Employee Work Areas

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

Work Areas

According to the ADA the definition of an employee work area is:
Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.
Work Area Equipment. Any machine, instrument, engine, motor, pump, conveyor, or other apparatus used to perform work. As used in this document, this term shall apply only to equipment that is permanently installed or built-in in employee work areas. Work area equipment does not include passenger elevators and other accessible means of vertical transportation.
Per the 2010 ADA Standards for Accessible Design:
203.9 Employee Work Areas. Spaces and elements within employee work areas shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the employee work area.
9313ae6d-6478-4008-bd15-efe1aeb8bb3a
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.
b55adaec-54e2-43c0-9587-3a8a65d3d20f
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.
db963206-9b79-4ff6-8189-a45131183d25
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.
1a90ae27-a3b1-4da6-a2a5-73a09bec244c

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. 

696cbb1c-fed3-45d8-9f81-6e06a9ce9dcb

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.

953933fb-ba49-45e5-86a5-7a6d31d3aaae

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.

a931f280-ecd5-4a88-9942-d7177a84dac0

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.
afb1479e-7345-4baa-8418-a514b2fa6d11

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.

59cbdd78-0767-4d0e-ace8-429866af56d2

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.

0aded221-9dcc-4de6-94de-1e9b472a2dac

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

ec099bea-eb49-425c-8789-a75bc6fc0cc3

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

f73b485e-a355-431a-990f-3761b988dcc1

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

be1e16a6-3527-4f50-9d31-6626693d2364

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

1c0ed1ae-7c2d-4d35-9ea9-66db8eb3384d

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

Employee Locker Rooms

9035ade6-9a22-4d44-aa8d-ea7515456b17

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

Employee dining counters

8e1599a6-cc28-40a5-8b2d-a81c309772d9
5% of the dining counter is required to be between 28″-34″ a.f.f. and provide a knee space like the photo above.
Employee parking
43684dac-ccd1-4f0f-a29a-ef34b2c2dd3f
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
e9605fb9-5b9b-4990-b0ec-5d1213775bdb

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.
c3a05777-9605-4094-9b94-0c3a1122f592 (1)

Need CEUs

May 5th- Barrier Free Day Panel Discussion  5:30-7:30 at the Eberhard 2107 N. Henderson Dallas Tx 75206 1 hr. HSW Barrier Free CEU
May 23-27th  Building Industry Professionals: University of Texas at Arlington 416 Yates Street Arlington, TX 76010
May 24th: Legal and ADA issues of Practicing Architecture at Building Industry Professionals Conference, Arlington Texas
If you are interested in Building Code seminars check out my colleague Shahla Layendecker with SSTL Codes
If you want to learn more about these standards, be sure to check out my books:
97c8a80a-9426-4c3d-88fb-ef6213d947126fc8cab3-4989-476b-b86b-d65fdc8c74cc

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
marhoads@abadiaccess.com
www.abadiaccess.com