August 2024:Fixed and Built in Elements
Posted on - Monday, August 5th, 2024The ADA regulations for building access only apply to built-in or fixed elements. Movable furniture and movable equipment (unless scoped in the standards specifically) are not covered by the Standards and do not have any requirements.
Scope of coverage. The 1991 Standards and the 2010 Standards apply to fixed or built-in elements of buildings, structures, site improvements, and pedestrian routes or vehicular ways located on a site.
My colleagues get confused about these requirements, so I am sharing some examples of when these rule can be ambigous and how we can clarify the requirements.
When elements that are not built in or fixed are not required to comply
Movable furniture is not required to comply with the ADA. Even if the furniture is a reception desk, a dining surfaces, or benches. That means that they don’t have any regulations, but they cannot be used as an accessible element that is required.
The image above shows movable tables in a cafeteria at a school. Even though a school is required to provide areas for kids and faculty with disabilities to eat lunch just like everyone else, the fact that these are movable will exempt them from any requirements found in the standards.
The image shown above shows a dining area that is not only movable but raised higher than the ground. But because it is not built in it does not have to be on an accessible route and the table does not have to have a knee space
The image shown above shows movable classroom tables. Since they are not built in, they will not have to be at a certain height or have knee clearance.
The image shown above shows a system’s furniture reception desk with a service counter. Because it is movable, the counter will not be required to comply with the sales and service counter requirements.
Even though the banquette itself is not scoped in the Standards, and even though the tables at this dining area is movable and also not scoped, what is scoped because it is a built in element is the charging outlet that is provided at the banquette. Because that charging outlet is fixed or built in, it will be required to be within reach (15″ min. a.f.f.)
When elements that are not built in or fixed are used to provide cane detection to protruding objects
Movable furniture and elements cannot be used to create cane detection for persons who are visually impaired. Cane detection is required to be permanently available because if the movable element is moved the cane detection will not be there. Below are some examples.
The image shown above shows a movable table below a pendant light. The pendant light is technically located along a circulation path because the table is not considered permanently in the location shown. It could potentially move and therefore the pendant light would be located in the open circulation path.
The pendant light was mounted at 63″ a.f.f. and therefore considered a protruding object.
The image shown above shows movable planters that are being used as cane detection to the open stairs beyond
The image shown above shows movable trash can that is being used as a cane detection for the paper towel dispenser that is protruding onto the circulation path. since the trash can is movable, it cannot be used as cane detection.
Movable elements being used to provide accessibility when a buiilt in or fixed element is not compliant.
Becuse only fixed or built in elements are scoped and have requirements, movable elements cannot be counted as the accessible element instead of the built in element. Below are some examples
In this kitchen, there are two built in microwaves that are mounted higher than the allowable reach range. The owner decided to provide a movable microwave as the accessible element, but as we have explained, this microwave can be moved and not returned, therefore it cannot be used as the “accessible” element.
But in this kitchen there is only a movable microwave and it will not be required to be within reach.because it is not technically there.
The image shown above shows a movable shower seat. If a shower seat is required, it must be built in and not mvable.
The bench shown above is not bolted down and therefore not considered a substitute for the built in enches at the lockers
Which movable elements are scoped and required to comply?
Even though ADA only applies to built in or fixed elements, there are a few elements that are movable but also scoped. Below are some examples:
The image shown above are of washer and dryers. Even thought they are movable, they are also technically built in because it is connected to the wall via venting. But even if they were not, there is scoping for the equipment on section 611.
Even though a beverage dispenser could be considered movable, most of the time it is part of the plumbing and built in by way of the connection of the water line. But even if it wasn’t built in, beverage dispensers are scoped by the standards and requirements are found in section 904.
Exercise equipment are also “movable” but are scoped and have requirements in the standards. The requirmements for Exercise equipment is found in section 1004