Accessible kitchen faucet sprayer?

[Yikes]

ADA / 11B-606.4 requires that kitchen faucets comply with 309 (no tight grasping, pinching, or twisting of the wrist).

But does this also apply to a handheld sprayer accessory? Is the accessory considered a type of "faucet"?

Examples:

1. A sink is supplied with both an accessible faucet and a second, separate handheld sprayer wand. You grasp and pull the wand/handle to make the nozzle point into the sink, and you grasp / press the button on the wand to make the water come out.
The sprayer is also located towards the rear of the sink (check reach depth vs. waste disposal obstruction below).
Question: if the main faucet complies, must the accessory wand also comply? ADA/11B-212.3 only requires 5% of each type of sink to be accessible. Does that imply that only 5% of water-emitting devices at a sink need to be accessible?


2. In this scenario, the wand is integral to the main faucet spout, but it has a button selector for different spray controls. Still requires grasping and pinching to fully depress the button:

 

[walker.t]

But does this also apply to a handheld sprayer accessory?

My opinion on this is that, because the sprayer is part of the kitchen sink, the sprayer must meet the same accessibility requirements as the main faucet.

Is the accessory considered a type of "faucet"?

No, it’s an accessory to a kitchen sink and the kitchen sink is one plumbing fixture. The sprayer doesn’t have controls to regulate the water temperature or pressure, it needs the main faucet. Kind of like a handheld shower sprayer, you have a fixed spray head up high and one down low in a cradle, but all together it’s one plumbing fixture.

if the main faucet complies, must the accessory wand also comply?

I think it should because I am considering the sprayer as a part of the entire kitchen sink plumbing fixture and if part of the plumbing fixture doesn’t comply, the fixture is not accessible.

the wand is integral to the main faucet spout, but it has a button selector for different spray controls.

Is the kitchen sprayer button that much different than an elevator button or the buttons on the front of a vending machine? I’d say it’s OK.

 

[Yikes]

Is the kitchen sprayer button that much different than an elevator button or the buttons on the front of a vending machine? I’d say it’s OK.

There are faucets where the nozzle sets into a rigid sleeve that enables it to function with the push of a button, no grasping required:


There are other nozzles that do not retract into a rigid, but instead permanently dangle down. These are loose, and require grasping in order for the button to depress. Is it "tight" grasping? I don't know. But if I had no opposable digits, I couldn't change the spray control:

 

[walker.t]

rigid sleeve that enables it to function with the push of a button, no grasping required:

Even with this you still might need to grip it. Here’s the kitchen faucet with a pull-out sprayer I have at home:

There’s a black button on each side, it runs through the width of the sprayer so when one side is pushed it pushes the other side out. Buttons are relatively large and easy to push, but the trick is that you have to hold the faucet in place by gripping it between your thumb and fingers, otherwise when you try to push one of the buttons it rotates the neck of the faucet instead of pushing the button in. So if you want to eliminate any grasping you keep pushing until it reaches the limit of travel. Having used this faucet for years I would say it is not accessible because sometimes it requires tight grasping to pull it out because of a design flaw where the O-rings around the base of the sprayer sometimes roll out of their tracks a little and it binds and you have to pull much harder to remove it.

Is it "tight" grasping? I don't know.

Good question. No grasping is required to point it at an angle, but it’s definitely going to flex when you try to push the button so you have to grasp it enough to prevent it from moving. If we’re allowed up to 5 pounds force for an operable part then 5 pounds would be the limit for “tight” grasping I would think, otherwise “tight” is a little subjective.