ADA compliant BBQ grill lid?

[Yikes]

Easing into the summer season, I'm trying to ensure that BBQ grills at a public housing project are ADA/CBC 11B compliant. Many charcoal "park" type grills have heavy lids that exceed 5 lbs. opening force. Some have a latching brace that requires 2 hands to unlatch/close the lid, or 2 hands to raise and lower the grill.

California CBC 202 defines "kitchens" as "area with equipment... for cooking of food", which makes the BBQ a type of kitchen appliance per 11B-804.6
Here's how I think it could still be compliant:
11B-804.6.2 exception #1 does not limit the control height, and exception #2 says that bottom-hinged doors do NOT need to comply with max. 5 lb. opening force, pinch/grasping/ one-hand operation, etc.

My question: would you consider the BBQ lid below to be a "bottom-hinged door"? It certainly looks that way when opened.

 

[e hilton]

No. A bottom hinged door would be like a tradition kitchen oven.

 

[mtlogcabin]

Kitchen or Kitchenette [DSA-AC]​

A room, space or area with equipment for the preparation and cooking of food.

No sink, no water, no countertop provided = no preparation can be done therefore not a "kitchen" by definition

It is a charcoal grille. Not an easy grille to use by an able-bodied individual.

 

[Yikes]

No. A bottom hinged door would be like a tradition kitchen oven.

A traditional kitchen oven has a hinge on the bottom when it is in the up position, and when in the down position the hinge is on one side.
The BBQ lid shown in the photo has a hinge on the bottom when it is in the up position, and when in the down position the hinge is on one side.

How is one bottom-hinged and the other is not?

 

[arwat23]

11B-804.6.2 exception 2 doesn't mention anything about the 5lbs requirement. Exception 1 does, but there's no specific requirement for hinge location.

11B-804.6.2 Operable Parts​

All appliance controls shall comply with Section 11B-309.
Exceptions:

1. Appliance doors and door latching devices shall not be required to comply with Section 11B-309.4.
2. Bottom-hinged appliance doors, when in the open position, shall not be required to comply with Section 11B-309.3.

11B-309.3 Height​

Operable parts shall be placed within one or more of the reach ranges specified in Section 11B-308.

11B-309.4 Operation​

Operable parts shall be operable with one hand and shall not require tight grasping, pinching or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.


Edit: I'd say that this is a bottom hinged door in regards to exception 2.

 

[mark handler]

Bottom hinge

 

[e hilton]

View attachment 15695
Bottom hinge

Agree