Bathroom medicine cabinet replacement: is it "substantial alteration"

[Yikes]

See the DOJ commentary below on "substantial alteration", taken from the State of California's Access Compliance Advisory Reference Manual.
I'm working on an old existing public housing project that needs a refresh of the unit interiors due to deferred maintenance. The apartment bathrooms have old surface-mount metal medicine cabinets where the mirrored doors and their hinges are falling apart. The least expensive fix is to replace them with new medicine cabinets.
Question: Are these small metal boxes meant to be included in the USDOJ comment about "replacement of cabinetry" triggering the definition of "substantially altered"?

The current rehab project budget cannot afford to trigger compliance with 11B-233.3.4.2, because the units are multistory townhomes.

 

[RLGA]

In my opinion, no, changing a medicine cabinet would not be considered "replacement of cabinetry."

What I believe they are referring to is the change in millwork cabinets, which could have a significant impact on the use of the bathroom.

However, if replacing medicine cabinets, you need to be cognizant of their location to stay within the required reach ranges.

 

[Yikes]

In my opinion, no, changing a medicine cabinet would not be considered "replacement of cabinetry."

What I believe they are referring to is the change in millwork cabinets, which could have a significant impact on the use of the bathroom.

However, if replacing medicine cabinets, you need to be cognizant of their location to stay within the required reach ranges.

Thanks!
For purposes of documenting it on the plans, I think I will call need to call them "mirrored box" instead of "medicine cabinet".
Hive mind, let me know if you come up with a better term than "box" that doesn't use the word "cabinet".

 

[e hilton]

Vanity mirror unit … ?