many and which type are required to comply with the technical standards found in 309.
Section 205 begins with some exceptions. According to this section, operable parts on an accessible element, accessible route and in accessible rooms must comply. In the same section we also have a few exceptions.
1.Operable parts that are intended for the use only by service or maintenance personnel do not have to comply:
The medical equipment in this patient room is only for the use of the medical service personnel and does not have to be mounted within reach range
2 . Dedicated use electrical receptacles do not have to comply
The outlets that are used for appliances or specific electrical uses above the counter will not have to comply
3 . Where two or more outlets are provided in a kitchen above the length of counter top that is uninterrupted by a sink or appliance, one outlet shall not be required to comply
There are two outlets above the counter. Because they are not interrupted by a sink or appliance only one outlet will have to comply
4 . Floor outlets are not required to comply
5 . HVAC diffusers shall not be required to comply
6 Redundant controls (except light switches) for a single element, one control in each space shall not be required to comply
7 . Cleats and other boat securement devices shall not be required to comply.
8 . Exercise machines and exercise equipment shall not be required to comply
The exercise equipment controls do not have to comply.
Section 309 Operable parts
Once we have determined which operable parts are required to comply, we read the requirements on those operable parts in section 309: There are several requirements but in this newsletter we will focus on reach ranges which are found in section 308.
The rules about reach ranges are to locate the maximum and minimum heights to the operable parts.. In essense the height to the parts of the element that will need to be operated so that the element can work.
309.3 Height. Operable parts whsll be placed within one or more of the reach ranges in section 308
Section 308 requires that the operable part be within reach. Either unobstructed forward or side.
This light switch was mounted so that its operable part is at 48 1/2″ a.f.f. rather than the required BELOW 48″ a.f.f. to the top of the switch (which is what make it operate)
The rocker light switch was mounted so that it was 48″ a.f.f. to the middle of the switch. The problem with this is that the switch is operable by pushing the top or the bottom of the switch, not the middle.
The low reach (forward or side) can be no lower than 15″ a.f.f The charging outlet at these booths are mounted 8″ a.f.f.
Operable parts could also be located so that they are reached over an obstruction, either forward or side approach.
the outlet at the wall behind the counter is a type of operable part that will need to be within reach range. Most of the times the outlets are located at the gyp board, which in this case it is located more than 25″ away from the edge
operable parts over the obstruction can only be located a maximum of 25″ from the edge of the obstruction. The soap dispenser is located 26″ away
operable parts at classroom lab tables must be within reach also
the operable part is more than 25″ from the edge of the obstruction
Operable parts have many requirements, including the ability to reach it in order to operate if. The reach range requirements are to the part of the element to operate it, rather than the middle of the element, or the top of bottom. In addition, the location should never be exactly at the “maximum” or “minimum” . Construction is not a perfect science and tolerances are built in to the requirements. So when we are designing the elements keep in mind how it is operated and always design within the reach range, not higher or lower.
Abadi 
