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Commercial kitchen for public use - accessibility requirements?

nbrooks

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Feb 4, 2025
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1
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New Mexico USA
Does a commercial kitchen used by the general public (for parties, events, whatever) at a county-owned community center need to be ADA-compliant beyond the "employee work area" requirements of the ADA? If so, what are the requirements for that kitchen? It is a commercial kitchen, not a small break area or kitchenette. Thank you!
 
We have designed county-owned community centers.
  1. If it is for use by county employees, or by contractors of the county, then it is treated as an employee work area. In CBC -11B-203.9 typically means an accessible "common use circulation path" to the appliance, but the appliance itself is not required to be accessible. I don't think this path requirement exists in in ADAS or ANSI 177.1, but you'll need to check.
  2. If it is for use by a catering business, then we design it as an employee work area, but even then I don't think that caterers visiting a site have a right under ADA to expect the kitchen to be accessible.
  3. A kitchen intended for use by the general public (example, a family rents the facility for a family reunion and will be prepping food themselves in the kitchen) would need to be accessible under the provisions of ADA 212.1, which refers to 804.
Typically in a commercial kitchen that must be accessible due to public use (#3), the biggest accessibility challenges are control reach range for commercial appliances (such as temperature controls at the top of refrigerators), and the requirement to make 50% of kitchen shelf storage accessible. ADAS 804.5 and 804.6. Extra-large commercial grade waste disposals can be an issue at accessible sinks.

Another problem with commercial kitchens for public use is that they may contain specialized components that are dangerous to untrained users, such as large mixers, slicers, etc.

The way we've worked around this problem is to typically divide the kitchen into at least 2 zones. A "public" zone" and a "non-pubic" zone.
  • The public zone will have basic accessible equipment. An accessible sink, accessible cooktop, accessible oven and microwave, accessible refrigerator, accessible worksurface, etc. 50% of the shelf storage in this area is accessible; typically it is a pantry or open shelving. You need to decide what utensils are intended for public use. All switches are accessible, or are managed via an EMS system.
  • The "non-public zone" will have either the whole area and/or individual components labeled "not for public use" and it will contain the more commercial/ dangerous elements: the 3-basin sink, the mixers, the commercial dishwashers, walk-in refrigerators/freezers, grilles and fryers with Ansul hood, etc. These are treated as employee workstations per #1 and 2 above.
  • Storage of non-food dry goods, such as paper plates and cups, is placed in a closet marked "general storage", so it is not considered as specifically "kitchen" (food prep) storage. In that scenario, some shelves are accessible, but the 50% storage requirement for kitchens (ADAS 804.5) does not apply.
  • For serving areas, such as pass-thru counters from the kitchen into the community room, coffee urns, etc., they should be accessible (max 34" AFF counter, observe allowable control heights, etc.).
 
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Does a commercial kitchen used by the general public (for parties, events, whatever) at a county-owned community center need to be ADA-compliant beyond the "employee work area" requirements of the ADA? If so, what are the requirements for that kitchen? It is a commercial kitchen, not a small break area or kitchenette. Thank you!
If the kitchen is used by the general public, it needs to be in compliance (all of it) with Title II or Title III of the ADA 2010 standard.
 
I agree with Yikes. There is commercial kitchen equipment for which there is no accessible equivalent. Just the size and weight of many items will exclude a good number of people without disabilities.
 
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