ADA & Utility / Lab Sinks

[Nancy A]

Is there any caveat in the accessibility code that states that accessible clearance is not required at utility/lab sinks, allowing deeper sinks? I cannot find anything and a 5" deep sink is not functional for a lab. Is the only alternative to put in a single accessible sink somewhere?

 

[classicT]

34" - 27" = 7" .... Are you limiting your sink to 5" to give yourself some wiggle room?

No exception in the IBC or A117.1-2009 for lab sinks to not be accessible. As for the number of sinks that must be accessible, see IBC 1109.3 (below)

1109.3 Sinks
Where sinks are provided, at least 5 percent but not less than one provided in accessible spaces shall be accessible.

Exception: Mop or service sinks are not required to be accessible.​

 

[ADAguy]

If you provide it, you must ply. is it a teaching environment?

 

[Nancy A]

Not a teaching environment. Ty J, your assessment is what I have been doing to date - I provide one ADA sink (assuming 1/5%) with the balance being deeper as required. I was just hoping that someone saw a different solution.

I do have an accessible kitchen sink in a separate room, I wonder if that would satisfy my municipality. A bit of a stretch but, stranger things have happened.

 

[steveray]

You may get some additional relief in the employee work area section of Ch. 11 IBC then....

1103.2.2 Employee work areas. Spaces and elements
within employee work areas shall only be required to comply
with Sections 907.5.2.3.1, 1009 and 1104.3.1 and shall
be designed and constructed so that individuals with disabilities
can approach, enter and exit the work area. Work
areas, or portions of work areas, other than raised courtroom
stations in accordance with Section 1108.4.1.4, that
are less than 300 square feet (30 m2) in area and located 7
inches (178 mm) or more above or below the ground or
finished floor where the change in elevation is essential to
the function of the space shall be exempt from all requirements.

 

[Sifu]

Employee work area is my take on it as well. Why would it be any different than a commercial kitchen?

 

[classicT]

Not a teaching environment.

You may get some additional relief in the employee work area section of Ch. 11 IBC then....

1103.2.2 Employee work areas. Spaces and elements
within employee work areas shall only be required to comply
with Sections 907.5.2.3.1, 1009 and 1104.3.1 and shall
be designed and constructed so that individuals with disabilities
can approach, enter and exit the work area. Work
areas, or portions of work areas, other than raised courtroom
stations in accordance with Section 1108.4.1.4, that
are less than 300 square feet (30 m2) in area and located 7
inches (178 mm) or more above or below the ground or
finished floor where the change in elevation is essential to
the function of the space shall be exempt from all requirements.

So if this is not a classroom (my initial impression from the OP), but is a commercial lab setting, then I'd agree with applying Section 1103.2.2. This would permit you to install non-accessible lab sinks with a caveat that if an employee requires an accessibility accommodation, you have to provide per the ADA.

If it were me, I'd note that one cabinet has a 33.5-in finished counter height with removable face (to permit roll-under), and sink to be replaced as necessary if accessible use is required.

 

[ADAguy]

No removeable face in CA per DSA. Agree with accommodation request.

 

[JPohling]

These are employee work areas and do not need to comply. Also these are not kitchens with either a stove or cooktop (cooking appliances) so a side approach is possible.

 

[classicT]

These are employee work areas and do not need to comply. Also these are not kitchens with either a stove or cooktop (cooking appliances) so a side approach is possible.

Work area exemption has been agreed to by most, but can you check out A117.1 Section 606.2 (below) regarding your second statement?

I think if you re-read Exception #1, you would want to revise your opinion on a side approach being possible.



As per the main statement of 606.2, forward approach is required. Exception #1 would only allow a side approach for a kitchen sink where a cook top is not provided. These are not kitchen sinks, therefore Exception #1 does not apply.

 

[JPohling]

Ty. Fully agree with you

 

[michael2020]

If this is in an instructional space, for example, a culinary arts kitchen that requires a deep sink to wash dishes. How do we handle the ADA requirement?

 

[arwat23]

If this is in an instructional space, for example, a culinary arts kitchen that requires a deep sink to wash dishes. How do we handle the ADA requirement?

That would be considered an "employee work area", which isn't explicitly addressed in ADAS (it would probably fall under "reasonable accommodations" requirements under the ADA). IBC addresses this in 1103.2.2, which limits the sections of code that employee work areas need to comply with.

Equipment generally does NOT need to be accessible, but does often need to be on an accessible route.

Edit: If the public uses the sinks, then it isn't a workstation and the sinks will need to be accessible.

 

[michael2020]

Thanks. But, since this is for educational purposes (high school), how do we deal with the equal program access thing?

 

[arwat23]

Thanks. But, since this is for educational purposes (high school), how do we deal with the equal program access thing?

Then it needs to be accessible as required by code. Refer to ADAS 212 for sink requirements.

Program accessibility is a bit beyond my knowledge. But, it would be best if you met the minimum requirement for accessible sinks:
212.3 Sinks. Where sinks are provided, at least 5 percent, but no fewer than one, of each type provided in each accessible room or space shall comply with 606.