Bottle Fillers vs. Electric Water Coolers

[indyarchyguy]

We have a project in progress where the designer provided space for a single, flush mount bottle filler. This does not project out and situated so that it has accessible reach. It is NOT a hybrid unit (Bottle Filler and EWC), but a single bottle filler unit. An inspector has insisted that two bottle fillers must be provided per the following:

ANSI A117.1 Section 602.4, page 45.
Is says DF spout height for wheel chair accessibility shall be +36” AFF
Is says DF spout height for standing is +38” to +44” AFF.
This cannot be done with only one DF unit.​

I suggest this is not applicable as it isn't an EWC. Thoughts? If I am wrong, I am wrong....

Current Building Code is 2014 Indiana Building Code (2012 IBC w/ IN Amend).

 

[mtlogcabin]

Agree a bottle filler is not a drinking fountain spout so that section is not applicable . However the operating controls and the bottle filling station must be within the reach range requirements for a front or side approach

 

[ADAguy]

You called it, "if provided" and it has operating controls, then it must comply.
Manufacturers did not anticipate the unintended consequences of their product (typical).
DFs are more accessible than BFS's.

 

[indyarchyguy]

Agree a bottle filler is not a drinking fountain spout so that section is not applicable . However the operating controls and the bottle filling station must be within the reach range requirements for a front or side approach

So going back to my original question. If the unit is already mounted for accessibility, and meets the reach requirements, I can't see how I would need to provide two of them at different heights. I think the inspector has taken his interpretation too far.

 

[indyarchyguy]

Thoughts on whether if a bottle filler is supplied that would still demand an EWC installed?

 

[indyarchyguy]

You called it, "if provided" and it has operating controls, then it must comply.
Manufacturers did not anticipate the unintended consequences of their product (typical).
DFs are more accessible than BFS's.

I agree with you on the accessible...client wants them because it is a work out facility and the bottle filling at EWC gets very, very messy in their other locations, hence the reason for a bottle filler. Any reason if this is supplied, we would still be required to supply and EWC as well?

 

[mtlogcabin]

Any reason if this is supplied, we would still be required to supply and EWC as well?

Yes the building code and the plumbing code require drinking fountains, bottle filling stations are not addressed

IBC Table 2902.1 footnote
e. The minimum number of required drinking fountains shall comply with Table 2902.1 and Chapter 11.

 

[Mr. Inspector]

The bottle filler can't replace the drinking fountains, they are still required.

 

[mark handler]

The bottle filler can't replace the drinking fountains, they are still required.

They can In California replace 50% of the DF's

 

[CityKin]

There is a paragraph added in the 2015 IPC that allows water dispensers to replace 50% of the required drinking fountains. The have added definition for water dispenser to include bottle fillers connected to the water supply and bottle water coolers.

"IPC 410.4 Substitution... where drinking fountains are required, water dispensers shall be permitted to be substituted for not more than 50% of the required number of drinking fountains".

 

[steveray]

There are some substitutions allowed, but not the first one (or 2 as it might be)..

 

[ADAguy]

The "key" is "required" number, to be provided.

 

[Sifu]

I am stuck on how to allow a bottle filler to substitute for a drinking fountain. I have an office bldg floor with occ load of 658, so 7 DF required. Per 1109.5.2, if they provide 7, they would need to provide 4 at standing height and 3 at wheelchair height (or vice versa). Would that mean I can substitute any number of those up to 50%, and place them within the reach ranges and approach criteria, fulfilling both standing and w/c heights? So I could have 3 bottle fillers or water coolers, which would serve as either standing or w/c heights and 4 DF at either height?

 

[mark handler]

The plumbing code does not override the accessibility code

 

[mark handler]

Are your water bottle fillers at accessible heights
You can put on cups at the bottle fillers

 

[ADAguy]

The purpose of a DF is a use not requiring a vessel other than your mouth with which to catch the water, operated by an accessible control.
The flow of water is often overlooked for compliance during inspections.
The advent of water bottles (which did not exist until the age of workouts) was not a consideration.
Use of paper cups could be viewed as not meeting LEED criteria.

 

[Sifu]

I have not seen the proposed specs, this was just an inquiry, but I am assuming they are like the ones I have in my office. If so, they have a motion sensor which activates the stream of water. That motion sensor height would be within the reach ranges, but not both the spout heights per code, since there are not spouts. That is part of the question. If I had 4 DF at 38", and 3 bottle fillers within reach ranges as the substitute, would I just make sure the sensor was at 36"? And yes, we can require cups. The alternative is 4 hi-low fixtures, I think they have two right now, so they are asking if they can use those 4 and add 3 bottle fillers to get to the 7 required, and I think they can but I don't know how to apply the accessibility standard. I am wondering if placing those 3 bottle fillers at the appropriate heights would do it. (1 at W/C and 2 at standing or vice versa)

 

[Sifu]

I just checked our bottle filler. The motion sensor is very precise and will only activate when something is directly in front of it. It is set at 42" but the base of the filling area is at 36". So a bottle that is 6" high activates it when it is set on the base, but a 4" paper cup would not, you would need to hlod the cup up to at least 38". I still don't think it is important. The important part of spout heights is that a user must bend down, lean in or otherwise articulate their mouths to get the drink. A bottle filler does not require that so I think they would only need to be within the reach ranges. Not the same as a DF but the code does allow the substitution.

 

[mark handler]

The purpose of a DF is a use not requiring a vessel other than your mouth with which to catch the water, operated by an accessible control.
The flow of water is often overlooked for compliance during inspections.
The advent of water bottles (which did not exist until the age of workouts) was not a consideration.
Use of paper cups could be viewed as not meeting LEED criteria.

"LEED criteria." is not code

 

[ADAguy]

I know that, Only if seeking to achieve LEED points toward certification.

 

[Sifu]

The more I thought about this and the more closely I read all the requirements I came up with this. IBC requires a minimum of two drinking fountains. It then requires that if more than two are provided, then 50% of those must be hi-low. IPC requires a given number by occupancy and load, and allows substitution, so it is the document that would require more than 2. So if it required 8 drinking fountains, but allows 50% to be substituted by bottle fillers then the IPC is requiring 4 drinking fountains be provided, which triggers the IBC to say that 50% of those would be hi and 50% would be low. So on a floor with 800 occupants, 4 drinking fountains (2 hi-low combos) and 4 bottle fillers meet the code. I presented this question and scenario to ICC for interpretation, and they confirmed. They added that the bottle fillers would need to be placed within the operable parts/reach ranges, which I think is easy to enforce.

 

[ADAguy]

It all comes back to "if required/provided" then compliance with code/ADA is required.

 

[Jmb]

The more I thought about this and the more closely I read all the requirements I came up with this. IBC requires a minimum of two drinking fountains. It then requires that if more than two are provided, then 50% of those must be hi-low. IPC requires a given number by occupancy and load, and allows substitution, so it is the document that would require more than 2. So if it required 8 drinking fountains, but allows 50% to be substituted by bottle fillers then the IPC is requiring 4 drinking fountains be provided, which triggers the IBC to say that 50% of those would be hi and 50% would be low. So on a floor with 800 occupants, 4 drinking fountains (2 hi-low combos) and 4 bottle fillers meet the code. I presented this question and scenario to ICC for interpretation, and they confirmed. They added that the bottle fillers would need to be placed within the operable parts/reach ranges, which I think is easy to enforce.

Sifu, I would agree exactly with your intepretation

 

[Sifu]

I think it complies with the scoping requirements as well as the technical requirements, the 2010 ADA has identical scoping and technical requirements. Both documents use "provided".