On May 27th we remember all the Veterans who have sacrificed with their lives to keep our country safe. According to the Journal of Rehabilitation, “It is estimated that for every military personnel that we lose in foreign wars and conflicts, there are at least sixteen wounded, and many will return to the United States with some type of disability”. The Department of Veteran Affairs has facilities to assist those veterans that will need assistance in rehabilitation and treatment. To provide building access, Federal government facilities are required to follow the Architectural Barriers Act (ABA). Because the percentage of disabled persons at VA hospitals is much higher than the percentage of disabled persons in the general population, The VA developed additional standards that we must follow. Those requirements are listed in The VA Barrier Free Design Standards This newsletter will give you some examples of the additional requirements found in the Standards.
Grab bars at toilet compartments
In the technical chapters of the ABA, just like in the ADA, one toilet compartment should be provided for persons in wheelchairs. In addition depending on how many compartments you have in the restroom if you have six or more toilets and urinals, you are also required to provide an “ambulatory” compartment. Both those compartments require that grab bars be installed. The VA also requires a wheelchair compartment and ambulatory when applicable. But in addition to the accessible compartments, every other toilet compartment is required to have grab bars.
In facilities that treat SCI patients, hospitals and long term care facilities the patient toilets must all have pull-down grab bars
The VA requires that its facilities have 1% more parking spaces than the ABA mandates. in addition, in facilities dealing with Spinal cord Injury (SCI) the number of parking spaces will be determined by the number of beds in the facility. 0.2 accessible spaces per Inpatient bed; 0.5 per LongTerm Care bed; 5.6 per Outpatient Exam Room Dedicated for SCI/D patients
The parking spaces also have a slightly different configuration that an ABA parking space. Each parking space must have their own access aisle. They are not allowed to share between cars.
Accessible route differences:
The turning space for VA rooms are bigger than the ABA requires. A turning space must be 6′-0″ rather than 5′-0″ in diameter. There are requirements for Bariatric patients as well which the ABA does not cover or mention.
Carpet padding and cushions are not permitted in a VA facility
Curb ramps are wider than an ABA curb ramp. They must be 4′-0″ min. rather than 3′-0″
The maximum slope that a VA ramp can be is 1:20 (5%). ABA allows a maximum of 1:12 (8.33%)
The door of an elevator has to be 4′-0″ wide rather than 36″ allowed by the ABA
One of the guidelines that seem to be misunderstood is for operable parts. This guideline requires that an accessible operable part have a mechanism that allows for operating or use without tight grasping or pinching, twisting of the wrist, with less than 5 lbs of force and to operate using only one hand.
ADA section 309.4 Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.
Why this is required?
There are persons that don’t have proper use of their hands. People with rheumatoid arthritis for example, or cerebral palsy, have a hard time grasping elements. Also, there are people, like amputees, or people that were born without hands or fingers that cannot operate elements which require tight pinching. In addition, some people with disabilities or older people may not have the amount of strength required to operate an element or activate an operable part if the force required is more than 5 lbs. Therefore, the ADA design guidelines provides rules to assist those people to navigate their environment in an equal manner.
Operable parts on accessible elements, accessible routes, and in accessible rooms
and spaces shall comply with with the standards. There are some exceptions which explain that certain operable parts do not have to comply:
1. Operable parts that are intended for use only by service or maintenance personnel
2. Electrical or communication receptacles serving a dedicated use (like a refrigerator)
3. Where two or more outlets are provided in a kitchen above a length of counter top that is uninterrupted by a sink or appliance, one outletshall not be required to comply
4. Floor electrical receptacles
5. HVAC diffusers
6. Except for light switches, where redundant controls are provided for a single element, one control in each space shall not be required to comply
7. Cleats and other boat securement devices
8. Exercise machines and exercise equipment
9. Operable windows that are only operated by staff and not occupants
There is an advisory that gives us more guidance and explanation;
205.1 General. Controls covered by 205.1 include, but are not limited to, light switches, circuit breakers, duplexes and other convenience receptacles, environmental and appliance controls, plumbing fixture controls, and security and intercom systems.
Operable parts have three requirements:
1) They must be within reach ranges as spelled out in the Section 308
the operable part of the coffee maker must be no higher than 48″ a.f.f.
2) They must have a 30″x 48″ clear floor space to reach the operable part as specified on 305. The clear floor space should have a slope no steeper than 1:48 (2%) in all directions.
the slope at the push button door opener was steeper
3) and the operable part should be the type that will not require tight grasping and twisting of the wrist and no more than 5 lbs, like explained before.
this feminine napkin dispenser operable part requires tight grasping and pulling to operate
this faucet has an operable part that requires graping and twisting to activate
Below are some more examples.
Fire Extinguisher cabinet
I get this question a lot about fire extinguisher cabinets:
“Do we mount the cabinet so that the top of the fire extinguisher is between 15″-48″ a.f.f.?”
The answer is no. The reach range is for “operable parts” of fixed elements. So a fire extinguisher would not be the operable part, but the handle to open the cabinet would be. So one should locate the fire extinguisher cabinet door handle between 15″-48″ a.f.f.
the operable part is the handle to open the cabinet door
Emergency Nurse calling
Another operating mechanism that is confusing is the emergency call button located in medical care facilities and long term care facilities. They are used when a patient or resident needs a nurse. They are typically located next to the toilet and in the shower and they are required to have a string that reaches the floor. The string is used if a patient or resident falls and they need to pull the string if they can’t get up.
this call button has a red lever that can be pushed down with a closed fist which has a compliant operable part
this call button also has a lever that can be pushed down with a closed fist which is a compliant operable part
this call button is only able to be activated by grasping and pulling the string. This would not meet the requirements for accessible operable parts
In order for the call button to be compliant, it must not only have the string, but it should have a second way of calling the nurse which will not require tight grasping and pulling.
Adjustable mechanism at the hand held shower
One of the operating mechanism that is forgotten is the one required to adjust a hand held shower unit.
the hand held unit height can be adjusted using the wheel next to the vertical bar. The wheel requires tight grasping and twisting to
operate it and therefore not a compliant operating mechanism.
Once the height is adjusted, the mechanism to loosen or tighten the adjustable part is not always used again. But the initial action to adjust must meet the requirements. So the adjustable mechanism must also comply.
this mechanism does not require tight grasping to loosen or tighten
this adjustable mechanism requires pinching to loosen
A turning space within a room or space is typically depicted by a dashed circle or a dashed “T”. It is an imaginary space that we allocate for turning by a person in a wheelchair. But it can really be located anywhere within that room or space as long as there is adequate room and no obstructions. There are some restrictions for the turning space, and this newsletter will explain them.
Where are turning spaces required?
A turning space is not required in every space. The ADA requires turning spaces in the following spaces:
1) Toilet and bathing rooms
2) Saunas and Steam rooms
3) Dressing, Fitting and Locker rooms
4) Patient rooms in medical care and long term care facilities
5) Kitchens and Kitchennettes
6) Holding cells
8) All rooms in a residential dwelling unit served by an accessible route (except if that space is less than 30″ wide or deep)
9) Amusement ride loading zones
10) Fishing piers
11) Play components in the same level (or next to a swing)
12) Shooting facilities
ANSI A117.1 also requires turning space at doors in series
Changes in Level at Turning Spaces
Besides the size of the turning space as shown in the introduction, the ADA also requires that the turning space have a stable firm and slip resistant ground surface, no slope greater than 1:48 and no changes in level are allowed.
304.2 Floor or Ground Surfaces. Floor or ground surfaces of a turning space shall comply with 302. Changes in level are not permitted.
EXCEPTION: Slopes not steeper than 1:48 shall be permitted.
But in the same section, there is an advisory that explain “changes in level”
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.
In other words, if you have a change in level that meets the exact requirements in section 303, but doesn’t exceed them, then it is permitted within the turning space.
Below are the figures which illustrate the two changes in level that are permitted within a turning space.
A change in level that is 1/4″ tall is acceptable in a turning space
A change in level that is 1/2″ tall with a beveled edge is also acceptable
So how does this information get applied? One example is a restroom with a roll-in shower.
Can the turning space be partly inside the shower as shown in the image above? What if the shower had a 1/2″ curb? Then can the turning space be partially inside the shower?
The answer is, yes, if the curb meets the requirements of Figure 303.3.
a collapsable curb can be part of a turning space as long as it collapses to 1/4″ max
Need Barrier Free CEUs?
Green CE On Demand Webinar: “Understanding the 2010 ADA Standards for Accessible Design”
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If you want to learn more about these standards, be sure to check out my books:
“The ADA Companion Guide” “Applying the ADA” published by Wiley.
The 2010 ADA Standards for Accessible Design has a section 217 which tells us which telephones are required to comply with the standards. The ones listed are coin-operated public pay telephones, coinless public pay telephones, public closed-circuit telephones, public courtesy phones, or other types of public telephones.
Most people assume the ones that are required to comply are “pay” telephones
But there are many others that are required to comply that we don’t always think about. As the list above explains, not just pay telephones, but also courtesy phones, and “other types”. Other types will also include emergency calling devices.
this is a courtesy phone that is required to be mounted within reach. This one is higher than 48″ a.f.f.
This is an emergency calling device that will require compliance
Requirements for Accessible Telephones
The ADA section 217 states that the telephones and calling devices that are required to comply should follow section 704
Section 704 tells us the following:
1) At least one of the telephones must be designed for the use by people who are in wheelchairs.
a) A 30″x48″ clear floor space must be provided. The clear floor or ground space shall not be obstructed by bases, enclosures, or seats
the clear floor space to approach this phone is less than 36″ wide
There is a fixed seat in front of this telephone
The emergency phone was located over the landscaping next to the concrete pad. This is not considered having a “clear floor space”
This phone is located behind the planter. Even though the planter is not fixed, technically the phone does not have a clear floor space to approach it.
The phone is located behind a table
b) If the clear floor space is positioned for a parallel approach, it should be located as shown in the figure below
c) If the clear floor space is positioned for a forward approach, it should be located as shown in the figure below
c) Operable parts shall comply with 308 and 309. Telephones shall have push-button controls where such service is available.
The operable part on this phone (the push buttons) were mounted higher than 48″ a.f.f.
The button to call the police was mounted higher than 48″ a.f.f.
d) The cord from the telephone to the handset shall be 29 inches (735 mm) long minimum.
This phone had a cord that was 26″ long
2. The telephones should also be designed for the hearing impaired to have the ability to use it. Some telephones are required to provide volume control and TTY (An abbreviation for teletypewriter)
a) All public telephones are required to have volume controls. Volume controls shall be equipped with a receive volume control that provides a gain adjustable up to 20 dB minimum. For incremental volume control, provide at least one intermediate step of 12 dB of gain minimum. An automatic reset shall be provided.
This phone had a volume control device built in on the handset
Most pay phones have volume controls on the cabinet
b) TTYs required at a public pay telephone and shall be permanently affixed within, or adjacent to, the telephone enclosure. Where an acoustic coupler is used, the telephone cord shall be sufficiently long to allow connection of the TTY and the telephone receiver.
some TTY phones are placed on a shelf that is provided on the phone cabinet
Sometimes the TTY is a permanent part of the cabinet
Emergency Calling Devices
Emergency calling devices are not specifically scoped in the 2010 ADA Standards. Some have considered these emergency calling devices to be subject as a two-way communication element if they only allow communication between the called and one party. The standards only address two-way communication systems under 230 and 708 where admittance to a building or restricted space is dependent on the two-way communication system. The closest similar device for these emergency calling devices is a “closed circuit telephone” per the definition section of the standards.
Closed circuit telephones must also comply with the requirements listed above and in section 704. But volume control is not a common feature for these devices. The use of the variance process in Texas is the only way you can achieve compliance. In the ADA there is no variance process and therefore when providing devices that are not fully compliant, you can use “equivalent facilitiation” to achieve compliance and documenting this within the owner’s organization.
The telephones that are required to comply are not just the public pay phones that we are used to seeing in public buildings. There are many more types of telephones that are provided in different facilities that require compliance. Airports, Hotels, schools and other places of public accommodations will provide a “courtesy” or “emergency” phones and will also require compliance with the ADA Standards so that persons with different disabilities can also communicate.
Shower seat installation, location and the effects of shower controls and other elements
Seats are not always required at bathing facilities, but there are some situations that will require showers seats to be added. For instance, a transfer shower always requires a seat. Also, in transient lodging facilities (hotels, halfway houses, dorms), a seat is required not only in transfer showers but also in roll-in showers.
The shower must be permanently attached to the shower and not be movable. The one exception will be at residential facilities which require blocking for future seats.
This article will explain how the seat should be installed and how it affects the location of controls and other elements.
Shower Seat: Scoping
There are two types of showers: Transfer showers and roll in showers. Transfer showers are one’s people with mobility impairment will “transfer” onto. Roll-in showers are the ones that a person in a wheelchair will roll their wheelchair into.
ADA Section 608.4 requires permanent shower seats in transfer showers.
These must be either folding or not folding seat.
The only exception is for residential dwelling units required to comply with ADA (not Fair Housing). Reinforcement in the wall for the future installation shall be provided instead.
Roll-in showers are not required to provide a shower seat per section 608.4. There are two exceptions where seats are required to be provided in roll-in showers:
In social service establishments (i.e. homeless shelters) with more than 50 beds. (per DOJ’s Subpart D of 28 CFR Part 36) AND
In transient lodging guest rooms with mobility features
If a seat is provided in a roll in shower, either by choice or because it is required as stated above, the seat must be permanent and folding. This allows a person to either use the shower as a transfer type with the seat or as a true roll-in-shower without the seat in the way.
The same technical requirements must be provided as in a transfer shower with a seat (see next entry)
This photo shows a folding seat mounted on a roll in shower. The controls are located in the correct location, but there is a grab bar above it. A grab bar should not be provided where the seat is located.
This shower was intended as a roll in shower, but the seat provided is not “folding”, therefore a person in a wheelchair could not roll in and use it easily.
Shower Seats: Technical
Sections 610.3 describes the types of seats allowed at showers. There can be a rectangular seat or an “L-shape” seat:
1) Where a seat is provided, the seat shall extend from the back wall to a point within 3″ of the compartment entry.
This seat did not extend from the back wall to 3″ of the entry
The seat is 9″ away from the entry
Sometimes, the seat is located around a gyp wall and the shower sits back a few inches. So do we consider the wing wall part of the shower when measuring the location of the seat? According to the Texas Department of Licensing, the shower begins at the shower pan and therefore the wing wall is not counted as part of the shower.
This shower seat is located 3″ away from the shower pan which is technically where the shower entry begins. The gyp wall extension is not technically part of the shower. We recommend that if at all possible, you make the shower pan flush with the wall.
2) The top of the seat shall be 17″-19″ above the bathroom finish floor.
3)They can be rectangular meeting figure 610.3.1
This seat is 4″ away from the end wall rather than 1 1/2″ max
4) Or they can be “L-shape” meeting figure 610.3.2
5) The structural strength should be able to sustain 250 lbs of applied force on the seat, fastener, mounting device or support structure.
There are two types of roll in shower configurations allowed by the ADA. The shower seat location in these showers will dictate where the controls and grab bars will be located.
The Standard Roll-in shower with seat:
The alternate shower with a seat. An alternate shower is a combination of a transfer shower and roll in shower, so it is larger in depth than a standard roll-in shower.
The photo above shows an alternate roll-in shower
Depending on where the seat is located, the controls must be located no farther than 27″ away from the seat.
Clear Floor Space
In order to transfer onto the seat, there should be a clear floor space that meets the requirements at 305 parallel to the shower seat. The requirements include the size to be 30″x48″ and that the slope is not steeper than 1:48.
This shower has a ramp transition up to the entry which creates a slope steeper than 1:48 at the clear floor space of the seat
This shower entry into a transfer shower has a sloped entry which would have been acceptable if the clear floor space would have been 30″ deep. The slope begins with that 30″ making the slope steeper than 1:48.
The 2010 ADA Standards states that only stairs that are part of a means of egress must comply with the ADA sections 504 and 505. That means that grand stairs that are typically found in a lobby of an office building, for example, will not have to comply because typically are not part of a means of egress according to the building code.
ADA 210.1 General. Interior and exterior stairs that are part of a means of egress shall comply with 504
This stair is not part of a means of egress and therefore the requirements for nosings, closed risers, handrail shape and extensions do not apply.
What happens when a stair that is part of a means of egress is getting modified or altered?
According to ADA Section 210 Exception #2, in alterations, existing stairs between levels that are already connected by an accessible route (like an elevator or ramp) is not required to comply with 504, except for the handrails. The handrails will have to be brought up to compliance with ADA section 505.
What if you add a new adjoining stair between floors?
A typical scenario that has been occurring in office buildings is that a tenant will take two floors and create a connection within their suite with an adjoining stair.
If the stair did not exist in the space before, and even if the building core has an elevator, an accessible route will be required in the same area. That means that an elevator or wheelchair lift would also would have to be installed in the suite.
It would not be acceptable to make a person in a wheelchair exit the space and find the elevator in the core and then re-enter the space on the upper floor.
The Texas Department of Licensing and regulation wrote a technical memo to explain their position. Click here for the memo
This past year i have received some questions that I thought would be good to share with my readers. I hope you find these useful
is there a requirement in the ADA to always provide a double unit for drinking fountains?
No. The requirement for drinking fountains per section 211.2 is that no fewer than two drinking fountains be provided. If you have just one, you must add a second one. One of the drinking fountains should be for people who use wheelchairs and the second drinking fountain should be for people who cannot bend down and will be standing.
You may use a “hi-lo” unit or you can have them as two separate units. This section also does not require that you provide them in the same place. As long as your count yields 50% for wheel chairs and 50% for standing persons located somewhere in the facility.
this is a hi-lo unit that also has a bottle filler. A bottle filler by itself cannot substitute one of the drinking fountains
In case you are designing for children, you cannot substitute one of the required drinking fountains for a child height drinking fountain. The child drinking fountain will have to be a third one that is provided.
What is the difference between a toilet compartment and a toilet room?
A toilet compartment generally is located in a toilet room where other toilet fixtures are provided as well. They are typically located in a multi-user restroom. What can get confusing is when the toilet compartment partitions are constructed out of gypsum walls instead of the typical metal or plastic laminate partitions.
this is a toilet compartment that is made of walls that go from floor to ceiling
Even if the toilet compartments are made out of gypsum walls that go from floor to ceiling, they are still considered “compartments” and not toilet rooms.
this is a multi-user toilet room with toilet compartments within
A toilet room, on the other hand, has more than just a toilet within. It typically will have a lavatory or sometimes even a shower. A toilet room could also have two water closets, or a urinal and a lavatory. In those scenario, there are other requirements that you must adhere to, such as door maneuvering clearances, and turning space.
this plan shows a toilet room with a water closet and lavatory
Unlike a toilet room, a toilet compartment does not require a turning space within, although door maneuvering clearances will be required.
If a restroom is not a public space per se, but for a worker or staff, are we still required to provide it as accessible?
Yes. 100% of all toilet rooms are required to be accessible. A staff toilet or a non-public toilet are not excempted. There are some exceptions for single user unisex restrooms that are clustered together. Those will only require 50% of them to be accessible. And even private toilet rooms that are accessed by someone’s office only are not fully excempted and must comply with certain requirements. I wrote a newsletter about that if you would like more information.
Is the distance of a double toilet paper dispenser from the edge of the toilet seat measured to the middle of the dispenser as a unit? to the closest roll? or to the furthest roll?
We measure the toilet paper dispenser to the centerline of the double roll.
We are designing in an existing campus that has 4 main buildings on it with 9 parking lots and 1 parking garage. In reading TAS, it says that each parking “facility” shall have its own accessible spaces and that parking “facility” is the same as a parking “lot”. We understand that Lot E (for example) would need its own calculation for ADA spots (223 total = 7 ADA), but you wouldn’t locate them in Lot E, would you? I would think that you would want those 7 spots to be located in Lot B, closer to the buildings. Can we designate them as ADA spots in one Lot for a different Lot?
Their assumption was correct. Even though the ADA and TAS require that each parking facility have its own set of accessible parking spaces, there is also a requirement (208.3.1) that the accessible parking spaces be located on the closest accessible route to the entrance of the building they serve.
There is an exception under 208.3.1 #2 that states that “parking spaces shall be permitted to be located in different parking facilties if substantially equivalent or greater accessibility is provided in terms of distance from an accessible entrance , or entrance fee and user convenience.”
A blind person who uses a cane to find their way, can only detect objects that are located 27″ a.f.f. Any object mounted higher cannot be detected by the cane. So the ADA puts limits on how far an object can project onto the pedestrian circulation path. The ADA under section 307 only allows 4″ of projection onto a path of travel for an able bodied visually impaired person.
This is the ADA figure that shows the limits of objects mounted along a circulation path.
In one of my inspections there were wall mounted TV monitors that were deeper than 4″
Because the TV is in a circulation path to the back door, a person who is visually impaired, might run into it and hurt themselves because they would not be able to detect it.
At the same project, they added glass panels around the TV which acted as a recess. As you can see the TV is surrounded by glass panels.
Without the glass panel we measured 4 1/2″ from the bare gyp to the edge of the TV.
But if you measured from the glass panel to the edge, the TV only projects
3 1/4″ which is then not a protruding object.
5 lbs opening force at Windows
Under Section 309, any operable part must have an opening force no heavier than 5 lbs. Operable windows also have the same requirement. A single hung window is is very difficult to achieve less than 5 lbs of opening force. A third party mechanism like a “Fenestrator” or a “Window Ease” can be used to make the opening force compliant.
A shower, whether it is a transfer shower or a roll in shower, requires a “clear” floor space parallel to to it.
The clear floor space (shown by a dashed rectangle in the figures above), cannot have any changes in level within the space and that it must have a slope no steeper than 1:48 (2%) in all directions within the rectangle.
Recently I inspected two facilities with showers that had sloped entries. Those entries were part of the clear floor space and it did not provide the 1:48 slope required for a person in a wheelchair to safely park their chair parallel to the seat and transfer on.
This photo shows a transfer shower with a clear floor space, but part of the floor space is sloped (as shown in the images below)
This photo shows a level and tape measure at the clear floor space of the shower. Part of the clear floor space was sloping more than 2% (as shown in the image below)
The slope at the clear floor space for the shower was 2.8% (and it varied in different places as you can see by the tile)
this roll in shower also had a sloped entry where the clear floor space should be
The US Access Board created a video to explain how this clear floor space is used by people with mobility aids such as wheelchairs. Click here to view
As you can see by the video, the clear floor space is a crucial component for the ability to maneuver and transfer onto the shower seat.
this transfer shower shows a proper clear floor space
1) No fewer than 2 drinking fountains should be provided in a building (if they are located in the facility). One should be for wheelchair users, and the second one should be for standing persons that cannot bend down. This can be done with one unit like the photo shown below
2) If there are more than two drinking fountains 50% should be for wheelchairs and 50% should be for standing person. If there is an odd number, it is allowed to round down to yield an even number.
3) The drinking fountains do not have to be a single unit (hi-lo), but it can be multiple drinking fountains mounted at the required heights, and they can be distributed throughout the facility.
4) At the wheelchair drinking fountain there should be a floor clearance that has a forward approach and is 30″ wide x 48″ long centered on the unit, like shown in the drawing below. In addition, there should be a 27″ high knee clearance.
Since the clearance underneath the wheelchair drinking fountain must be centered, when there is a lower drinking fountain for wheelchairs next to a drinking fountain for standing persons, the clearance underneath the lower drinking fountain will sometimes be located partially underneath the higher drinking fountain depending on the distance between the two fountains.
The person using the drinking fountain is using not only the space underneath the wheelchair drinking fountain but also part of the space of the higher drinking fountain. Why is this important?
Like in the image above, this drinking fountain is located in a circulation path and it protrudes more than 4″ above the finished floor and since it is higher than 27″ a.f.f. (the high drinking fountain specifically), then it is not detectable by a cane of a visually impaired person.
One solution to correct the protrusion is to install a cane detectable apron underneath the higher drinking fountain which is higher than 27″ a.f.f.
The higher drinking fountain has a cane detectable apron mounted below the leading edge which aligns with the 27″ required knee clearance of the lower drinking fountain.
But sometimes the apron is mounted lower than 27″ a.f.f. This would not be a problem for the high drinking fountain since it is primarily used by standing persons that do not require a knee space to use the fountain. It is, however, a barrier for the person using a wheelchair because now the knee space that it shares with the second drinking fountain has been reduced to less than 27″ a.f.f. and not usable.
The cane detectable apron at the high drinking fountain shown in this photo was lower than the 27″ a.f.f. and it encroaches the knee space at the lower one.
This photo shows both the high and low drinking fountains with cane detectable aprons below it. Both do not have the proper knee clearance because of the apron
When locating a cane detectable apron keep in mind this requirement about the floor space needing to be centered. Any obstruction from the fountain adjacent must not reduce the knee space of the lower fountain.
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