When can a sink be allowed to have a parallel approach?

Tuesday, November 1st, 2022

There seems to be a lot of confusion regarding the parallel (side) approach at sinks. The ADA, TAS and ANSI standards require all sinks and lavatories have a forward approach with a knee and toe clearance provided.

ADA and TAS (ANSI A117.1 similar) 606.2 Clear Floor Space. A clear floor space complying with 305, positioned for a forward approach, and knee and toe clearance complying with 306 shall be provided.

There are some exceptions that we will cover in this newsletter. Exceptions don’t have to be used, but if you need them, they are available.

Kitchen sinks WITHOUT a cook top or range

Exception 1. A parallel approach complying with 305 shall be permitted to a kitchen sink in a space where a cook top or conventional range is not provided and to wet bars.

The confusion in this exception is what is a “kitchen” sink. When there is not a clear definition in the definition section of the standards, they recommend that a dictionary definition may be used. TDLR did go on record as explaining what is their definition of kitchen with their Technical Memo TM2012-09.

In essense, a space with a fixed or built in cooking appliance will be considered a kitchen. And if the kitchen DOES NOT have a cooktop or range, then a parallel approach at the sink can be used.

The photo above is of a space with a built in oven. It is a built in cooking appliance, therefore it is considered a kitchen. Because this “kitchen” does not have a cook top or a range, the sink may have a parallel approach.

The photo above is of a space with a movable microwave oven on a shelf. Since the microwave is not built in, this is not considered a “kitchen” and a parallel approach cannot be used at the sink. The sink must have a forward appraoch with a knee and toe clearance as shown.


The photo above is of a space with a built in microwave oven and a built in range. This is considered a kitchen. And since it has a range, it cannot take the parallel approach exception and a knee clearance must be provided (as shown) at the sink.


The photo above is of a space with a microwave on the counter. Because the microwave is not built in, it is not considered a kitchen. Therefore, it cannot take the parallel approach exception and a knee clearance must be provided (as shown) at the sink.

Outdoor Kitchen Sinks

The photo below is of an outdoor kitchen for an office space. It is in essense an outdoor break area. The outdoor kitchen is scoped per TAS 212, 606, and 804. The sink is not eligible for 606.2 exception 1 because a fixed cooking facility is provided (grill). The parallel approach is not compliant because the kitchen does not meet the definition of a wet bar – it provides a fixed cooking facility and it is used as a range/cook top.

The photo above is of an outdoor break area with a sink and a range

Wet Bars

Exception 1. A parallel approach complying with 305 shall be permitted to a kitchen sink in a space where a cook top or conventional range is not provided and to wet bars.

Part of this exception allows a parallel approach if the sink is part of a “wet bar”. A wet bar is essentially a place where only drinks will be served or prepared. These most commonly occur at waiting rooms or at hotel rooms without kitchennettes.

The photo above is of “wet bar” at a waiting room in a clinic

Lavatory at a private bathroom (accessed from a private office)

Exception 2. A lavatory in a toilet room or bathing facility for a single occupant accessed only through a private office and not for common use or public use shall not be required to provide knee and toe clearance complying with 306.

A office is deemed “private” if it is only for one person and not located in a common area. A “private” bathroom is deemed private if it is only accessed from the private office and only used by one person.

The image above is of a “private bathroom” that is accessed by a doctor’s office. The lavatory may take excepton 2


The photo above is of the lavatory at the private restroom that is accessed by a doctor’s office. The lavatory may take excepton 2 and can have a parallel approach.

The image above is of a restroom accessed from the staff break room. This is NOT a private bathroom and the lavatory must have a forward approach w

ANSI A117.1, ADA and TAS Residential Lavatory and Kitchen Sinks

Exception 3. In residential dwelling units, cabinetry shall be permitted under lavatories and kitchen sinks provided that all of the following conditions are met:

(a) the cabinetry can be removed without removal or replacement of the fixture;

(b) the finish floor extends under the cabinetry; and

(c) the walls behind and surrounding the cabinetry are finished

This exception can be taken only at residential dwelling units. If it is taken a door can be used to cover the knee clearance, but the floor finish must extend to the back wall and the pipes must be protected. In addition the cabinetry must be able to be removed without having to re-build the knee clearance.

The image above shows a sink at a residential dwelling unit that has doors in front of the knee space. Once the doors are open, the floor finish and all the side walls around the sink are finished as well.

Sinks and lavatories for children 5 years old and younger

Exception 5. A parallel approach complying with 305 shall be permitted to lavatories and sinks used primarily by children 5 years and younger.

The image above shows a sink at a classroom for children five years old and younger

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When does the Fair Housing Require a centered approach?

Monday, October 3rd, 2022

The ADA is not the only Standard that requires clear floor space to be centered. The Fair Housing Design Guidelines and ANSI A117.1 also does. This newsletter will provide guidance on when the clear floor space in a residential dwelling unit must be centered.

Fair Housing Kichen Appliances

The parallel clear floor space at sinks, as at sink when bowls are ranges and cooktops, must be centered on the bowl of unequal size or appliance.

In addition to the turning space, the kitchen must be arranged so there is a 30-inch x 48-inch clear floor space for a parallel approach centered on the sink, range, or cooktop. The centerline of the fixture or appliance must be aligned with the centerline of the clear floor space.


Fair Housing Clear Floor Space Bathroom Lavatories

A 30-inch x 48-inch clear floor space is required at the lavatory so a person who uses a wheelchair or scooter can get close enough to the basin and controls to use the fixture. When knee space is not provided for a forward approach, this 30-inch x 48-inch clear floor space must be parallel to the cabinet or counter front and centered on the basin.

ANSI A117.1 Washer and Dryer

611.2 Clear Floor Space. A clear floor space complying with Section 305, positioned for parallel approach, shall be provided. For top loading machines, the clear I floor space shall be centered on the appliance. For front loading machines, the centerline of the clear floor space shall be offset 24 inches (610 mm) maximum from the centerline of the door opening.

ANSI A117.1 Residential Kichen Work Surface

In kitchens of residential dwelling units there is a requirement to provide a “work surface” with a knee clearance with a floor space centered and allowing a forward approach.

804.3 Kitchen Work Surface (Residential only)

804.3.1 Clear Floor or Ground Space. A clear floor space complying with 305 positioned for a forward approach shall be provided. The clear floor or ground space shall be centered on the kitchen work surface and shall provide knee and toe clearance complying with 306.

The image above shows a residential kitchen with a sink as well as a “work surface” which provides a forward approach. The work surface is required that the clear floor space below it be centered at the surface. The sink is not required to provide a clear floor space that is centered.

The image above shows a residential kitchen work surface and it is centered at the surface.

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.

About the ADA and TAS. What you might not know?

Monday, December 2nd, 2019
After almost 20 years in my business I am still learning things about the ADA and TAS.  I want to share with you some things that might not be so apparent when you read the standards.

Location of Work Surface in a Residential Kitchen

When designing a residential kitchen that will be used by the public (e.g. a an assisted living resident room, a kitchen in an emergency personnel facility, an apartment for a resident hall director or RA etc.) the appliances that you choose will have to be compliant with the ADA and TAS.   One of the requirements is typically missed or overlooked.  It is the one pertaining to a work surface in a “residential kitchen”.
804.3 Kitchen Work Surface. In residential dwelling units required to comply with 809, at least one 30 inches (760 mm) wide minimum section of counter shall provide a kitchen work surface that complies with 804.3
804.6.5.1 Side-Hinged Door Ovens. Side-hinged door ovens shall have the work surface required by 804.3 positioned adjacent to the latch side of the oven door.
804.6.5.2 Bottom-Hinged Door Ovens. Bottom-hinged door ovens shall have the work surface required by 804.3 positioned adjacent to one side of the door.
Where a work surface is required and the kitchen has an oven, the work surface needs to be located adjacent the oven.


Keep in mind, this only applies to “residential” kitchens….not all kitchens.  So a break room or common use kitchen not located in a residential dwelling unit (as defined by the ADA) does not require a work surface.

Clearance vs. Clear Floor Space

There are two concepts that are sometimes thought to be interchangeable in the ADA and TAS:  “Clearance” and “Clear Floor Space”.  Section 305 lists the requirements for “Clear floor space” .  Clear floor space is required adjacent beds, under counters, lavatories, sinks, at operable parts for reaching, inside platform lifts, at drinking fountains, at toilet room fixtures, at washer and dryers, at saunas and steam rooms, at ATM, at signage, at work surfaces, at jury boxes and adjacent exercise equipment.

Some of the requirements are listed below from Section 305:

305.2 Floor or Ground Surfaces. Floor or ground surfaces of a clear floor or ground space shall comply with 302. Changes in level are not permitted.

EXCEPTION: Slopes not steeper than 1:48 shall be permitted.

305.3 Size. The clear floor or ground space shall be 30 inches (760 mm) minimum by 48 inches (1220 mm) minimum.


Any time that the words “clear floor space” is found in the Standards these are the requirements that must be followed.  Some of those instances will be at the clear floor space to reach objects, a clear floor space at wheelchair seating in assembly areas or clear floor space at toilet rooms.

A clear floor space is required at the push button. The clear floor space needs to have a slope no steeper than 1:48 . This clear floor space is steeper.


What sometimes gets conflated are the “clearance” at plumbing fixtures like toilets, showers and tubs. “Clear floor space” is defined, but “clearance” is not….except to describe its size and location.

608.2.2.1 Clearance [at roll in showers]. A 30 inch (760 mm) wide minimum by 60 inch (1525 mm) long minimum clearance shall be provided adjacent to the open face of the shower compartment.

The clearance is mentioned to let us know what size we need to provide and where it should be located…but it does not mention slope.

Unlike the clear floor space where a slope cannot exceed 1:48, a clearance at the shower for example is not defined.  So the clearance at the roll in shower can have a slope that exceeds 1:48
This roll in shower has a slope up to the shower pan which is acceptable (although may not be recommended)

Accessible sinks at Kitchens

Friday, February 24th, 2017

Sinks and Lavatories

In the 2010 ADA and the 2012 TAS requires that 5% but no less than 1 sink must be accessible.  One of the requirements of accessibility at sinks is  to have a knee space under the sink.  But there is a few exceptions.  The one we will focus on this time is the first exception:
606.2 Clear Floor Space Exception 1: A parallel approach complying with 305 shall be permitted to a kitchen sink in a space where a cook top or conventional range is not provided, and to wet bars. 
The Texas Department of Licensing and Regulation issued a bulletin whichdefines “kichen sink”  And another technical memo that explains when this exception can be taken and when it cannot.  This newsletter will explain it as well.

Does my sink at a break room have to have a knee space?

It depends (don’t you love that answer?)…..
It depends on whether the break room is a kitchen or not. But it can’t be our definition of a “kitchen”, but the dictionaries definition. When dealing with terms that the ADA and TAS do not define, we are directed by the US Access Board to use the Webster’s definitions:
-Kitchen: A place (as a room) with cooking facilities.
-Kitchenette: A small kitchen or alcove containing cooking facilities.
-Wet Bar: A bar for mixing drinks that contains a sink with running water.
-Cooking Facilities: Fixed or built-in range, cook top, oven, microwave, or convection oven.
-Fixed Appliance: When attached to a cabinet, shelf or other surface or to a gas supply.
-Built -In Appliance: When cabinetry design or location of utilities (i.e.. gas supply or 220V electrical outlets) creates a dedicated shelf or space for the appliance.
So, if a break room has no fixed “cooking facilities” within, then it is not considered a “kitchen” and therefore it must have a proper knee clearance at the sink.
This break room has a microwave in a shelf, but it is not fixed or built in.  Because it is not considered a “fixed cooking facility”, this space is not a ‘kitchen” and the sink will require a knee space.
If on the other hand, the break room has a fixed cooking appliance, like a fixed microwave, wall ovens, or a range, then it is a kitchen.
If it is a kitchen and has a cook top or a range, then a knee space at the sink will be required.
This break room is a kitchen because it has both a range and a fixed microwave oven.  Therefore the sink must have a knee space.  In addition, all appliances must be accessible, and 50% of the shelving must be within reach.  This breakroom should follow section 804 for kitchens.
But if the break room has a built in microwave or oven, then it will still be considered a “kitchen” but now the sink can take the exception and have a parallel approach rather than a front approach.
This break room has a built in oven, but no range or cook top.  This break room is considered a “kitchen”, but can take the exception for the knee space per 606.2

Wet bars and other sinks

According to Exception #1, another location where a knee space at a sink is not required is at wet bars. Wet bars is a place where drinks are mixed.They are typically found either at hotels or sometimes even at waiting rooms.  According to TDLR, a break room is not a wet bar.
This is a wet bar and does not require a knee space
Sinks that are part of a “work” area and only used for work related things,  like a commercial kitchen, teacher’s work room, medical labs etc., are exempted from having to comply.

Need CEUs

If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:

If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Counters at Accessible Kitchens

Tuesday, January 24th, 2017

Accessible Kitchens

Kitchens have certain requirements when it comes to accessibility.  In order to understand the requirements you first have to define what kind of kitchens are required to comply with accessibility standards like the ADA, ANSI or FHA.  The type of kitchens required to comply are ones that are:
  1. Kitchens that are not staffed with employees that have fixed cooking appliances
  2. kitchens located in residential facilities like multi-family housing units, dorms, social service facilities, assisted living facilities or emergency personnel facilities like fire stations used by residents
In kitchens when there are counters facing each other all the standards require a certain amount of distance between the counters, depending what kind of kitchen it is.  The ADA, ANSI and FHA have similar requirements, but this newsletter will describe the small differences that might get us in trouble if we don’t understand them.

What does the Fair Housing Act Design Guidelines require at accessible counters in kitchens?

There are two types of kitchens described in the Fair Housing Act: Parallel or U-Shape.  The parallel or pass through type kitchen requires 40″ between counters.  This is measured between counters not the base cabinet.




A question arises when appliances are located within the counters, like a refrigerator, which extends a bit beyond the counter’s depth.  The guidelines will require that the 40″ clearance be measured at the appliance face, exclusive of the hardware and handles.
The second type of kitchen are “u-shape” kitchens.  The distance between two counters that are facing each other in a u-shaped kitchen is 60″
In the fair housing act design guidelines, there are two exceptions: one where there is a sink with a knee space which then allows the distance between counters to be 40″
And the other exception is when there is a u-shape kitchen but the cook top and the dishwasher are on the same base cabinet at the end of the kitchen.  That configuration requires 64″ in width between the counter

What does the 2009 ANSI design guidelines require?

Just like the Fair Housing Act Design Guidelines, the ANSI Standards also requires 40″ at the face of the base cabinet, counters or applicances at a pass through kitchen.
804.2.1 Pass-through Kitchens. In pass-through kitchens where counters, appliances or cabinets are on two opposing sides, or where counters, appliances or cabinets are opposite a parallel wall, clearance between all opposing base cabinets, counter tops, appliances, or walls within kitchen work areas shall be 40 inches (1015 mm) minimum. Pass through kitchens shall have two entries.
There are two differences between the FHA and  ANSI
a) The clearance is not just between counters, but also between walls and counters.  Below the 2009 ANSI A117.1 figures
b) The second difference is that the ANSI does not stipulate that the clearance should not be measured from the face of the hardware.  
The requirements for the U-Shape kitchen is only for 60″  between counters.  There is no exception for a narrower or wider kitchen.  Below the 2009 ANSI  A117.1 Standard figure.

What does the 2010 ADA Standards for Accessible design require?

Just like the other standards require 40″ at the face of the base cabinet, counters or appliances at a pass through kitchen.  And just like the Fair Housing Act design guidelines, the clearance is measured from the face of the appliance and not from the hardware of the appliance.  Below the 2010 ADA Standard for Accessible Design figures
Advisory 804.2 Clearance. Clearances are measured from the furthest projecting face of all opposing base cabinets, counter tops, appliances, or walls, excluding hardware
And just like the ANSI Standard, the U-shape kitchens only has the 60″ clearance required between counters.  Below the 2010 ADA Standard for Accessible Design figures

Need CEUs

If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:

If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Transient Lodging

Friday, July 1st, 2016

It is summer and it is time to take vacations! As you travel you might stay at hotels or motels. People with disabilities also enjoy traveling and the ADA has requirements for guest rooms in hotels (as well as other type of transient lodging) that will accommodate mobility impairments, visual impairments and hearing impairments as well. This newsletter outlines a few of the requirements for designing transient lodging facilities for people with disabilities.

Guest Rooms with Mobility features

A hotel must have  a certain number of rooms provided with features that people in wheelchairs and other mobility equipment will use.  The number of guest rooms required is based on the total number of guest rooms in the hotel and based on the table below
This table will also tell you how many rooms without “roll in showers” are required.   Once you have more than 50 guest rooms then you will need to provide a roll in shower (and it the number gets greater as the number of guest rooms increase).  When a guest room states that a room should not have roll in showers, then a accessible tub or transfer shower should be provided.
In addition, these rooms must be dispersed by type of rooms, type of beds and type of amenities provided in the room.
Other items that are required for mobility are the following:
1) All doors in the hotel must have a clear width of 32″ min.  Since traveling is a social activity, and people with disabilities would travel with friends and family, they should be able to go “visit” another room.  The clear width makes that possible.  Mobility rooms doors must also meet the requirement in Section 404
2) Living and dining areas within the guest room must be accessible.
3) At least one sleeping area shall provide a clear floor space complying with 305 on both sides of a bed. The clear floor space shall be positioned for parallel approach to the side of the bed.
4) At least one bathroom that is provided as part of a guest room shall comply with 603. No fewer than one water closet, one lavatory, and one bathtub or shower shall comply with applicable requirements of 603 through 610. In addition, required roll-in shower compartments should have a seat within.
This restroom is not compliant due to the fact that there is no enough clearance at the toilet, the mirror is mounted too high and the flush control is located opposite of the transfer side.  There are other issues with the shower.
5) If vanity counter top space is provided in non-accessible guest toilet or bathing rooms, comparable vanity counter top space, in terms of size and proximity to the lavatory, shall also be provided in accessible guest toilet or bathing rooms.
6) Kitchens and kitchenettes shall comply with 804.
7) Turning space shall be provided within the guest room.
8) Where operable windows are provided in accessible rooms for operation by occupants, at least one opening shall comply with 309.
9) Other elements must comply with the standards, such as reach ranges for closet rods, locks, and other fixed elements.

Guest Rooms with Communication features

In addition to mobility features, a certain number of rooms must also provide communication features.  These would be for people that are hearing impaired and visually impaired.  The number of rooms with communication features are found in the table below:
These rooms must be dispersed also by type of rooms.  Only 10% of the communication rooms can also be a mobility rooms.Factors to be considered in providing an equivalent range of options may include, but are not limited to, room size, bed size, cost, view, bathroom fixtures such as hot tubs and spas, smoking and nonsmoking, and the number of rooms provided.
Some other requirements for these rooms are:
  1. Where emergency warning systems are provided, alarms complying with 702 shall be provided in rooms with communication features
  2. Visible notification devices shall be provided to alert room occupants of incoming telephone calls and a door knock or bell. Notification devices shall not be connected to visible alarm signal appliances. Telephones shall have volume controls compatible with the telephone system and shall comply with 704.3. Telephones shall be served by an electrical outlet complying with 309 located within 48 inches (1220 mm) of the telephone to facilitate the use of a TTY

Need CEUs

July 12th: “Applying the ADA and Fair Housing in Residential Facilities” at 11:00 a.m. for the ASID Dallas July Event: Day of CEUs and Happy Hour @ Daltile
August 11th “How Accessible Is your Workplace” Metrocon16  at 3:00 p.m.
August 12th.”How Accessible is your Workplace” Metrocon16 at 7:30 a.m
August 16th: “ADA and Urban Regeneration” at AIA Dallas (Time TBD)
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes

If you want to learn more about these standards, be sure to check out my books:


If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714

Employee Work Areas

Monday, May 2nd, 2016
A work place can be complicated to understanding as it pertains to the requirements for accessibility. Some spaces in work areas are exempted while some require full access.  Because the ADA requires that a person with disabilities is given the same opportunity to seek employment, an employer may not decide that his establishment will not employ persons with disabilities, and therefore will not make the work areas accessible. So what does the ADA require the employer to provide?
This newsletter will  give an overview of what requirements exist in the ADA about work areas and when the ADA Standards apply.

Work Areas

According to the ADA the definition of an employee work area is:
Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.
Work Area Equipment. Any machine, instrument, engine, motor, pump, conveyor, or other apparatus used to perform work. As used in this document, this term shall apply only to equipment that is permanently installed or built-in in employee work areas. Work area equipment does not include passenger elevators and other accessible means of vertical transportation.
Per the 2010 ADA Standards for Accessible Design:
203.9 Employee Work Areas. Spaces and elements within employee work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area.
An example of a work area that only requires an approach, enter and exit would be a janitor’s closet.  Elements within the janitor’s closet such as the faucet for the mop sink will not be required to comply.
An exam room is partially a “work” area and partially a “patient” area.  The area that is only used by the doctor (the sink) will be exempted from having to comply.
Employee work areas, or portions of employee work areas, other than raised courtroom stations, that are less than 300 square feet and elevated 7 inches or more above the finish floor or ground where the elevation is essential to the function of the space shall not be required to comply with these requirements or to be on an accessible route.

This toll booth is less than 300 s.f. and elevated more than 7″ a.f.f. and therefore do not require an accessible route to it or the ability to approach it and enter it.

The Standards sometimes provide additional guidance through “advisories”.  These are NOT requirements, but they are suggestions that might make your design a better one.  Below are some of the advisories on work areas:

Advisory 203.9 Employee Work Areas. Although areas used exclusively by employees for work are not required to be fully accessible, consider designing such areas to include non-required turning spaces, and provide accessible elements whenever possible. 

Under the Title I of the ADA, employees with disabilities are entitled to reasonable accommodations in the workplace; accommodations can include alterations to spaces within the facility. Designing employee work areas to be more accessible at the outset will avoid more costly retrofits when current employees become temporarily or permanently disabled, or when new employees with disabilities are hired. 


In addition to approach, enter and exit, the employee work area shall also comply with the following sections of the ADA Standards: 206.2.8, 207.1, and 215.3. These will be explained in detail below.

206.2.8 Employee Work Areas. Common use circulation paths within employee work areas shall comply with 402.


The circulation path should meet the requirements for ADA Section 402 which includes a minimum 36″ width along the circulation path.


1. Common use circulation paths located within employee work areas that are less than 1000 square feet (93 m2) and defined by permanently installed partitions, counters, casework, or furnishings shall not be required to comply with 402.2.


This employee work area is less than 1,000 s.f. and therefore the step is allowed

Common use circulation paths located within employee work areas that are an integral component of work area equipment shall not be required to comply with 402.3.

This commercial kitchen has equipment that is an integral part of the work area.  The 36″ min. circulation path in this space is not required to comply due to the location of the work area equipment.

Advisory 206.2.8 Employee Work Areas

Exception 2. Large pieces of equipment, such as electric turbines or water pumping apparatus, may have stairs and elevated walkways used for overseeing or monitoring purposes which are physically part of the turbine or pump. However, passenger elevators used for vertical transportation between stories are not considered “work area equipment” as defined in Section 106.5.


An accessible route/circulation path up to the elevated walkway used to monitor work area equipment is not required to be provided.

Common use circulation paths located within exterior employee work areas that are fully exposed to the weather shall not be required to comply with 402.


A dumpster is considered an extension of a work area.  Although a circulation path within the work area might be required, because the dumpster is located on the exterior and fully exposed to the weather, a circulation path will not be required.

Advisory 206.2.8 Employee Work Areas Exception 1. Modular furniture that is not permanently installed is not directly subject to these requirements


The modular furniture in an open office is not required to be installed so that there is a minimum 36″ width is provided.  They are essentially exempted from having to comply (unless they are permanently attached to the ground or wall)

207.1  Employee work areas are required to have an accessible means of egress per the requirements in the IBC

215.3 Employee Work Areas. Where employee work areas have audible alarm coverage, the wiring system shall be designed so that visible alarms complying with 702 can be integrated into the alarm system.

Employee Areas that are not work related

The requirements thus far have been for areas that are considered part of the “work” areas in a space.  But there are other areas that are also part of an employee area, but are not related to the work they perform.  Those areas that are NOT related to their job description will not be exempted and must comply.  Below are a few examples of areas that might be for employees only, but must be fully compliant with the Standards:

Break Rooms


The sink in this break room and the height of the counter are required to comply.  The microwave shown in this photo is not permanently attached and therefore the reach range is not required to comply.

LEED Showers for employees


Some showers that are accessed through a private office have less requirements.  But if it is a common use shower for all employees to use, then they must comply with section 608

Employee Restrooms


All restrooms including employee restrooms must comply with the requirements in Sections 603-606

Employee Locker Rooms


The lockers as well as the bench in this locker/dressing room must comply with the Standards

Employee dining counters

5% of the dining counter is required to be between 28″-34″ a.f.f. and provide a knee space like the photo above.
Employee parking
Parking that is designated for employees should have accessible spaces as well.
Vocational schools where they teach how to use certain “work area equipment” is not exempted.  Because it is considered a “public accommodation” , the equipment or access to it will have to be provided.  Sometimes that is not reasonable, and at that situation, the school will have to get a variance from TDLR or provide reasonable accommodations for the students with disabilities

Barrier Free Day in Dallas Texas

Experience what it is like to have a disability and be in a work space.  The AIA Dallas Codes and Standards Committee is having their annual Barrier Free Day this May 5th.  If you would like to participate, please sign up today.  If you would like to just get a 1 hr. Barrier Free CEU, join us at the happy hour where participants will share their experience of their day with a disability.
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Need CEUs

May 5th- Barrier Free Day Panel Discussion  5:30-7:30 at the Eberhard 2107 N. Henderson Dallas Tx 75206 1 hr. HSW Barrier Free CEU
May 23-27th  Building Industry Professionals: University of Texas at Arlington 416 Yates Street Arlington, TX 76010
May 24th: Legal and ADA issues of Practicing Architecture at Building Industry Professionals Conference, Arlington Texas
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:

They are available for sale now. (also available as an e-book)

If you have any questions about these or any other topics, please feel free to contact me anytime.

Marcela Abadi Rhoads, RAS #240
Abadi Accessibility
214. 403.8714