Posted on - Monday, February 24th, 2014

Many of my clients get confused about what heights which type of counters must be. There are five type of counters scoped in the ADA Standards: Work surfaces, dining counters, service counters, sales counters and check out counters. Then there are two type of counters that are not scoped: work area counters and non-work area common use counters that do not fall under the other listed.  There are also Food service lines, as well as other portions public side service areas.

This newsletter will explain the different requirements for each type of counter and how the Standards apply.

Dining Counters

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

Section 902 states that at these counters, an accessible portion that are counter that is 30″ min. wide and 34″ maximum high with a forward approach clearance that meets the requirements for ADA 305 and 306 must be provided.



This bar was designed for both sitting and standing to drink, since the stools are not permanent.  An accessible portion would be required here.


This dining counter does not have a lower portion.  If there is not any other fixed counter similar to this one that is at 34″ a.f.f., either they would need to build a new one or lower a portion of this one.


This booth is fixed, but the table is not.  The dining surface is what is required to comply in the 2010 ADA Standards.  Therefore, the table must be bolted down in order to then be in compliance.

Check-out counters

A Check-out counter is a type of sales counter but has different requirements.Section 227.2 requires that a minimum number of check-out counters (as in a grocery store) be provided based on a table 227.2 for each function of the check-out.  So if one check-out is self service, one check-out is full service and maybe one check-out is for a specific department, each one must comply with 904.3.


Section 904.3 explains the technical requirements which states that the approach can be either forward approach per 305.5  (with a knee space) or parallel approach per 305.5 (without a knee space).  Either one is acceptable as long as there is enough room for the solution provided.


For a check out counter, the height of the counter should be no higher than 38″ a.f.f.  If there is an edge protection for the counter, it should not be higher than 2″ above the counter on the aisle side.  The check writing table, if provided, will be considered a “work surface” and must comply with section 902 (which will be explained further down in the newsletter)



The check writing surface must meet the requirements for 902 which will require that the surface be at least 30″ wide
Only the public side of the counter is scoped.  Where the checker stands to work is exempted under Title III of the ADA.  In case that the store hires a person with disabilities, then accommodations will be required.

Sales and Service counters

The scoping section 227.3 states that  at least one of each type of sales and service counter must comply with ADA 904.4.   This type of counter may have either a parallel approach or a forward approach.  Section 904.4 requires that the sales or service counter be no higher than 36″ a.f.f..  The length will depend on the approach.

Service counters are one’s like an information desk or a reception desk where only information is exchanged.


This reception desk has provides a portion of the counter that is provides a forward approach with a knee space as well as the 36″ maximum height and 36″ min length at the accessible portion.


This reception desk is higher than 36″ a.f.f.

A sales counter where the exchange of money for goods or services takes place will be required to comply with 904.4.  Some examples are sales counters at retail stores, or check-out aisles at a doctor’s office.


This sales counter was much higher than 36″ a.f.f.

Both sales and service counters must be no higher than 36″ and depending on whether it is a forward approach or a parallel approach there will be different requirements for the length.  The length for a counter with a parallel approach will be 36″ long.


Although this counter is 36″ high, the length was not 36″ long

If a forward approach is provided, the counter must be at least  30″ wide and no higher than 36″ a.f.f.  A knee and toe clearance must also be provided if it is positioned for a forward approach.


This information counter has a forward approach with a knee space and proper height.

 Non-Employee and Employee Work Surfaces

Another type of counter that sometimes gets missed because of lack of understanding is the “work surface”.  The work surface that is scoped in ADA Section 226 and 902 are the surfaces where non-employees perform a task (“work”).  Surfaces such as the public side of a bank teller station at a bank, the public side of a check-in counter at a hospital or even a diaper changing station are considered non-employee work surfaces.


The public side of the “check in” desk is considered a work surface.  


The diaper changing counter is also considered a “work” surface  


Library study carrels are another example of a non-employee work surface

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



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

More Information

We are celebrating our 10th year of service to the building industry as a Registered Accessibility Specialist!  Mention this newsletter and receive 10% off your next review or inspection.

As of February 1st 2014, the Texas Department of Licensing and Regulation (TDLR) will not be conducting TAS reviews OR TAS Inspections.  All of these will be done by private Registered Accessibility Specialists.

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. 

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