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.”