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.
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 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.
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:
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.
EXCEPTIONS:
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.
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.
Which projects have to comply?
The Federal Fair Housing Act covers newly constructed multi-family housing projects that are first time occupancy residential. The projects must also have more than four dwelling units. In an a building with elevators, ALL dwelling units must comply with the guidelines. In a building without an elevator, only the first floor units must comply. If the building is only two story units, then none of them must comply.
In addition to the Fair Housing Act, some municipalities have also adopted the ANSI A117.1 for their residential dwelling units. These dictate that a certain percentage must be built as with mobility features (for the mobility impaired) and a percentage with communication features (for the hearing and visually impaired)
Seven Requirements
The Fair Housing Act Guidelines have seven requirements for the covered residential dwelling units. Here is the definitions. This newsletter will just give an overview and will not describe all the details for each requirement. We will plan to explain in more detail in future newsletters:
REQUIREMENT 1
Accessible Building Entrance on an Accessible Route:
Covered multifamily dwellings must have at least one building entrance on an accessible route, unless it is impractical to do so because of terrain or unusual characteristics of the site. For all such dwellings with a building entrance on an accessible route the following six requirements apply.
REQUIREMENT 2
Accessible and Usable Public and Common Use Areas:
REQUIREMENT 3
Usable Doors:
All doors designed to allow passage into and within all premises must be sufficiently
wide to allow passage by persons in wheelchairs.
REQUIREMENT 4
Accessible Route Into and Through the Covered Dwelling Unit:
REQUIREMENT 5
Light Switches, Electrical Outlets, Thermostats and Other Environmental
Controls in Accessible Locations:
All premises within the dwelling units must contain light switches, electrical outlets, thermostats and other environmental controls in accessible locations.
REQUIREMENT 6
Reinforced Walls for Grab Bars:
All premises within dwelling units must contain reinforcements in bathroom walls to allow later installation of grab bars around toilet, tub, shower stall and shower seat, where such facilities are provided.
REQUIREMENT 7
Usable Kitchens and Bathrooms:
Dwelling units must contain usable kitchens and bathrooms such that an individual who uses a wheelchair can maneuver about the space.
Inspector’s Corner
Requirement 1 of the Fair Housing Act states that an accessible entrance is required to the dwelling units. This photo shows three steps up to the stoop which leads to the entrance, and no ramp or lift to get them to the stoop. This unit does not meet the requirement.
Need CEUs
February 24th: “How Accessible is Your Work Space” at
Herman Miller Showroom in Dallas, Texas
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with
SSTL CodesIf you want to learn more about these standards, be sure to check out my books:
Sunday, March 24th, 2013
In the new ADA there are residential scoping and technical guidelines. But these guidelines only deal with Federally funded housing, residences in places of education or social service establishments that have dwelling within. Other residential facilities, do not fall under the ADA, but Fair Housing or Model Codes. There are four types of residential projects, but only two are required to follow the ADA Standards.
- Single Family Housing
- Multi-Family Housing
- Federally funded multi-family housing
- Residential facilities as defined by ADA
This newsletter will explain single and multi-family housing that are not required to meet ADA Standards.
Privately funded Multi-Family Housing
The Fair Housing Act requires that any multi-family project be made accessible to the disabled community. Therefore the owner of a multi-famly property cannot discriminate against a family or individual who is disabled on the grounds that the property is not accessible.
ALL multi-family housing projects are required to be accessible per the Fair Housing Act. This includes apartment complexes, and even condominiums as long as there are four or more units in the property.
Here are the requirements from the fair housing act guidelines:
– At walk-ups (no elevator) ALL ground level units must meet the requirements
– in an elevator building ALL units must meet the requirements
Building code and ADA does have percentages for how many units are required to be fully compliant vs. adaptable, but fair housing does not. Therefore all units must be designed using the minimum guidelines listed below.
There are seven requirements:
1) Accessible building entrance on an accessible route: At least one entrance into the building or unit
2) Accessible and Usable public and common use areas: Places such as parking lots, mail boxes, recreational area, lobbies, laundry areas, community building must be accessible and usable.
3) Usable doors: all doors that allow passage must be wide enough (32″ nominal) and the main entrance must have proper hardware
4) Accessible route into and through the covered dwelling unit
5) Light switches, Electrical outlets, thermostat and other environmental controls in accessible locations
6) Reinforced walls in bathrooms for future installation of grab bars
7) Usable kitchens and bathrooms: Should be designed and constructed so an individual in a wheelchair can maneuver in the space provided. No knee clearances are required
To understand more in detail the requirements, visit the Fair Housing Act website or click here for the Design Manual
Single Family Housing
Single family homes, duplexes, triplexes and multi-story townhouses are not required to be accessible by any accessibility standards. Therefore any single family home development are essentially exempted from having to be accessible to the disabled.
A new movement called “Aging in Place” are advocating for remodeling or retro-fitting homes in order to make them more usable to the disabled and more universally designed so that families can stay together as they age. Below are some of the enhancements we did in a kitchen of a family with a disabled mother and son. It is also good for their able body husband.
Before the upgrades:
After the upgrades:
Inspector’s Corner
This was a remodel of a single family home. We installed a pull down shelving which made the shelves within reach range
Click here to watch the video of pull down shelving
For more information
If you want to learn more about the new Standards, The ADA Companion Guide explains the 2004 ADAAG Guidelines with commentary and explanations throughout. The 2004 Guidelines were adopted by the DOJ to create the 2010 Standards and by Texas to create the 2012 TAS. This book explains the technical requirements for both.
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
Monday, December 24th, 2012
The Texas Department of Licensing and Regulation regulates the Architectural Barrier Act and the Texas Accessibility Standards in Texas. They also issue memos that explain certain ambiguous terms and concepts in the Standards. They have issued four so far to explain the 2012 TAS. This newsletter explain them.
TM 2012-01 Electrical Vehical Charging Station
The Technical Memorandum TM 2012-01 has requirements for Electrical Vehicle Charging Station.
Because the US Department of Justice have not issued guidelines for Electric Vehicle Charging station, TDLR decided to create one. So in Texas this is the requirements:
Twenty percent (20%) but not less than one, of each type of charging station in each cluster on a site shall meet the following criteria:
- Controls and operating mechanisms for the accessible charging station shall comply with TAS 309 (no twisting of the wrist and less than 5 lbs to operate) and shall be within the forward reach ranges specified in TAS 308.2;
- The vehicle space(s) with the accessible charging station shall be at least 96 inches wide and shall provide a 36 inch wide (minimum) accessible route complying with TAS 402 on both sides of the vehicle space to allow the user adequate space to exit their vehicle and access both sides of the vehicle. Striping of the accessible routes is recommended but not required.
- Directional and informational signage complying with TAS 216.3 shall designate the location of the accessible charging stations. The symbol of accessibility is recommended but not required.
This figure is just one example. There might be other ways to meet the requirements
TM 2012-02 Emergency Response Building and Facilities
The Technical Memorandum TM 2012-02 explains what to do with facilities for emergency response personnel. This was taken from the US Access Board and DOJ Commentary. There are basically Three type of areas within emergency response facilities:
- Crew quarters that are used exclusively as a residence by emergency response personnel and the kitchens and bathrooms exclusively serving those quarters shall comply with the requirements of 233 (including 233.3.1) and 809 for residential facilities and residential dwelling units.
- All other common use areas, elements, and spaces, including, but not limited to, parking, drinking fountains, public restrooms, meeting and training rooms, and conference rooms, shall comply with the 2012 TAS. Multi-story buildings and facilities shall comply with the accessible route requirements found in 206.2.3 unless exempted by 206.2.3, Exception 2, which states that in a public building that is less than three stories with less than 5 occupants on the upper or lower story, an accessible route is not required.
- Truck bays, workshops, and other employee work areas, elements, and spaces used exclusively by emergency personnel for work shall comply with 203.9 and other provisions of the 2012 TAS applicable to employee work areas which state only approach, enter and exit is required.
TM 2012-03 Shopping Centers and Shopping Malls
The Technical Memorandum TM 2012-03 explains what defines a shopping center or shopping mall and how this affects the elevator/accessible route exception.
The definition of a shopping center is:
a) A building housing five or more sales or rental establishments; or
b) A series of buildings on a common site, either under common ownership or common control or developed either as one project or as a series of related projects, housing five or more sales or rental establishments
If a private building is a shopping center and has more than one story, an accessible route is required, no matter what is going on on the second story.
But there is an exception if it is a retail space in a one story building with a mezzanine.
A free standing store, like Walmart is not a shopping center and therefore a mezzanine may not require an accessible route if it meets all the criteria on 206.2.3 Exception 1 or 206.2.4 Exception 3.
This photo is of a retail story with a second story and it does require an accessible route to the second story.
TM 2012-04 Multi-Story Buildings and Facilities
The Technical Memorandum TM 2012-04 explains what is meant by “square feet” and “per story” in 206.2.3, Exception 1:
- Square Feet. The reference to “square feet” shall mean gross square feet.
- Per Story. The term “story” is defined in 106.5.64 as that portion of a building or facility designed for human occupancy included between the upper surface of a floor or the upper surface of the floor or roof next above. A story containing one or more mezzanines has more than one floor level.
Therefore, based on 106.1 and the indicated meaning of “story”, the reference to “per story” shall also apply to the first story when calculating square footage.
These clarifications have been confirmed by the Department with the U. S. Access Board and do not constitute a substantive change to the compliance requirements of 206.2.3, Exception 1.
Continuing Education Opportunities
New Orleans
4 hr HSW: 2010 ADA and IBC
Please use this link below for registration and details
Little Rock
4 hr HSW 2010 ADA and IBC
Please use this link below for registration and details
If you want to learn more about the new Standards, The ADA Companion Guide explains the 2004 ADAAG Guidelines with commentary and explanations throughout. The 2004 Guidelines were adopted by the DOJ to create the 2010 Standards and by Texas to create the 2012 TAS. This book explains the technical requirements for both.
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
Tuesday, October 23rd, 2012
In the 2010 ADA and the 2012 TAS there are certain elements that require front approach and parallel approach. But not all of those also require for them to be centered along the element. This newsletter will enumerate the one’s that do. Other elements such as lavatories and sinks and operating mechanisms only require forward approach but it is not required to be centered.
Centered Elements
602 Drinking Fountain
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.
611 Washer and Dryer
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.
703 Signage
703.4.2 Location. Where a tactile sign is provided at a door, the sign shall be located alongside the door at the latch side. Where a tactile sign is provided at double doors with one active leaf, the sign shall be located on the inactive leaf. Where a tactile sign is provided at double doors with two active leafs, the sign shall be located to the right of the right hand door. Where there is no wall space at the latch side of a single door or at the right side of double doors, signs shall be located on the nearest adjacent wall. Signs containing tactile characters shall be located so that a clear floor space of 18 inches (455 mm) minimum by 18 inches (455 mm) minimum, centered on the tactile characters, is provided beyond the arc of any door swing between the closed position and 45 degree open position.
This sign has a drinking fountain in front of it, therefore the requirement for a clear floor space centered on the sign has not been met.
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.
904.4 Sales and Service Counters.
EXCEPTION: In alterations, when the provision of a counter complying with 904.4 would result in a reduction of the number of existing counters at work stations or a reduction of the number of existing mail boxes, the counter shall be permitted to have a portion which is 24 inches (610 mm) long minimum complying with 904.4.1 provided that the required clear floor or ground space is centered on the accessible length of the counter.
Playground Transfer Systems
1008.3.1.3 Transfer Space. A transfer space complying with 305.2 and 305.3 shall be provided adjacent to the transfer platform. The 48 inch (1220 mm) long minimum dimension of the transfer space shall be centered on and parallel to the 24 inch (610 mm) long minimum side of the transfer platform. The side of the transfer platform serving the transfer space shall be unobstructed.
Pool Transfer Walls
1009.4.1 Clear Deck Space. A clear deck space of 60 inches (1525 mm) minimum by 60 inches (1525 mm) minimum with a slope not steeper than 1:48 shall be provided at the base of the transfer wall. Where one grab bar is provided, the clear deck space shall be centered on the grab bar. Where two grab bars are provided, the clear deck space shall be centered on the clearance between the grab bars.
1009.4.3 Wall Depth and Length. The depth of the transfer wall shall be 12 inches (305 mm) minimum and 16 inches (405 mm) maximum. The length of the transfer wall shall be 60 inches (1525 mm) minimum and shall be centered on the clear deck space.
1009.5.2 Transfer Space. A transfer space of 60 inches (1525 mm) minimum by 60 inches (1525 mm) minimum with a slope not steeper than 1:48 shall be provided at the base of the transfer platform surface and shall be centered along a 24 inch (610 mm) minimum side of the transfer platform. The side of the transfer platform serving the transfer space shall be unobstructed.
Forward Approach but not centered
The following elements are required to have a forward approach, but do not require it to be centered.
605 Urinals
606 Lavatories and Sinks
902 Dining and Work Surfaces
Parallel Approach bu not centered
The following elements are allowed to have a parallel approach, but do not require it to be centered.
704 Telephones
804 Range or cooktop
Photo: The range can have a parallel approach, but the sink requires a forward approach.
904 Sales Counters
If parallel approach is provided, it requires 36″ in width and 36″ in height plus the same depth as the main counter
Photo 1: This photo is of a service counter/reception desk at a hotel that did not provide the 36″ wide x 36″ high counter
If forward approach is provided, it requires 30″ in width and 36″ in height, plus the same depth as the main counter and a knee and toe space per 306
Photo 2: This counter has provided a lower portion that meets the requirements for the parallel approach. (photo provided by Structures and Interiors)
602 Exception at Drinking Fountains for children
606 Exception at sinks in kitchens without a cooktop or range
Photo: This kitchen has a built in microwave but NO cooktop, therefore it can take the exception for parallel approach at the sink.
606 Exception at Wet bars
606 Exception at lavatories or sinks for children under 5
804 Freezers or Refrigerator in kitchens
Continuing Education Opportunities
November 2- International Facilities Managers Association Convention in San Antonio, Texas
November 7- provided by SSTL Codes 4 hr ADA seminar in Tulsa OK
If you want to learn more about the new Standards, The ADA Companion Guide explains the 2004 ADAAG Guidelines with commentary and explanations throughout. The 2004 Guidelines were adopted by the DOJ to create the 2010 Standards and by Texas to create the 2012 TAS. This book explains the technical requirements for both.
NOTE: Our offices will be closed October 1 and 2nd and again October 8th and 9th for religious observance.
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
Thursday, August 23rd, 2012
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 new 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 that explains when this exception can be taken and when it cannot. This newsletter will explain it as well.
Break Rooms
Does my sink at my 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 “cooking facilities” within, 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.
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 microwave on top of the counter. This is not considered a “fixed cooking facility”, therefore this space is not a ‘kitchen” and the sink will require a knee space.
If our space is not a true kitchen based on the definition, then if there is storage located within, it must comply only with Scoping 225 which says that at least one of the storage units must comply with 811 and be within reach range. This is important, because if we truly have a kitchen, there would be many more requirements associated with them. See the next entry for those.
212 and 804 Kitchens, Kitchenettes and Sinks
Based on the definition we discussed earlier, if the space is truly a kitchen, then certain requirements will be listed in the scoping of the ADA and TAS:
- 5% of sinks but no fewer than one must comply with 606
- And they must follow the technical standards of section 804
Section 804 states that kitchens must follow the following requirements:
- Floor clearances must be provided depending on the configuration of the kitchen
- A work surface in a “residential” kitchen will require an additional knee space not under a sink. To understand about what is considered “residential”, you can read our July edition of our newsletter
- Heights of work surfaces must be 34″ high max above the floor
- Sinks shall comply with 606
- 50% of the shelf space in storage shall comply with 811 (measured in linear feet)
This is an important one! In order for this to be able to be compliant, the shelves must be within reach range. Which means that if a kitchen has upper cabinets and base cabinets, the number of linear feet of shelving must be the same for the non-accessible ones than for the accessible ones. This could be problematic since at the base cabinets there is typically appliance, knee spaces and no shelving.
- Appliances in kitchens must be accessible and follow requirements listed in 804.6
Commercial kitchens are exempted from having to comply with these requirements since they are part of a “work area”
Wet Bars and other Sinks
Another location where a knee space at a sink is not required is at wet bars. Wet bars are defined in our first entry, but it is a place where drinks are mixed. They are typically found either at hotels and other transient lodging places 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
The other sinks that must follow the scoping of 212 and the technical requirements of 606 are common use sinks such as science labs at a school.
But sinks that are not common use, but are part of a work area and are only used for work related activities are exempted as a “work area”. These are located in teacher workrooms, back of bar at a restaurant, or commercial kitchens.
Continuing Education Opportunities
August 9th- Metrocon12 in Dallas Texas “2012 TAS in interior projects”
September 5th- AIA Dallas Procrastinator’s day
September 12th- CSI’s Construct Show at Phoenix Arizona
November 2- International Facilities Managers Association Convention in San Antonio, Texas
If you want to learn more about the new Standards, The ADA Companion Guide explains the 2004 ADAAG Guidelines with commentary and explanations throughout. The 2004 Guidelines were adopted by the DOJ to create the 2010 Standards and by Texas to create the 2012 TAS. This book explains the technical requirements for both.
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
Thursday, July 12th, 2012
TDLR issued a new RAS bulletin for projects that are built in Texas. Here is the link . I also wrote my August newsletter that explains it:
In summary, here is the issue:
The following terms are not defined in TAS, therefore, based on 106.3, definitions provided in collegiate dictionaries, and information received from the U.S. Access Board, they shall have the referenced meanings:
– 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, cooktop, 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 (ie. gas supply or 220V electrical outlets) creates a dedicated shelf or space for the appliance.
For purposes of compliance with 212 and 804, the terms “kitchen” and “kitchenette” shall be used interchangeably.
With Cooking Facilities: A room or space with at least one fixed or built-in cooking facility is considered a kitchen/kitchenette and shall be subject to compliance with 212 and 804. Storage required by 804.5 shall be calculated by linear feet.
Section 212 Kitchens and Kitchennettes:
212.1 General. Where provided, kitchens, kitchenettes, and sinks shall comply with 212.
212.2 Kitchens and Kitchenettes. Kitchens and kitchenettes shall comply with 804.
212.3 Sinks. Where sinks are provided, at least 5 percent, but no fewer than one, of each type provided in each accessible room or space shall comply with 606.
EXCEPTION: Mop or service sinks shall not be required to comply with 212.3.
Section 804 Kitchens
These are the technical guidelines for kitchens in common use spaces, residential dwelling units and transient lodging spaces.
804.5 Storage (in kitchens): At least 50 percent of shelf space in storage facilities shall comply with 811. This is measured in linear feet.
According to TDLR, the photo above would be considered a kitchen with cooking facilities because there is a built in range and built in microwave. Therefore the sink would require a knee space per section 606.2 and be at 34″ high max.
If the same kitchen had a fixed oven only, or a fixed microwave only without a cooktop, then it would still be a kitchen but now the sink would NOT require a knee space.
Without Cooking Facilities: A room or space without a fixed or built-in cooking facility shall be subject to compliance with all applicable provisions of TAS based on the elements provided. 606.2, Exception 1 shall NOT apply to sinks provided in spaces without cooking facilities unless it is a wet bar since this exception is applicable only to kitchen sinks. Storage provided shall comply with 225 and 811.
Section 606 Sinks and Lavatories
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.
Exceptions:
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.
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.
4. A knee clearance of 24 inches (610 mm) minimum above the finish floor or ground shall be
permitted at lavatories and sinks used primarily by children 6 through 12 years where the rim or
counter surface is 31 inches (785 mm) maximum above the finish floor or ground.
5. A parallel approach complying with 305 shall be permitted to lavatories and sinks used primarily
by children 5 years and younger.
6. The dip of the overflow shall not be considered in determining knee and toe clearances.
Section 225 Storage
225.2 Storage. Where storage is provided in accessible spaces, at least one of each type shall comply with 811.
811 Storage
This section describes the techincal requirements for storage in common use accessible spaces including common use, residential and transient lodging. (but they are different than in kitchens which should follow 804.5)
811.1 General. Storage shall comply with 811.
811.2 Clear Floor or Ground Space. A clear floor or ground space complying with 305 shall be
provided.
811.3 Height. Storage elements shall comply with at least one of the reach ranges specified in 308.
811.4 Operable Parts. Operable parts shall comply with 309.
The photo of the sink above shows a sink that is not located at a kitchen as defined by TDLR since there is no “fixed” cooking facility. We see the microwave but it is not fixed. Therefore a knee space is also required at this location.
Wet Bars: A bar used for purposes other than drink preparation is not considered a wet bar.
Summary: Kitchens, Kitchenettes, and Comparable Spaces. This table explains when and how many kitchens are required to comply.
Basically, kitchens and ktichennettes in common spaces, must comply with sections 212 and 804 of the 2012 TAS (as well as the 2010 ADA).
Kitchens at residential facilities must comply with sections 233 and 809
Kitchens at Transient lodging must comply with 224 and 806
Kitchens at work areas do not have to comply. These are commercial kitchens or kitchens used for work purposes.
Some kitchens require a separate work surface with a knee space but only at residential and transient lodging places.
Storage not in a kitchen (such as a break room without a fixed cooking facility) will have to comply with 811 and only one of each kind will have to comply.
Storage in kitchens at residential and transient lodging do have to comply with the 50% rule.
For facilities without cooking facilities within and in common use spaces, residential dwelling units and transient lodging, are not considered kitchens. Therefore if they have a sink they must comply with the requirements for sinks listed in 606.2 and are not subject to Exception No. 1 unless it is a wet bar. They also would not be subject to the storage requirement since they are not kitchens. Break rooms are good examples of such facilities. They are not kitchens because they don’t have a built in cooking facility, but must comply with the requirements for sinks.
Abadi 
