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.

High Obstructed Reach Range over lavatories and Clear floor space requirements

Friday, October 2nd, 2020


This month’s newsletter we are excited to speak to Ms. Marsha Godeaux from TDLR where she will be clarifying a common question they receive. It has to do with the reach range over obstructions and clear floor spaces below the obstruction.

The 2010 ADA Standards and the 2012 TAS (even the 2009 ICC ANSI A117.1) has a requirement that the depth of the clear floor space below an obstruction should equal the high reach range over an obstruction.

308.2.2 Obstructed High Reach. Where a high forward reach is over an obstruction, the clear floor space shall extend beneath the element for a distance not less than the required reach depth over the obstruction.

Therefore if we have to reach to a faucet, or a soap dispenser mounted behind the sink then we are also required to have the same amount of space at the floor directly under the operable part.

And the way we measure the clear floor space is to use the figure showing the toe clearance. The 30″x48″ clear floor space should be measured from the operable part above and must be no deeper than 25″ and no less than 17″.

This sink section shows all the correct knee and toe clearance but it also shows a piece of blocking at the base board which measures 17″. Unless the faucet is also at 17″ from the edge of the counter, this detail does not provide the correct amount of clear floor space under the sink to allow for the reach range to the faucet.

This sink was built in a similar design as the detail with only 17″ of depth at the toe clearance, which was not enough clear floor space for the high reach required to the faucet or the test tube racks or even the outlet behind the sink.

This clear floor space was only 17″

This section shows the relationship between the high reach above and the clear floor space below.

This lavatory has a faucet 20″ from the edge of the counter.

The clear floor space below the lavatory is more than 20″ from the operable part which is compliant.

The reach range at the sink or lavatories should always be a forward approach even though high reach can also be parallel.

So to summarize, the amount of depth required to reach an operable part above a sink or lavatory (such as faucets, soap dispensers, paper towel dispensers, electric outlets etc) should have an equal or greater amount of clear floor space below the operable part.

New parking requirements in Texas

Tuesday, September 1st, 2020


In Texas, Beginning Aug. 1, 2020, a new rule from The Texas Department of Licensing of Regulation relating to markings and signage required for Accessible Parking Spaces went into effect.  Rule 68.104 (Texas Administrative Code) implements House Bill 3163, passed by the 86th Texas Legislature in 2019. The Elimination of Architectural Barriers (EAB) Advisory Committee recommended adoption of the rule during its June 15, 2020 meeting, and it was adopted by the Texas Commission of Licensing and Regulation at their June 30, 2020, meeting.

All projects registered with TDLR on or after August 1, 2020 must comply with the rule, as well as Texas Accessibility Standards requirements related to parking spaces. Any new or alteration construction projects that begin on or after August 1, 2020 (including those that do not meet the $50,000 threshold requiring registration with TDLR), must also satisfy the rule if they include accessible parking requirements. Rule 68.104 is available on TDLR’s Elimination of Architectural Barriers webpage.

Rule 68.104 is available on TDLR’s Elimination of Architectural Barriers webpage.

68.104. Accessible Parking Spaces.

(New section effective August 1, 2020, 45 TexReg 5166)

  • (a) A paved accessible parking space must include:
  • (1) the International Symbol of Accessibility painted conspicuously on the surface in a color that contrasts the pavement;

(2) the words “NO PARKING” painted on any access aisle adjacent to the parking space. The words must be painted:

  1. in all capital letters;
  2. with a letter height of at least twelve inches, and a stroke width of at least two inches; and
  3. centered within each access aisle adjacent to the parking space and;

These images are from California Code Title 24 but it is very close to what TDLR is requiring

(3) a sign identifying the consequences of parking illegally in a paved accessible parking space. The sign must:

  1. at a minimum state “Violators Subject to Fine and Towing” in a letter height of at least one inch;
  2. be mounted on a pole, post, wall or freestanding board;

  1. be no more than eight inches below a sign required by Texas Accessibility Standards, 502.6; and
  2. be installed so that the bottom edge of the sign is no lower than 48 inches and no higher than 80 inches above ground level.
  • (b) A parking space identification sign that complies with Texas Accessibility Standards, 502.6, that includes the requirements in subsection (a)(3)(A) satisfies subsection (a)(3).

This sign complies with TAS 502.6 which is acceptable for the new requirements

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