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.

 

[Sifu]

Another struggle with "work surface". Given an office with a few lower cabinets. The surface is used for office supplies, printers, etc. But it is also open to and usable by the public and would include documents such as brochures. Would a portion of this be required to be 34" max.?

 

[arwat23]

Another struggle with "work surface". Given an office with a few lower cabinets. The surface is used for office supplies, printers, etc. But it is also open to and usable by the public and would include documents such as brochures. Would a portion of this be required to be 34" max.?

Yes. Its common use space, not a work surface. Workstations are only used by one or a small number of employees at a time. On top of that, if the public interacts with it, then it's definitely not a work surface.

Edit: Ignoring the "how many people" use it part (because now that I think about it that may not be applicable here), the public has access to it, so any work surface exceptions don't apply to the publicly accessible portions.

 

[Blazer]

If there is no table in this conference room provided as the "work surface" then should we be calling it a conference room? A room full of cabinets seems more like a storage room. The table in a conference room is your "work surface" and any cabinetry on the perimeter is just storage. Compliance with ADA 225.2 is required if not an employee work space. If you have a clear floor space and reach ranges for the cabinetry then you will comply even if 36" height. Your permitted a range of 15" min to 48" max to reach storage.

 

[Sifu]

If there is no table in this conference room provided as the "work surface" then should we be calling it a conference room? A room full of cabinets seems more like a storage room. The table in a conference room is your "work surface" and any cabinetry on the perimeter is just storage. Compliance with ADA 225.2 is required if not an employee work space. If you have a clear floor space and reach ranges for the cabinetry then you will comply even if 36" height. Your permitted a range of 15" min to 48" max to reach storage.

View attachment 16524

Not a conference room. This is a sales office. It has a few displays, and 6' of lower cabinets with a top. The cabinets will be for storage, employee only, but the surface may have brochures and such along with a printer/copier. I have a hard time calling it a work surface. The brochures would be for public consumption. If not work surface what requires it to be 34"?

 

[Blazer]

Not a conference room. This is a sales office. It has a few displays, and 6' of lower cabinets with a top. The cabinets will be for storage, employee only, but the surface may have brochures and such along with a printer/copier. I have a hard time calling it a work surface. The brochures would be for public consumption. If not work surface what requires it to be 34"?

There is a "front of house" that provides direct access to this conference room, so it wouldn't be considered an employee work area.

You said per the above that it is a conference room. Now its a sales room. I don't recall a local government anywhere in this country that also operates as a for- profit business. Seems a bit fishy to me, LOL.
I can only suggest that ADA standards sole purpose is to eliminate architectural barriers. Brochures and printers are not built into the building so accessing them is not regulated by ADA chapters 1-10. That is a question for the DOJ.
If there are outlets/switches/controls on the wall above this countertop that are made available to the public then those of course need to be within reach range and of course will fall into Obstructed High Reach at which the "barrier" is the cabinets and should not exceed 34 inches AFF.

 

[Yikes]

I don't recall a local government anywhere in this country that also operates as a for- profit business. Seems a bit fishy to me, LOL.

 

[Sifu]

You said per the above that it is a conference room. Now its a sales room. I don't recall a local government anywhere in this country that also operates as a for- profit business. Seems a bit fishy to me, LOL.
I can only suggest that ADA standards sole purpose is to eliminate architectural barriers. Brochures and printers are not built into the building so accessing them is not regulated by ADA chapters 1-10. That is a question for the DOJ.
If there are outlets/switches/controls on the wall above this countertop that are made available to the public then those of course need to be within reach range and of course will fall into Obstructed High Reach at which the "barrier" is the cabinets and should not exceed 34 inches AFF.

Totally different project. The conference room post was from February, this is just another case of the somewhat subjective idea of a work space. This project is not governmental, it is private. The only outlets on the wall are dedicated to the printer power and data.

 

[arwat23]

Not a conference room. This is a sales office. It has a few displays, and 6' of lower cabinets with a top. The cabinets will be for storage, employee only, but the surface may have brochures and such along with a printer/copier. I have a hard time calling it a work surface. The brochures would be for public consumption. If not work surface what requires it to be 34"?

Why do you want the counter to be more than 34" aff?

 

[Yankee Chronicler]

You said per the above that it is a conference room. Now its a sales room. I don't recall a local government anywhere in this country that also operates as a for- profit business. Seems a bit fishy to me, LOL.
I can only suggest that ADA standards sole purpose is to eliminate architectural barriers. Brochures and printers are not built into the building so accessing them is not regulated by ADA chapters 1-10. That is a question for the DOJ.
If there are outlets/switches/controls on the wall above this countertop that are made available to the public then those of course need to be within reach range and of course will fall into Obstructed High Reach at which the "barrier" is the cabinets and should not exceed 34 inches AFF.

I'll take it a step further: If there's a printer/copier on the counter -- it's a work surface. And if there are switches or outlets above the counter, it doesn't matter if they are for public use or employee use only -- switches and outlets have to meet accessibility requirements.

 

[Blazer]

I'll take it a step further: If there's a printer/copier on the counter -- it's a work surface. And if there are switches or outlets above the counter, it doesn't matter if they are for public use or employee use only -- switches and outlets have to meet accessibility requirements.

Au contraire, it does matter if its for employees. If its an employee work area, meaning not for the public, then the space is not required to provide accessible elements (such as outlets/switches, sinks, counters, cabinets, built-in desks), only common use circulation paths need be accessible so employees can enter, circulate and exit the room unless the room is less than 1000 square feet per ex #1 of 206.2.8. This is stated by general exception 203.9 of the ADA standards. Nowhere in 203.9 does it require elements, described above, to be accessible. It is always "advised" to provide employees with greater accessibility when possible, such as new construction, but for an existing building its not required even if they are altered or new elements.

 

[steveray]

For reference:

[BE]EMPLOYEE WORK AREA. All or any portion of a space used only by employees and only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.