Accessible counter-top

[Sifu]

Existing building, existing conference room with new cabinetry to be installed. Wall and base cabinets, with a counter-top. IBC scopes "standing" space at fixed or built-in counters. ANSI 117.1 has technical requirements for work surfaces with a max. height of 34". The base cabinets with counter-top are 36". I don't think I have seen a proposal for counters higher than 36" so I have never had to think much about it. This is a local government building. There is a "front of house" that provides direct access to this conference room, so it wouldn't be considered an employee work area. Would the counter-top be required to meet the height requirement for 5% of the length? I checked the ADA for this type of facility, and it doesn't mention seating or standing space, just "work surfaces". There is no forward approach, only a parallel approach, but ANSI doesn't seem to permit that either. If they are required to be accessible, the height and approach would be a problem.

The facility also has some "back of house" training rooms, with a small set of cabinets and a sink. The tops and sinks are at 34". This is pretty typical and I have never required an accessible work surface since there is no cooking equipment. It seems like if it is good enough for a counter with a sink, (kitchenette?), it would be good enough for a counter without a sink, but there is a little doubt in my reading of the code.

Seating is easy, standing is a little less clear. I don't think these would be considered as standing spaces. I also don't want to be too elastic in my review for a government building. To me it would seem short-sighted to not provide the top at 34", but I don't regulate short-sightedness.

Would they just be considered storage?

 

[Yikes]

First question to ask: will work be done on this surface?

I know that sounds funny, but the countertop could just be a nice aesthetic way to finish off the top of the base cabinets. Or it could be a display shelf for awards or or artwork, or a place on which to set a flat screen display.

Here's what the Dept. of Justice advises regarding worksurfaces covered under ADA:

 

[Sifu]

No way to answer that, because of how "work" may be defined. I would assume it is largely a space for coffee cups, file folders, maybe some code books, places for people to put their briefcase. Typical building, planning, public works department type stuff done in every conference room. I imagine all "work" of the type I imagine would take place on the conference table. Since it has doors from both the back of house and the front of house, it will be used by the public for meetings with the administrators, inspectors, building officials and planning officials. I don't think it would be required, but I want it as clean as possible since it is a government building. I don't want an applicant angry over an inspection failure due to accessibility to be able to be able to point out that the building department's own building isn't accessible. I do that enough all by myself.

 

[Yikes]

If the counter is used for setting code books, briefcases, etc., then it is a type of storage, not a worksurface, and the upper height can be 46"-48" depending on base cabinet depth (ADAS 308).
If the intent is for people to drink their coffee and eat their food while seated at a table, then even if someone sets their own cup of coffee on the counter to avoid spilling on the documents at the table, it might still be regarded as a shelf.

However, if someone puts a clipboard on the counter with intent to have a sign-in at that location, now it's a worksurface. If someone sets self-service buffet food line there, it might be a worksurface. If someone sets the coffee service (cream, sugar, stirrers) there and expects people to prep their coffee at that location, IMO they made it into a worksurface.

In my opinion, better to plan from the start for 34" height. If it's already in place at 36" and you are out of budget, you will have to manage it so that it doesn't function as a worksurface.