June 2020 Inspector’s Corner

Posted on - Tuesday, June 2nd, 2020

Vertical Diaper Changing Counters

Diaper changing counters have been discussed in several of my past newsletters, from the rules about where to locate them,  to general rules about height and knee clearance. So we are all mostly aware that they must comply with the ADA under “work surfaces” (and why “work” you may ask…well have you ever tried to change a diaper?)…Some of the items that must comply is the reach range of the opening mechanism of the diaper changing counter.  Most  of them have handles that you grab and pull down.

The handle should be no higher than 48″ a.f.f.

Once open, the second thing that must comply is that the counter be no higher than 34″ a.f.f. and have a knee space no lower than 27″ a.f.f.

the counter in the open position should have the top no higher than 34″ a.f.f. and the bottom no lower than 27″ a.f.f.

These work nicely when you are using a horizontal diaper counter.  But what happens when you want to use a vertical diaper changing counter?

Vertical Diaper changing counter

The handle on a vertical counter is shown higher than 48″ a.f.f. in the unit above.  But if they lower it, then the bottom of the counter (when open) will be lower than 27″ a.f.f.

the handle is mounted at 53″ a.f.f.


the top of this counter when open is 37″ a.f.f. and the bottom knee space is 33″ a.f.f.

So unless the manufacturer has a model with a handle mounted lower so that it is able to be mounted within reach and with the proper clearances, it is not recommended to use a vertical diaper changing counter for the accessible counter.

here is a good chart to follow:

Automatic Flush Controls

One of the requirements in the ADA is to have the flush control located on the transfer side of the water closet

Sometimes the water closet has an automatic flush control which does not have the person flush on their own, therefore the location is not dictated. But what happens when the automatic mechanism breaks and the unit has a manual option located in the middle of the water closet? We found this exact condition on one of our inspections.

water closet with automatic flush control located behind the toilet


sign that is broken and to push the button located behind the toilet

There are many issues with this, one being that now the flush control is not located on the transfer side, but also, the fact that to reach for the control you have an obstruction that is likely more than 25″ long which is not within reach range.
If at all possible, when installing automatic flush controls, try to also install the override button on the transfer side.


not sure this ATM meets the reach range required by ADA