24" vs 48" vs 60" deep closet spaces in ADA dwelling units

[Yikes]

Had an interesting discussion with a CASp yesterday regarding depth of small spaces such as closets.

If the door to the closet provides less than a 32" opening (e.g, smaller than a 6' pair of sliding doors), then a person in a wheelchair cannot get into the closet. In that case, the maximum reach-in depth from outside face of wall to back of closet is 24". In practicality, this will only work for hanging clothes if the bypass doors are very thin, such as masonite doors. Thick doors won't leave enough rod space. Another option is to use a pair of swinging doors. Since these doors are not intended for path-of-travel, typical ADAS 404 clearances don't apply.

Next, and this was the interesting part: if you can roll into the closet, then you better not make it deeper than 48", or else you will have to provide a turnaround inside the closet, and make it 60" deep.
Why?
Because ADAS 809.2.1 requires an accessible route connecting all spaces and elements which are part of a residential dwelling unit. So if you go in the closet 48" or less, the back of your 30"x48" wheelchair (ADAS 305.3) is till touching the accessible route in front of the closet door.
If you make it deeper than 48", now the wheelchair goes in further, and it needs a way to turn around, because the closet has become a room in its own right. That means you need a turning circle or T, and you need maneuvering clearances for both sides the closet passage door.

In conclusion, depending on the available closet opening width, the closet either needs to be:

• max 24" deep from outermost face of door/adjacent wall to back of closet, if door opening is less than 32" wide
• max 48" deep if 32" or greater opening is provided, but you don't have space for a turnaround or door clearance inside the closet
• min 60" deep x 60" wide for a closet that is any greater than 48" in depth.

 

[Mr. Inspector]

Which door face do you measure from in the case of two sliding doors?

 

[Yikes]

Rick18071, according to the CASp, you measure out to the furthest obstruction.
As an example:
If you have a closest that's 5' wide, and it has a pair of 30" sliding doors, the opening will be less than 32" wide. (In fact it will more likely be about 26" wide if your idea of accessible door hardware is a handle instead of a recessed cup.) So now, the max. reach is 24" from the front of the wheelchair to the back wall of the closet. What is limiting the position of the wheelchair at a 26" wide opening? Well, it's not only the door face, it's now actually the wall face in the bedroom, or perhaps some trim casing at the opening.

So let's say you decided to install full 1.375" thick bypass doors, with the outer door face flush with the outer wall face, and no trim. What the remaining minimum depth inside of the closet to hang clothes?
24" - 1.375" - 1.375" = 21.25". depth from back of closet wall to innermost face of innermost door.
Now, let's say you use a standard shelf and pole hardware, which sets the pole 12" away form the back wall. That means that your remaining space for 12 the width of a coat hanger is only 9.25". Most coat hangers are around 8.5-8.75". Bottom line: the clothes will hang at an angle, and scrape against the doors.

My takeaway for ADA units is to try and design closets with bypass doors to be at least 6' wide, and if that can't be done, then consider using swinging doors instead.

 

[Paul Sweet]

The 24" reach distance should only be a problem if you hang clothes on pegs on the back wall of the closet. You only have to reach 12" plus the wall thickness to hang clothes on a rod 12" from the back wall.

 

[ADAguy]

Other options:
Consider use of exterior barn doors that the leave the opening flush when opened (allowing for 27" clr vs 24")
Use of hinged rods by Hefele that swing out similar to overcounter shelves in kitchens with pocket doors, (better if use 6' opening with sliders)?
Note that hangers with overcoats are more than 24" wide (duh?)

 

[mjw_accessibility]

The 24" reach distance should only be a problem if you hang clothes on pegs on the back wall of the closet. You only have to reach 12" plus the wall thickness to hang clothes on a rod 12" from the back wall.

What about the shelf that the rod is hanging from? The far end of the shelf has to be within reach ranges too.

 

[mjw_accessibility]

Had an interesting discussion with a CASp yesterday regarding depth of small spaces such as closets.

If the door to the closet provides less than a 32" opening (e.g, smaller than a 6' pair of sliding doors), then a person in a wheelchair cannot get into the closet. In that case, the maximum reach-in depth from outside face of wall to back of closet is 24". In practicality, this will only work for hanging clothes if the bypass doors are very thin, such as masonite doors. Thick doors won't leave enough rod space. Another option is to use a pair of swinging doors. Since these doors are not intended for path-of-travel, typical ADAS 404 clearances don't apply.

Next, and this was the interesting part: if you can roll into the closet, then you better not make it deeper than 48", or else you will have to provide a turnaround inside the closet, and make it 60" deep.
Why?
Because ADAS 809.2.1 requires an accessible route connecting all spaces and elements which are part of a residential dwelling unit. So if you go in the closet 48" or less, the back of your 30"x48" wheelchair (ADAS 305.3) is till touching the accessible route in front of the closet door.
If you make it deeper than 48", now the wheelchair goes in further, and it needs a way to turn around, because the closet has become a room in its own right. That means you need a turning circle or T, and you need maneuvering clearances for both sides the closet passage door.

In conclusion, depending on the available closet opening width, the closet either needs to be:

• max 24" deep from outermost face of door/adjacent wall to back of closet, if door opening is less than 32" wide
• max 48" deep if 32" or greater opening is provided, but you don't have space for a turnaround or door clearance inside the closet
• min 60" deep x 60" wide for a closet that is any greater than 48" in depth.

I know this conversation is a little older, but I wanted to put forth my two cents. I do not claim to be an expert, so take what I say with a handful of salt. I agree that a closet door with a clear width below 32" cannot provide user passage, but that does not necessarily mean it is too narrow for a wheelchair user to maneuver into the closet to reach an item on a shelf or rod from a forward approach. This does not mean that such a closet can be deeper than 24" from the outside surface (alcove conditions would apply to a space deeper than 24", requiring the clear floor space to be 36" wide). However, it "should" mean that the reach range height could be measured as a forward reach (obstructed or unobstructed).

I will be glad to be proven wrong. Hopefully ICC, ADA, or FHA will provide some clarity on this in a future edition of code/design guidelines. I have seen a lot of architects design these reach-in closets to be 24" deep from the back of the closet to the inside of the closet, and the rabbit trail connecting the dots to correct this can be a little confusing.

 

[Yikes]

I know this conversation is a little older, but I wanted to put forth my two cents. I do not claim to be an expert, so take what I say with a handful of salt. I agree that a closet door with a clear width below 32" cannot provide user passage, but that does not necessarily mean it is too narrow for a wheelchair user to maneuver into the closet to reach an item on a shelf or rod from a forward approach. This does not mean that such a closet can be deeper than 24" from the outside surface (alcove conditions would apply to a space deeper than 24", requiring the clear floor space to be 36" wide). However, it "should" mean that the reach range height could be measured as a forward reach (obstructed or unobstructed).

I will be glad to be proven wrong. Hopefully ICC, ADA, or FHA will provide some clarity on this in a future edition of code/design guidelines. I have seen a lot of architects design these reach-in closets to be 24" deep from the back of the closet to the inside of the closet, and the rabbit trail connecting the dots to correct this can be a little confusing.

FHADM page 3.14 shows a "recommended" reach of 18" clear depth (plus closet wall and door thickness = about 24") when the door is less than 32" clear width:


This is a recommendation, not a requirement.

Regarding ADA: I respectfully disagree regarding forward approach to a closet that has less than 32" clear width. ADA 308.2.1 does not show a forward reach that extends beyond the 30x48 front of the wheelchair space. If you can't wheel at least partway into the closet, then only an "obstructed side reach" per ADAS 308.3.2 will work, and the max depth of the reach is 24".
In most closets, there is about 11-12" from CL of rod to nearest obstructing wall:


On closets where you can't roll in, the side reach to a rod might be 18" or so, which is still OK, especially since most people are grabbing the end of the coat hanger, not the rod.

The problem I've had with accessibility inspectors is when it comes to either shelf storage or floor (shoe) storage. They say, "hey what if something gets pushed to the back of the shelf, or falls down towards the back of the closet?"
They have made me put in low walls, angled walls, and other devices to shallow up the horizontal surfaces, ensuring that nothing get pushed out of reach range.

 

[Inspector Clouseau]

FYI, the San Francisco Mayor's Office on Disability created an information sheet covering storage in mobility type units for the purposes of comparability to adaptable type units. The document covers reach ranges and common obstructions surrounding closets and what-not, looks to be a few years old but helpful nonetheless: https://www.sf.gov/sites/default/files/2022-05/MOD-01 Storage Comparability-201009.pdf

 

[Yikes]

FYI, the San Francisco Mayor's Office on Disability created an information sheet covering storage in mobility type units for the purposes of comparability to adaptable type units. The document covers reach ranges and common obstructions surrounding closets and what-not, looks to be a few years old but helpful nonetheless: https://www.sf.gov/sites/default/files/2022-05/MOD-01 Storage Comparability-201009.pdf

That is very interesting, thanks!
One of their assumptions is that you can roll fully into, and then back out of, a closet that is greater than 48" deep.


The problem is, if the closet is deeper than 48", then it is deep enough for the door to be closed behind the wheelchair, thus many CASps treat this as a "room". ADAS/CBC 11B-809.2.1 requires all rooms in a mobility accessible dwelling unit to be on an accessible route, and ADAS/CBC 11B-809.2.2 requires all such rooms to have a full turning space (60" circle or 60" T-turn) per ASAD/CBC 11B-304.

So any closet deeper than 48" but less than 60" is problematic. Even 60"+ closets can be problematic if you are purposefully designing clothes rods that will hang clothes into the turning space.

 

[Sifu]

Similar question. Not in a group R, but in an A2. Consider a liquor storage room. Approximately 7'wx5'd, with shelves that wrap around the interior, resulting in a space that is 5'wx3'9"d. This is an employee workspace, so it must be accessible to enter and exit. If a user entered and the door closed bejhind them then a turning space would be required. But can they enter? If the door was scheduled without a closer (it is scheduled with one) would that be enough? Or, why would this not be a simple accommodation to remove the closer?

 

[jc_ks]

Or, why would this not be a simple accommodation to remove the closer?

A liquor storage room likely requires a lock and removing the door may not be considered a reasonable accommodation.

 

[Yikes]

Similar question. Not in a group R, but in an A2. Consider a liquor storage room. Approximately 7'wx5'd, with shelves that wrap around the interior, resulting in a space that is 5'wx3'9"d. This is an employee workspace, so it must be accessible to enter and exit. If a user entered and the door closed bejhind them then a turning space would be required. But can they enter? If the door was scheduled without a closer (it is scheduled with one) would that be enough? Or, why would this not be a simple accommodation to remove the closer?

I wonder if you could treat the entire liquor storage itself as a type of unique “employee workstation”, similar to how walk-in commercial freezers are often treated. If so, the common path-of-travel terminates at the face of the door and the locked liquor storage is not required to be accessible.

 

[Sifu]

I didn't ask about removing the door, only the closer. If there is a closer and the user could enter the room completely and the door closes behind them then they would have no way to turn and re-open the door. I have used this thought process before, and this room may be big enough that this could happen.

 

[Sifu]

I wonder if you could treat the entire liquor storage itself as a type of unique “employee workstation”, similar to how walk-in commercial freezers are often treated. If so, the common path-of-travel terminates at the face of the door and the locked liquor storage is not required to be accessible.

I read a bunch of other posts that say the same thing, some with your input. I do consider the liquor storage room to be an employee workspace, but considered the requirement that the user be able to approach enter and exit the space. The conundrum is if the user can "enter" the space. I read the opinions that the path of travel terminates at the face of the door, but I'm not sure about that. If this were a larger room, like an office I don't think that would apply so I'm not sure it would here. Is there an IBC path that gets me to this? If this were a smaller room, like a closet and the user couldn't enter completely I wouldn't think this is a problem. It is a liquor "closet", maybe just big enough to enter completely, but it seems a bit too far to make it accessible from the inside when it is highly unlikely that would ever happen.

 

[Yikes]

Sifu, I don't know about IBC. Here in California, our accessibility code is based on the 2010 ADA standards, not the IBC, so I'm mainly versed in those and will respond accordingly, in hopes that IBC has some similar overlap. Apologies in advance if you've already covered this.

From ADAS Chapter 1 definitions:

• 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.

In my experience with liquor storage and bars, restaurants, lounges and other assembly areas, the secured liquor storage is definitely used only by qualified employees and only for securing items that are commercially regulated by law (alcohol). Therefore I agree with you that the closet is an employee work area, and would label the closet "Employee Work Area: Regulated Liquor Secured Storage" on the plans, in case there was any future confusion.

In 2010 ADAS for employee work areas, the only accessibility scoping requirement is for a "common use circulation path":

206.2.8 Employee Work Areas. [1] Common use [2] circulation paths within [3] employee work areas shall comply with 402.​

So it has to hit all three of these features in order to be required to have an accessible route within the space.

Going back to Chapter 1 definitions:

Common Use. Interior or exterior circulation paths, rooms, spaces, or elements that are not for public use and are made available for the shared use of two or more people.​

So, looking at your particular situation, the next question is whether the circulation area is for 2 or more people:

Consider a liquor storage room. Approximately 7'wx5'd, with shelves that wrap around the interior, resulting in a space that is 5'wx3'9"d.

In my opinion, the liquor storage area with a circulation space of only 18.75 SF is intended for use by only one person at a time. Therefore the circulation space is not "common use" and therefore it doesn't need to comply with ADAS 402 "accessible routes". The "common use circulation path" for employees terminates at the face of the door into the liquor storage. If necessary, I would add on the plans a callout to this space which says: "Note: NOT a common use circulation path", just so everyone can understand the code analysis / intent.

 

[Sifu]

So maybe this is the difference.

IBC 1103.2.2 tells us that employee work areas must comply with 1104.3.1....[here is the difference] AND shall be designed and constructed so that individuals with disabilities can approach, enter, and exit the work area.

The "approach" is fine, the "enter" is murky, the "exit" is not good if they "enter".

"Enter" is murky because I don't know of a codified dimension for when something can be entered, and whether it would include knee and toe space. If they can enter, and if the door can close, then they have no way to "exit".

The "approach, enter and exit" is subjective code. I have given my opinion of subjective code before, so I'll save it. But the code giveth, so maybe I will subjectively say the work space can't be entered, therefore it is not required to be exited.

Subjectively speaking.

Definitely too small for two people to work, unless they were doing something other than looking for tequila.

 

[Yikes]

OK, so the murky words are "enter" and "exit".
Let's try another thought experiment: Let's say you didn't need that much liquor storage, and closet floor space is only 2' or 3' deep from the outside face of wall at the door. The 48" long wheelchair can roll into the closet, but only partway - -the back wheels are still sticking outside of the doorway.

• Does this mean the wheelchair never fully entered the closet?
• If "yes", that means no commercial area can ever have a closet shallower than 4' without violating the IBC 11 requirement for "entering" an employee work area?
• If "no", then it means for any closet smaller then 48" deep, entry is accomplished by rolling in and backing out, no turnaround space needed.

Furthermore even if this wasn't an employee work area, chances are that the shelving close to the door will meet the 5% accessible requirement in 1109.9 without the wheelchair rolling fully into the closet.