Kitchen VS Break Room ADA Sink

[Ana]

I have an office breakroom and the Client wants to use deep sinks that will not allow a forward approach, so I'm providing a parallel approach based on section 606.2, Ex. 1 of the ADA guidelines. The issue is that I saw several articles that differentiate between a kitchen and a break room, and they indicate that for breakrooms, sinks should ALWAYS have front approach (even if they don't have fixed cooking appliances), but for kitchens it's allowed to have the side approach per the section I mentioned above. I don't see anywhere in the code where it differentiates between kitchens and breakrooms, so I'm inclined to go by the section above and provide the parallel approach for the office little breakroom since there's no actual differentiation whether it's a kitchen with no fixed cooking appliances or a breakroom. I'm interested to know your thoughts. Thanks

 

[north star]

@ ! @

Ana, ...I have always interpreted Section 606 the same as you.
Unless something has changed, the Breakroom Sink can have
either a Forward Approach or a Parallel Approach.

@ ! @

 

[mark handler]

ADA Inspections Nationwide, LLC — ADA Compliancy

This article will review the technical requirements for kitchens and kitchenettes with respect to the Americans with Disabilities Act (ADA). First it is important to note that the ADA does not distinguish between kitchens and kitchenettes.

inspectionsada.com

What is a Kitchen according to TDLR - Abadi Access

TDLR issued a new RAS bulletin for projects that are built in Texas. Here is the link . I also wrote my August newsletter that explains it: In summary, h

abadiaccess.com

2010 ADA Standards for Accessible Design

The 2010 Standards set minimum requirements – both scoping and technical – for newly designed and constructed or altered State and local government facilities, public accommodations, and commercial facilities to be readily accessible to and usable by individuals with disabilities.

www.ada.gov

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Based on 2010 ADASAD106.3, definitions provided in collegiate dictionaries, and information received from the U.S. Access Board, they shall have the referenced meanings:–​

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Kitchen: A place (as a room) with cooking facilities.–​

Kitchenette: A small kitchen or alcove containing cooking facilities.​

Break rooms do not have built in cooking facilities.

Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.​

ADA does not distinguish between kitchens and kitchenettes.​

For kitchens and kitchenettes in non-residential installations, which includes commercial buildings and hotels, the requirements for ADA compliance is based partially on whether or not there is a cook-top or range installed. 2010 ADA Standard 804.2, [Kitchens and Kitchenettes], Clearance, Exception, states, “Spaces that do not provide a cooktop or conventional range shall not be required to comply with [Standard] 804.2.” In other words, the cook-top or range is the trigger for when the kitchen or kitchenette ADA laws apply.
If a cook-top or range is installed in a non-residential kitchen or kitchenette, then the requirements for clearances (u-shaped or pass-through), sink(s), storage, and appliances apply. In this design the sink must have a forward approach. If a cook-top or range is not installed in a non-residential kitchen or kitchenette, then the sink is allowed to have a side, or parallel, approach, and the clearance requirements (40/60 inches) do not apply. The requirements for operable parts, storage, and appliances still apply. Note that the requirements for kitchens and kitchenettes apply to exterior and interior installations equally. Note also that a microwave oven is not considered a cook-top, range, or conventional oven...

Kitchens that are not in residential dwelling units do not require work surfaces. 2010 ADA Standard 804.3, Kitchen Work Surface, states, “In residential dwelling units required to comply with [Standard] 809, at least one 30 inches (760 mm) wide minimum section of counter shall provide a kitchen work surface that complies with [Standard] 804.3.”....

2010 ADA Standard 606.2, [Sink] Clear Floor Space, states, “A clear floor space complying with [Standard] 305, positioned for a forward approach, and knee and toe clearance complying with [Standard] 306 shall be provided. EXCEPTION: A parallel approach complying with [Standard] 305 shall be permitted to a kitchen sink in a space where a cook top or conventional range is not provided and to wet bars.” ...

Break rooms are not kitchens because they don’t have a built in cooking facility, but must comply with the requirements for sinks.
break room without a fixed cooking facility shall comply with 811 and only one of each kind will have to comply

 

[Ana]

Break rooms are not kitchens because they don’t have a built in cooking facility,

Does this mean that a kitchen with no built-in cooking facility is not a kitchen? but can still comply with the exception in 606.1? then can a break room just change its name and become a "kitchen with no built-in cooking facility"?

 

[Ana]

@ ! @

Ana, ...I have always interpreted Section 606 the same as you.
Unless something has changed, the Breakroom Sink can have
either a Forward Approach or a Parallel Approach.

@ ! @

yes it makes perfect sense to me.

 

[classicT]

Posting A117.1-2017 Section 606.2 for reference here.

606.2 Clear Floor Space​

A clear floor space complying with Section 305.3, positioned for forward approach, shall be provided. Knee and toe clearance complying with Section 306 shall be provided. The dip of the overflow shall not be considered in determining knee and toe clearances.
Exceptions:

1. A clear floor space providing a parallel approach shall be permitted at a kitchen sink in a space where a cook top or conventional range is not provided.
2. The requirement for knee and toe clearance shall not apply to a lavatory in a toilet or bathing facility for a single occupant, accessed only through a private office and not for common use or public use.
3. A knee clearance of 24 inches (610 mm) minimum above the floor shall be permitted at lavatories and sinks used primarily by children ages 6 through 12 where the higher of the rim or counter surface is 31 inches (785 mm) maximum above the floor.
4. A clear floor space providing a parallel approach shall be permitted at lavatories and sinks used primarily by children ages 5 and younger.
5. The requirement for knee and toe clearance shall not apply to more than one bowl of a multibowl sink.
6. A clear floor space providing a parallel approach shall be permitted at wet bars.

 

[classicT]

I don't see anywhere in the code where it differentiates between kitchens and breakrooms

It does not differentiate by use of the room. What it does differentiate, is the type of sink. If it is a kitchen sink (not defined, but I think we all would generally recognize one) and there is no cook top or range, then parallel approach is acceptable.

Does this mean that a kitchen with no built-in cooking facility is not a kitchen?

No. That is not the case.

 

[Mr. Inspector]

I only require compliance with the 2018 IBC not ADA:
ICC 117.1-2009
606 Lavatories and Sinks
606.1 General. Accessible lavatories and sinks shall
comply with Section 606.
606.2 Clear Floor Space. A clear floor space complying
with Section 305.3, positioned for forward approach,
shall be provided. Knee and toe clearance complying
with Section 306 shall be provided. The dip of the overflow
shall not be considered in determining knee and
toe clearances.
EXCEPTIONS:
1 . A parallel approach complying with Section 305
and centered on the sink, shall be permitted to I
a kitchen sink in a space where a cook top or
conventional range is not provided.

 

[Ana]

I only require compliance with the 2018 IBC not ADA:
ICC 117.1-2009
606 Lavatories and Sinks
606.1 General. Accessible lavatories and sinks shall
comply with Section 606.
606.2 Clear Floor Space. A clear floor space complying
with Section 305.3, positioned for forward approach,
shall be provided. Knee and toe clearance complying
with Section 306 shall be provided. The dip of the overflow
shall not be considered in determining knee and
toe clearances.
EXCEPTIONS:
1 . A parallel approach complying with Section 305
and centered on the sink, shall be permitted to I
a kitchen sink in a space where a cook top or
conventional range is not provided.

Awesome! Thank you.

 

[Paul Sweet]

Ana,

Check what codes are used where this project is located. Most states use ANSI A117.1, but some use ADA Standards for Accessible Design and others have their own enhancements to ADA or ANSI.

In any case, the base ANSI and ADASAD are 98% the same. A few years ago ANSI increased maneuvering space sizes to accommodate larger motorized wheelchairs and added a vertical grab bar in toiler stalls.