Accessible Sink in a Medical Office Exam Room

[arwat23]

Do all exam room sink in a "professional office of a healthcare provider" need to provide an accessible forward approach? The project is in California using 2022 CBC.

I'm coming to a different opinion than my coworkers on this. Looking at CBC 11B-223.4 and 11B-805.6, I read this as ALL hand washing fixtures (outside of restrooms and scrub sinks) need to be accessible, and one of these requirements is to have a forward approach. The sinks are installed in cabinets (similar to this visually), and 11B-805.7 says that the counter need to be accessible too.

My coworkers aren't looking at 11B-223.4 but instead are arguing that the cabinets and counters are an "employee work area" and only needs to comply with 11B-215.3, which doesn't have the forward approach requirement. Their argument is that only the doctors and nurses will be using the sink, despite the sink being located in a room where patients will be. Because of this, they argue these are employee work areas and they don't need to comply with 11B-223.4.

I wanted to get some other opinions on this because my coworkers and I aren't budging on this.

 

[RLGA]

I concur that the lavatory would be considered part of the employee work area and would not need to be accessible for a forward approach if it is not for patient use.

Although this ADA.gov website (https://www.ada.gov/resources/medical-care-mobility/) does not mention lavatories or sinks, it does describe what is considered an "accessible examination room." The illustrations show a lavatory in the exam room without a forward approach.

 

[arwat23]

I concur that the lavatory would be considered part of the employee work area and would not need to be accessible for a forward approach if it is not for patient use.

How do you determine that a sink is or isn't for patient use? There's also the sections below that seem, to my eyes, to conflict with this. Can you explain how the lav is a "employee work area" and also how it doesn't need to comply with 11B-805.6?

Although this ADA.gov website (https://www.ada.gov/resources/medical-care-mobility/) does not mention lavatories or sinks, it does describe what is considered an "accessible examination room." The illustrations show a lavatory in the exam room without a forward approach.

CA amended ADAS and included provisions specifically for offices of a healthcare provider. Section 805 is completely rewritten for the state. Those ADA.gov diagrams don't all completely apply to California (I've run into this issue a lot). My concern is the amendments, listed below, seem to conflict with what's required for "employee work areas".

11B-223.4 Professional Offices of Health Care Providers​

Professional offices of health care providers shall comply with Section 11B-805.

11B-805.6 Hand Washing Fixtures, Lavatories and Sinks​

All hand washing fixtures, lavatories and sinks shall comply with Section 11B-606. (11B-606 includes the forward approach requirement).
Exception: Scrub sinks, as defined in California Plumbing Code Section 221.0, shall not be required to comply with Section 11B-606.

11B-805.7 Built-In Cabinets and Work Surfaces​

Built-in cabinets, counters and work surfaces shall be accessible, including: patient wardrobes, nurse stations, administrative centers, reception desks, medicine preparation areas, laboratory work stations, equipment consoles, clean and soiled utility cabinets and storage areas; and shall comply with Sections 11B-225 and 11B-902.

 

[RLGA]

Well, California is special--always has been. Per the sections you provided, I would have to agree that the lavatories in exam rooms are required to have a forward approach in accordance with the "specific provisions" requirement in CBC 1.1.7.2, since the requirements for health care provider offices is more specific than the general requirements for employ work areas.

 

[arwat23]

Well, California is special--always has been.

Yes we are, and it can be headache inducing sometimes haha.

Also, I referenced the wrong section in the original post. My co-workers reference 11B-203.9, not 11B-215.3. Just wanted to correct myself .

 

[arwat23]

Per the sections you provided, I would have to agree that the lavatories in exam rooms are required to have a forward approach in accordance with the "specific provisions" requirement in CBC 1.1.7.2, since the requirements for health care provider offices is more specific than the general requirements for employ work areas.

Out of curiosity, what makes 11B-223.4 more specific than 11B-203.9?

 

[RLGA]

Out of curiosity, what makes 11B-223.4 more specific than 11B-203.9?

Section 11B-203.9 applies to any employee workstation, regardless of the type of employer. It is located under the main heading of 11B-203, "General exceptions," which clearly states that this section includes general provisions.

However, Section 11B-223.4 references the requirements for professional offices of healthcare providers (i.e., Section 11B-805), which has provisions specific to sinks and lavatories. If any of the other special facility requirements include provisions for sinks and lavatories, then those would also be considered more specific. However, if the special facility requirements are silent on sinks and lavatories, the general requirements of Section 11B-203 would then apply.

 

[Sifu]

Given a "mother's room" in a B occupancy. Small room, with counter, sink and and under-counter frig. Two question arise. Using 2017 ANSI 117.1 and 2021 IPC.

1) Is the sink required to be accessible? If so, is a forward approach required (single bowl)? 606.2 allows a parallel approach "at a kitchen sink", but this is not a kitchen...unless from the baby's perspective. If parallel allowed, 2017 appears to not require it to be centered, either by 606.2 nor 804. This is a departure from the 2009 ANSI that required it to be centered for a "kitchen" sink.

2) Is it required to be set 15" min. from the sidewall? The requirement for this in the IPC is under 405.3.1 for lavatories. Neither "sink" or "lavatory" is defined.

 

[walker.t]

1) Is the sink required to be accessible?

Assuming new construction, I would think so, can’t think of an exception to the general requirement that sinks be accessible stated in A117.1 606.1.

"at a kitchen sink", but this is not a kitchen

I would say this qualifies as a wet bar, which allows a parallel approach per A117.1 606.2, Exception 6. The A117.1 commentary makes reference to how “kitchenette-type areas, such as coffee stations in office buildings or wetbars in hotel rooms, there is not typically a need to wash dishes on a regular or extensive basis in this sink; therefore, a side approach is a viable option.”

A117.1-2009 stated that the wet bar parallel approach be centered but that is not in the 2021 version. A117.1-2021 don’t tell us by how much it can be shifted. A117.1 804.5.6 allows the parallel approach to be shifted 24” from the centerline of a refrigerator, so that might be a good number to use as your maximum offset.

 

[Sifu]

So if the sink is required to be accessible, and considered a kitchen sink with a parallel approach permitted, and the parallel approach is not required to be centered on the sink, is there a requirement from the accessibility code that it be 15" min. from the sidewall?

FWIW, I absolutely think it needs to be accessible, but if we consider it a kitchen sink there is no requirement for a forward approach with knee and toe space, therefore no real requirement for a 15" min., unless it is somehow addressed by the IPC (or IBC ch. 29) as a lavatory, but that is grey.

 

[walker.t]

is there a requirement from the accessibility code that it be 15" min. from the sidewall?

From an accessibility standpoint, the only reason I can think that you’d need to set the center of a sink 15” from the finish face of a wall is so you can center a 30” wide clear floor space on the sink.

unless it is somehow addressed by the IPC

A117.1-2021 804.4 Sinks Commentary (partial quote, emphasis added)
Sinks in kitchens shall have knee and toe clearances that allow for a front approach…The centerline of the sink must be a minimum of 15” for compliance with plumbing codes. It is not required that the clear floor space be centered on the sink.

They don’t give a reference in the plumbing code, I’m not familiar with the IPC to add my own comments.

A117.1 804.2.3 commentary shows the below diagram, the commentary is discussing the 40” minimum clearance in kitchenettes, but the diagram calls out 24” minimum to the centerline of the sink for a parallel approach. The commentary then says, “It is recommended that if this option [parallel approach] is chosen that the center of the sink be a minimum 24” from the wall to allow for the kitchen user to reach the faucets, but this is not required.”

 

[mjw_accessibility]

I had been wondering about the position of the CFS for forward approaches. There are several CFS, particularly for parallel approaches, that are required to be centered on the fixture. However, there is no requirement in ADA or ICC A117.1 that requires the CFS for forward approach lavatories to be centered on the lavatory, even though all figures show it centered on the lavatory. This IPC (section 405.3.1) reference was eyeopening, and a bit disappointing.

 

[walker.t]

there is no requirement in ADA or ICC A117.1 that requires the CFS for forward approach lavatories to be centered on the lavatory

U.S. Access Board Technical Guide Toilet Rooms FAQ (emphasis added)
Must the clear floor space at lavatories be centered?
It is advisable, though not required, that the clear floor space be nominally centered on the fixture.

Link to that technical guide is here.

They don’t provide commentary on just what falls within the range of “nominally centered.” I would like to see them state a maximum offset like they do for the side approach for refrigerators and freezers in A117.1-2017 804.5.6.

Here’s the commentary figure from A117.1 showing the front approach, it calls out 15” minimum to the center of the kitchen sink but I can’t find anything in the commentary text that even suggests 15” minimum to the centerline of the sink.



I think that image has an error. It looks like they are providing 30” wide for the clear floor space, but assuming the dashed line to the right of the sink is a base cabinet, and assuming the counter is 25” minimum, then that’s greater than 24” and an alcove condition per A117.1-2017 305.7.2 and the width should be increased to 36”.

 

[arwat23]

I had been wondering about the position of the CFS for forward approaches. There are several CFS, particularly for parallel approaches, that are required to be centered on the fixture. However, there is no requirement in ADA or ICC A117.1 that requires the CFS for forward approach lavatories to be centered on the lavatory, even though all figures show it centered on the lavatory. This IPC (section 405.3.1) reference was eyeopening, and a bit disappointing.

There's no requirement for it to be centered. It's highly advisable to center the clear space - helps lower the likelihood of litigation - but it's not strictly required. If I had to guess, the reason this doesn't exist is due to that 20% hardship exception for path of travel improvements. Allows for some wiggle room when working with existing elements. Just a guess though.

I can’t find anything in the commentary text that even suggests 15” minimum to the centerline of the sink.

In CA (I know you didn't reference CA, but the post was about CA), we're required to have the lav 18" off the side wall measured to the center of the fixture.

 

[e hilton]

What if a doctor or PA or NP who works there is in a wheelchair?

 

[Yankee Chronicler]

In CA (I know you didn't reference CA, but the post was about CA), we're required to have the lav 18" off the side wall measured to the center of the fixture.

But the sink in a medical exam room isn't a lavatory. It's a medical sink.

 

[arwat23]

But the sink in a medical exam room isn't a lavatory. It's a medical sink.

I don't believe that definition or term exists here in CA's building or plumbing codes.

Here, it's a lav as far as I'm aware. The only exception to the 18" rule is if the fixture doesn't need to be accessible (not within Ch 11B scoping) or is a scrub sink (CBC 11B-223.4 and 11B-805.6).

 

[Yankee Chronicler]

I don't believe that definition or term exists here in CA's building or plumbing codes.

Here, it's a lav as far as I'm aware. The only exception to the 18" rule is if the fixture doesn't need to be accessible (not within Ch 11B scoping) or is a scrub sink (CBC 11B-223.4 and 11B-805.6).

The IPC doesn't define "lavatory" or "sink," either, yet the code uses both terms. Webster's dictionary defines "lavatory" as "a vessel (such as a basin) for washing." The word is derived from Latin lavare, which means "to wash." A sink in a medical exam room could certainly fall within this definition, but my working definition of "lavatory" has always been a sink for washing hands.

Since the code doesn't define the terms involved, it's up to the AHJ to decide what it means.

 

[arwat23]

The IPC doesn't define "lavatory" or "sink," either, yet the code uses both terms. Webster's dictionary defines "lavatory" as "a vessel (such as a basin) for washing." The word is derived from Latin lavare, which means "to wash." A sink in a medical exam room could certainly fall within this definition, but my working definition of "lavatory" has always been a sink for washing hands.

Since the code doesn't define the terms involved, it's up to the AHJ to decide what it means.

We don't use the IPC. We use the UPC (CPC), which also doesn't explicitly define either word (kinda... looks like OSHPD / HCAI defines "handwashing fixture" and HCD defines "lavatory" in the CPC, but those definitions usually don't apply to medical offices - yes, our amendments can be unnecessarily confusing).

The California Building Code defines both lavatory and sink in chapter 2. These definitions generally only apply to chapters 11A and 11B (accessibility):

Lavatory​

A fixed bowl or basin with running water and drainpipe, as in a toilet or bathing facility, for washing or bathing purposes. (As differentiated from the definition of "Sink".)

Sink​

A fixed bowl or basin with running water and drainpipe, as in a kitchen or laundry, for washing dishes, clothing, etc. (As differentiated from the definition of "Lavatory.")

Outside of our weird state, yeah, you're probably right.

 

[mark handler]

Depends on licensing? Is it an OSHPA Licensed facility? Do they want to be?

Department of Health Care Access and Information

Office of Statewide Hospital Planning and Development

CODE APPLICATION NOTICE (CAN) Health and Safety Code §129851

https://hcai.ca.gov/wp-content/uplo...cessibility_in_Health_Facilities_121923_A.pdf



SECTION 11B-805 Medical care and long-term care facilities.

11B-805.6 Handwashing fixtures, lavatories and sinks. All handwashing fixtures, lavatories and sinks shall comply with Section 11B-606.

Exception: Scrub sinks, as defined in California Plumbing Code Section 221.0, shall not be required to comply with Section 11B-606.



INTERPRETATION The requirements of Section 11B-606 apply to all lavatories, sinks, and handwashing fixtures for public use, patient use, and employee use, unless otherwise specifically exempted by the code. Lavatories, sinks, and handwashing fixtures are common use areas and therefore, require accessibility.

Exceptions: Scrub sinks (due to impracticality)

Specific workstations (see Section 11B-203.9). This applies only where the sink is the actual workstation. Clinical sinks are workstations and not required to be accessible. Example: A sink used exclusively for cleaning endoscopes. The sink is the actual area where work is performed as opposed to a place where the employee cleans up before and after performing work elsewhere in the room. Knee clearance requirement – All accessibility requirements of Section 11B-606 apply to lavatories, sinks, and handwashing fixtures required to be accessible. Lavatories are subject to Section 11B-306.3.3, Exception 1 which states: “At lavatories required to be accessible by Section 11B-213.3.4, the knee clearance shall be 27 inches high minimum above the finish floor or ground at a depth of 8 inches minimum increasing to 29 inches high minimum above the finish floor or ground at the front edge of a counter with a built-in lavatory or at the front edge of a wall-mounted lavatory fixture.”

This requirement applies to all lavatories. “Handwashing fixtures” are special application “lavatories” and are subject to the exception to 11B-306.3.3. Handwashing fixtures, as lavatories, are not subject to Section 11B- 306.2.3, Exception 1 which states: “The toe clearance shall extend 19 inches minimum under sinks required to be accessible by Section 11B-212.3.” Consequently, handwashing fixtures must have a minimum depth of 17 inches to a maximum of 19 inches in order to comply with the toe clearance requirements. They shall also have a minimum knee clearance of 29 inches at the front of the lavatory with depth and reduction described in Sections 11B-306.3.3 Exception 1 and 11B-306.3.4.