1002.12 Kitchens and Kitchenettes.
Kitchens and kitchenettes shall comply with Section 804. At least one work surface, 30 inches minimum in length, shall comply with Section 902.
Exception: Spaces that do not provide a cooktop or conventional range shall not be required to provide an accessible work surface.
1003 Type A Units
1003.12 Kitchens and Kitchenettes. Kitchens and kitchenettes shall comply with Section 1003.12.
1004 Type B Units
1004.12 Kitchens and Kitchenettes.
Kitchens and kitchenettes shall comply with Section 1004.12.
Although the requirement does apply to all three types of units (Accessible, Type A, and Type B), the application of the new text will mostly affect sleeping units and will have less of an impact on a dwelling unit. This is because it is more common to include a kitchenette within a sleeping unit than it is to see a kitchenette included in an accessible dwelling unit that already contains a kitchen.
When dealing with the Type A units, however, the requirements are not as clear and, depending upon the interpretation, they may even result in those units being more restrictive than the Accessible units for certain requirements. As stated earlier, when dealing with an Accessible unit, Section 1002.12 clearly provides the exception for work spaces and also the reference to Section 804 that will result in the parallel approach to the sink. The Type A unit requirements of Section 1003.12 do not provide an equivalent exception for the work surfaces or for allowing the sink to have a parallel approach. Specifically, the problem can be seen in the work surface requirements of the Type A units where Sections 1003 and 1003.12.3 do not contain an exception similar to that of Section 1002.12. A similar problem also exists with the clearance requirements of Section 1003.12.1 and 1004.12.1, which do not contain an exception similar to that found in Section 804.2. Remember that Type B units do not have a requirement for a kitchen work surface and already allow for a side approach to the sink, so there should not be the same issue for Type B units.
Because of these inconsistencies, users must decide to either be code literal and make the Type A units more restrictive and provide better access than required for the Accessible units, or they must use their judgment to permit the Type A units to use the exceptions that are allowed for an Accessible unit. Because an Accessible unit is considered as the higher level of accessibility, I believe that granting these needed reductions for kitchenettes in Type A units is a reasonable solution even if it cannot be supported by the specific language of the standard.
Significant Changes to the A117.1 Accessibility Standard: 2009 Edition
