Drinking Fountain Substitution

[mp25]

I've read the other threads on this exact topic in this forum, but wanted to approach this from a different angle then previously discussed.

State plumbing code permits substitution of drinking fountain with "bottled drinking water or a water dispensing faucet (water station)." Plumbing code would require 1 drinking fountain or equivalent substitution.

This is strictly an accessibility question.

Plans indicate a water dispenser unit only (no drinking fountains) - automatic sensor is built in that activates the water, when a cup, a bottle or other container is placed under the spout, and has a cool green counter on how many plastic bottles it has saved over its lifetime. The manufacturer, on their spec sheet list "ADA and ANSI 117.1" under Product Compliance listing.

If the dispenser is installed with clear space, the sensor activation is located within reach range and cane detection is provided, are there any accessibility concerns?

The comment from a plan review states that cups are not graspable, therefore a dispenser cannot be used - a hi/low drinking fountain is required.

The argument against this review comment is that the appliance or plumbing fixture, meets the criteria for operable parts, no tight grasping, pinching, twisting of wrist, uses less than 5# to operate (this argument is supported by access boards technical guide on drinking fountains). The argument further states the ADA/ANSI does not regulate cups or containers. It regulates the appliance itself only (the issue of cups/containers was not discussed on the technical guide).

For reference are the definitions:
Operable parts is defined as: Component of an element that is used to insert or withdraw objects, or to activate, deactivate or adjust the element.
Element is defined as: An architectural, mechanical (including plumbing), or electrical component of building, facility, space, site or public right of way.

Thoughts?

 

[Yankee Chronicler]

What code? You haven't said what jurisdiction the project is located in.

 

[ICE]

The argument further states the ADA/ANSI does not regulate cups or containers. It regulates the appliance itself only (the issue of cups/containers was not discussed on the technical guide).

A kitchen stove-top comes to mind. All of the features of the appliance can meet accessibility requirements except the handle on a frying pan. The difference here is that a stove-top is not required by code whereas a drinking fountain is required by code. However, this dog has a tail and the code allows for a substitution that provides "equivalency." The examples of bottled water and this appliance are equivalent in that they provide water but they fall short of meeting the same accessibility that a low fountain can provide.

The result of substituting the appliance in place of a required drinking fountain is that certain disabled people would not be provided a required drink of water. That will not fly.

Of course I am not an accessibility specialist and have no idea what codes that you are dealing with. But this is the internet and I have access to that.

 

[rktect 1]

Its Illinois. Send your request to Felicia Burton as she is the accessibility specialist with the capital development board here.

CDB

News

cdb.illinois.gov

She will most likely support the bottled water dispenser. She has provided me documentation that the Illinois accessibility code does not trump the Illinois Plumbing Code.

 

[mp25]

The code is 2018 IBC w/ the associated ANSI A117.1 and 2010 ADA (and Illinois Accessibility Code), but there are no technical modifications to the scoping of drinking fountains within IL accessibility code. As there are no technical mods in the IL from the ADA, if the access board guidelines would permit a water dispenser without any regulations or requirement of the types of containers used to receive the water, I would expect IL to follow suit since the sections regulating this are the same. It really comes down to an interpretation differences between the ADA interpreters and and the ILAC interpretations.

I did email for an official interpretation and did receive a response and was told that a water dispenser must be on an accessible route, have a clear floor space with forward or side approach and if hand operated, must be within accessible reach range/no tight grasping/pinching twisting/5# etc. The answer also included that such substitution is permitted under the IL plumbing code.