Counter outlet behind dishwasher in ADA unit

[Yikes]

How do you handle this situation in an ADA mobility accessible dwelling unit (see sample photo below):
- Electrical code requires outlets within 24" of any point along back of counter
- ADA kitchen has a 24" wide dishwasher next to the sink, so it looks like I need a counter outlet behind the dishwasher, right?
- But wait, the dishwashers are designed to be installed into 24" deep cabinet boxes, so the counter is 25" deep.
- ADA limits reach range 308.3.2 to 24", so 25" is too deep
- Can't put an outlet in the backsplash at the sink area, even if I have knee and toe clearance - - besides the hazard, the waste disposal prevents full depth of knee and toe clearance.
- Dishwasher (and new NEC) prevents outlet in face of cabinet
- Dishwasher takes up space where I could normally put a pop-up outlet in the counter

 

[Jean Tessmer-HI]

How do you handle this situation in an ADA mobility accessible dwelling unit (see sample photo below):
- Electrical code requires outlets within 24" of any point along back of counter
- ADA kitchen has a 24" wide dishwasher next to the sink, so it looks like I need a counter outlet behind the dishwasher, right?
- But wait, the dishwashers are designed to be installed into 24" deep cabinet boxes, so the counter is 25" deep.
- ADA limits reach range 308.3.2 to 24", so 25" is too deep
- Can't put an outlet in the backsplash at the sink area, even if I have knee and toe clearance - - besides the hazard, the waste disposal prevents full depth of knee and toe clearance.
- Dishwasher (and new NEC) prevents outlet in face of cabinet
- Dishwasher takes up space where I could normally put a pop-up outlet in the counter



View attachment 14371

205 Operable Parts

205.1 General. Operable parts on accessible elements, accessible routes, and in accessible rooms and

spaces shall comply with 309.

EXCEPTIONS: 1. Operable parts that are intended for use only by service or maintenance

personnel shall not be required to comply with 309.

2. Electrical or communication receptacles serving a dedicated use shall not be required to comply

with 309.

3. Where two or more outlets are provided in a kitchen above a length of counter top that is

uninterrupted by a sink or appliance, one outlet shall not be required to comply with 309.

4. Floor electrical receptacles shall not be required to comply with 309.

5. HVAC diffusers shall not be required to comply with 309.

6. Except for light switches, where redundant controls are provided for a single element, one control

in each space shall not be required to comply with 309.

7. Cleats and other boat securement devices shall not be required to comply with 309.3.

8. Exercise machines and exercise equipment shall not be required to comply with 309.


Reach over counter in kitchen

Only the sink and the work surface must be 34” AFF.

Keep in mind that operable parts associated with the sink or the work surface must comply with the requirements for an obstructed forward reach in 4.2.5. Even if you have a removable cabinet under the sink, it is still a forward reach because the assumption is that if someone needs that knee and toe clearance, the cabinet will be removed. And it is the operable parts that can be no further back than 24” or 25”. The counter can be deeper unless you have outlets on the wall. The outlets can be moved out if the wall is further back.

Sarah Presley

Accessibility Specialist

U.S. Access Board

(202)272-0046

presley@access-board.gov

www.access-board.gov

 

[mark handler]

 

[redeyedfly]

Why do you have residential units using ADA? And if it's under ADA, why are you referencing A117.1?

Often box extensions are used to meet the 24" side reach over the counter.

 

[Sifu]

Here is one opinion, written by an ICC staff member on the subject.

 

[Yikes]

Why do you have residential units using ADA? And if it's under ADA, why are you referencing A117.1?

Often box extensions are used to meet the 24" side reach over the counter.

1. It is public housing, covered under 2010 ADAS 233.3.1.1, and 809.3.

2. I've seen wiremold extension boxes used on retrofit projects. That will technically probably work, but it looks pretty ugly on new construction.

205 Operable Parts

205.1 General. Operable parts on accessible elements, accessible routes, and in accessible rooms and spaces shall comply with 309.

EXCEPTIONS:
3. Where two or more outlets are provided in a kitchen above a length of counter top that is uninterrupted by a sink or appliance, one outlet shall not be required to comply with 309.

That exception #3 will work except for my new construction projects in California, because (yes, once again!) California has eliminated exception #3.

​

 

[redeyedfly]

2. I've seen wiremold extension boxes used on retrofit projects. That will technically probably work, but it looks pretty ugly on new construction.

I've seen it in new construction a lot. This detail is often omitted however. Many developers prefer to install the extensions upon request. That isn't to the letter of the requirements but I believe is very reasonable. It would take far less time to add extensions than to remove the base from a typical "removable front" cabinet.
That probably won't fly in public housing.

 

[wwhitney]

Build out the backsplash everywhere 1" to 1.5", so that the reach distance is only 24"? Or get custom depth lowers, and recess the dishwasher 1" to 1.5" into the wall framing?

Just a thought, my knowledge about these requirements is very little.

Cheers, Wayne

 

[Yikes]

Thanks Wayne. I realize that shallower base cabinets could help, however most dishwasher manufacturers design their appliances to be installed in 24" deep cabinets:


And because we want the dishwasher door to be accessible, it needs a handle that doesn't require grasping or pinching. That handle depth has to be factored as an obstacle in the reach range:

 

[wwhitney]

Thanks Wayne. I realize that shallower base cabinets could help, however most dishwasher manufacturers design their appliances to be installed in 24" deep cabinets.

Right, that's why I mentioned you'd have to build a shallow niche into the wall behind the dishwasher opening to provide the necessary depth. Unless you got lucky and could find a dishwasher that would work with the reduced depth. The one you posted the specs on looks like it would work with a 23" deep space.

But your handle comment I believe means that the discrepancy in reach distance is going to be more than 1", which makes both of my suggestions have more of an impact on other things.

Cheers, Wayne

 

[wwhitney]

FWIW, there are dishwashers that advertise as being "ADA compliant," which I didn't know until I googled accessible dishwasher. Looks like at least some of them have a long recess pocket instead of a projecting handle. And I think they generally support a lower countertop height than the standard 36", requiring only a 32" tall opening. Not sure if some of them are reduced in depth.

Cheers, Wayne

 

[redeyedfly]

FHADM specifically exempts appliance handles from clearance requirements. I don't know if there is any ADA clarification.

 

[SCBO1]

There are drawer receptacles on the market.

Mini-block receptacle extenders with a center screw may give you the 24-inch reach?