Accessible Counters

Thursday, July 1st, 2021

Abadi Accessibility is proud to support the Americans with Disabilities Act (ADA) 31st Anniversary. On July 26th we celebrate this important civil rights law that works to ensure all people with disabilities have the same rights and opportunities as everyone else. Celebrate with us by visiting: #ADA31 #ThanksToTheADA

How are you planning to celebrate Americans with Disabilities Act (ADA) 31st Anniversary? This July 26th the ADA National Network and individuals, communities, and organizations across the country will be participating. Learn how you can be involved by visiting #ADA31 #ThanksToTheADA

Introduction to our newsletter:

After I wrote my first newsletter about counters, my clients are still not clear on all the different requirements for the different types of counters and fixed or built-in surfaces that the ADA requires to be accessible. First of all let me review that there are five type of counters scoped in the ADA Standards: Work surfaces, dining counters, service counters, sales counters and check out counters. Then there are two type of counters that are not scoped: work area counters and non-work area common use counters that do not fall under the other listed. There are also Food service lines, as well as other portions public side service areas. For those please check out my newsletter I wrote I 2014.

This newsletter will explain the different requirements for dining surfaces, non-employee work surfaces and sales and service counters.

Dining Counters

According to Scoping section 226, at least 5% of seating spaces and standing spaces at dining surfaces must comply with 902. Standing spaces are those counters where people might stand to eat or drink rather than sit. Those counters must also comply. Some examples of dining counters are bars where drinks are served, fast food establishments with fixed tables, and booths and banquettes at a restaurant.

These fixed dining counters in a cafeteria is an example of a dining surface.

a bar is an example of a dining surface

Section 902 gives us direction on how to make the dining surfaces accessible:

  1. There must be a knee clearance complying with section 306 so that a person in a wheelchair will approach and use the counter in a forward approach
  2. The height of the counter must be between 28″-34″ a.f.f. PLEASE NOTE….WE RECOMMEND TO NEVER USE THE MINIMUMS OR MAXIMUMS WHEN DESIGNING.

A dining counter should have a 30″ width and a 17″ min. depth at the knee clearance.

A dining counter has a forward approach knee clearance and it is 34″ a.f.f.

This is a dining counter but also a service window. It is acceptable to have the dining counter in front of the service counter

Non-Employee Work Surfaces

Section 226 tells you that 5% of non-employee work surfaces must comply and meet the requirements set forth in section 902. These are also required to be dispersed throughout the space they are in. Section 902 states that a work surface must have a forward approach with a knee space per section 306 and be 30″ wide minimum and 34″ high maximum

Study carrols in a library is an example of a non-employee work surface

Diaper changing counters are also considered a “work surface”

A patient registration desk is another example of a non-employee work surface

All the requirements in section 902 are for non-employee work surfaces (or for the public). Employee work surfaces that are part of a work area are exempted until such time when a person with disabilities is hired at which point, the surface must be provided to accommodate them and their abilities.

Sales and Service counters

Where provided, at least one of each type of sales counter and service counter shall comply with 904.4.

Where counters are dispersed throughout the building or facility, counters complying with 904.4 also shall be dispersed.

Keep in mind that the requirements are the either sales or service counters. The term “transaction” is no longer used. A transaction could occur but it is not the only pre-requisite for compliance.

The counter shown above has different functions (some are sales and some are service). Each one must have a portion at an accessible height

Section 904 gives us the following requirements for sales and service counters:

  1. 36” high maximum
  2. Same depth as the main counter
  3. 36” length min.
  4. Parallel approach OR Forward approach allowed

the accessible couter must be 36″ a.f.f. maximum and at least 36″ long

A sales or service counter can have either with a forward approach knee clearance or a parallel or side approach.

The accessible portion of the counter must be the same depth as the main (or public) side of the counter. Even though the reception counter is deeper than the public counter, the accessible portion will only have to be 36″ a.f.f. maximun and 36″ min. long the same depth as the public counter (which can be higher than 36″ a.f.f.)

The reception desk is considered a “service” counter because information is a service a business would provide to their guests. The one shown above did not have a 36″ long counter

A service or sales counter may not be the type that is flipped up, or pushed in once it is used. it must be a permanent counter that is always available.

Inspector’s Corner

Tuesday, June 1st, 2021

Inspector’s Corner

Today’s newsletter I bring you some examples of violations that I found during my on site inspections. These specific ones are violations that were made because the standards were not so well understood. Hopefully these examples will give you some clarity for future installations.

Clearance at the drinking fountains

The drinking fountains that are mounted along a circulation path might be a protruding object if the leading edge is higher than 27″ a.f.f. When the leading edge is higher than 27″ a.f.f. which most of the time it will be the drinking fountains for standing persons, then that drinking fountain will be considered a protruding object. To resolve the violation, we typically see a cane detectable apron installed at the bottom edge of the high drinking fountain. Since the high drinking fountain is not for people in wheelchairs, but for people who are standing but have trouble bending down to drink, a knee clearance is not required. So technically the cane detectable apron could be mounted at any height as long as it reaches a minimum of 27″ a.f.f.

The misunderstanding is of the requirement that the clear floor space of the wheelchair be located centered with the low unit for them to use

602.2 Clear Floor Space. Units shall have a clear floor or ground space complying with 305 positioned for a forward approach and centered on the unit. Knee and toe clearance complying with 306 shall be provided.

So that means that the 30″ clear floor space will be partially located under the high drinking fountain

If the cane detectable apron located at the high drinking fountain is lower than 27″ a.f.f., it will reduce the required knee clearance at the low drinking fountain

The cane detactable apron is lower than 27″ a.f.f. which reduces the knee clearance which is centered at the low drinking fountain

In order to not have that violation, the cane detectable apron must be mounted exactly at 27″ a.f.f.

Post-mounted protruding objects

(this is not exactly examples of violations, but rather why it is not a violation)

The rules for protruding objects allows post or pylon mounted obects to project 12″ from its mounting surface. The figure below is from the ADA and TAS section 307.3 which shows the parameters of the protrusion limits.

My example is from an interior play area where there was a statue of one of their characters mounted on a pylon or tall base. The statue had a little hand and pigtail that projected beyond the edge of the base. But because the ADA and TAS allows a 12″ protrusion limit along the circulation path, the statue was not a protruding object.

The little hand of the statue projected 6″ beyond the base, which was compliant.


Another example of a post mounted protruding object is a stand pipe located at a means of egress stair landing. Because the means of egress is essentially a circulation path it will require that the protrusion limits that the ADA and TAS describe in section 307 be adhered to.

The stand pipe in the photo below does have an extension where the valve is projecting more 12″ beyond the pipe and mounted higher than 27″ a.f.f.

The stand pipe is a protruding object because the valve projects more than 12″ from the post onto the circulation path

Pendant lights as protruding objects

Sometimes the protruding objects occurs because the object is mounted below 80″ a.f.f. Pendant lights can be protruding objects if mounted too low. The condition shown in the photos below shows a play room with furniture mounted below the pendant lights. The pendant lights are mounted at 70″ a.f.f. and therefore are protruding objects.
But you might be asking why is it a violation since the furniture acts as our cane detection?
Good question…
What is a misunderstanding is that the only cane detection that is allowed must be fixed or buil-in (see the requirement below)

201.1 Scope. These standards apply to fixed or built-in elements of buildings, structures, site improvements, and pedestrian routes or vehicular ways located on a site.

because the furniture below the pendant lights are movable and not built in they cannot be use as cane detection

the pendant light is mounted at 70″ a.f.f. and is considered a protruding object

ANSI A117.1 vs. ADA

Monday, May 3rd, 2021

The 2010 ADA Standards for Accessible Design (The ADA for short) is sometimes used as a catch-all term for all requirements for designing for persons with dissabilities. What is sometimes misunderstood is that the ADA is a Civil Rights law with design guidelines for public accommodations and commercial facilities. But there are other laws and standards that govern how to design for persons with disabilities that are different from the ADA and still have to be followed. One of the standards are found in the building code. If a municipality has adopted Chapter 11 of the IBC that chapter references another Standards call the ANSI A117.1. The ADA and ANSI are very similar, but there are some differences. In this newsletter I will give you a few examples.

For the sake of this newsletter I wilil be discussing the 2017 ANSI A117.1 Standards. This may or may not be the Standared that has been adopted by the municipality you are designing under and you will need to verify which version you need to follow. Not all the versions have the same requirements.

304 Turning Space

Both the ADA and ANSI A117.1 have requirements for the size of a circular turning space. They used to be the same (60″ diameter), but In the 2017 version of the ANSI the size increased to 67″ min.
Below is the new figure for the 2017 ANSI

604.5.2 Rear Wall Grab Bar

Both in the ADA and the ANSI the section that discusses the rear wall grab bars is 604.5.2 But the location of the grab bar is measured differently in the ANSI than in the ADA. this confuses most installers and we typically find ADA violations based on the assumption that they are both the same.

Note the figure below. It is from the 2017 ANSI A117.1 604.5.2

It shows that the rear wall grab bar is located in relation to the side wall. It should measure 6″ from the side wall to the inner edge of the grab bar and it should have an overall dimension of 42″ min. from the side wall to the outer edge.

This is figure ANSI A117.1 604.5.2 from the 2017 version

Note the figure below. It is from the 2010 ADA section 604.5.2

It shows that the rear wall grab bar is located in relation to toilet. It should also be 36″ long min. just like the ANSI, but we locate it from the center of the toilet so that there is 12″ min. from the center to the inner edge and 24″ min. from the center to the outer edge.
The ADA rear wall grab bar location has no relation to the side wall.

This is figure 604.5.2 from the 2010 ADA Standards. It shows the rear wall grab bar and its lcoation in relation to the toilet.

502 Parking

There are two sections that the ANSI has that the ADA does not: parallel parking and Electrical vehicle charging station parking.

502.9 Parallel Parking

The 2017 ANSI Standards has guidelines for parallel parking for on-street parking. It requires a vehicle space plus an access aisle parallel to the curb and a curb ramp or accessible route close to the spaces.

The figure 502.9.1 above shows on-street parallel parking

502.11 Electrical Vehicle Charging Stations

The 2017 ANSI Standards provide requirements for Electrical Vehicle charging stations. Some of them are

  • Operable parts should be within reach
  • There should be an access aisl adjacent to the parking space with clear floor sapce next to the unit
  • Any protection bollards, curbs and wheel stops should not be located so it obstructs the route or the reaching.

Inspector’s Corner

Thursday, April 1st, 2021

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.

Accessible Toilet and Shower Rooms

Monday, March 1st, 2021


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.

Operable Parts and Reach Ranges

Monday, February 1st, 2021

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.

August 2019: Inspector’s Corner

Friday, August 2nd, 2019


It’s been a while since I shared with you some of my findings at my inspections.  Hope this newsletter assists in learning some of the pitfalls so we don’t repeat them.

Washer and Dryer

The ADA standards and the 2012 Texas Accessibility Standards section 611 requires that a washer and dryer have a 30″x 48″ clear floor space that will be centered on each unit.
611.2 Clear Floor Space. A clear floor or ground space complying with 305 positioned for parallel approach shall be provided. The clear floor or ground space shall be centered on the appliance.
When I get drawings and see laundry areas, I make sure to note that the clear floor space must be centered.  Which means that from the center of the appliance there should be 24″ on each side.  Below are some examples of drawings where it was not clear that the clear floor space was provided.  And after construction, the inspection also did not provide the space.
This drawing showed a guest laundry room with a dryer next to a wall which does not provide 24″ from the center line of the dryer to the wall.
This drawing shows a closet for the washer and dryer.  The doors reduce the ability to have a clear floor space that is parallel and centered on the appliances.

Here are some examples of the laundry rooms after construction:

The doors in this laundry closet were in the way of the clear floor space

Some solutions for this would be to make the doors open 180 degrees if possible, or there is a new type of washer/dryer that is all in one.  Here is a photo of a washer and dryer combo

This is a washer and dryer combination unit.  It still does not have the clear floor space of 48″ centered and parallel, but this would fit in the closet
Fair Housing Requirement #4: Accessible Route into and Through the Covered Unit
The Fair Housing Act which deals with multi-family housing requires that there be one accessible 36′ wide route throughout the apartment.  This would include a path to the closet.  This layout had a toilet in front of the closet.  But the distance between the toilet and the tub reduced the path to 32″
This unit has the toilet next to the closet door.  The distance between the front of the toilet too the tub should be no less than 36″ in order to allow access to the closet
The distance between the front of the toilet and the tub is less than 36″
The distance between the tub and the front of the toilet is less than 36″ which reduces the accessible route to the closet


31 1/2 inches clearance

Bottle fillers

It has been very popular to add bottle fillers near or above drinking fountains.  At one of my inspections they installed a bottle filler above the wheelchair accessible drinking fountain.  This would be acceptable but in this case they mounted it too high and the operable part (or the sensor) was mounted higher than the 48″ a.f.f. allowed
This bottle filler was mounted higher than 48″ a.f.f. to the sensor
The sensor was mounted at 54″ a.f.f.
Sometimes the bottle filler is mounted next to the drinking fountains which is also acceptable but might create issues with protruding objects.  Since the bottle filler is located inside the recessed niche where the drinking fountain is located it does not provide a cane detection.  The drinking fountain is located on the circulation path to the door into the restroom beyond.
this bottle filler was next to the high drinking fountain and did not provide a cane detection at the high drinking fountain