tabushabu
Registered User
Here's a third issue we are trying to address for our TAS inspection for our restaurant. This one is about our light switches, HVAC (thermostat) and volume controls. Sorry for the long post ...
BACKGROUND
There are 3 items called out for not meeting accessibility standards.
- Dining Room Lighting Control is mounted at 50” to the top button. Highest operable part cannot exceed 48” above the finished floor.
- Light switches are mounted at 50” to the top of the toggle. Highest operable part cannot exceed 48” above the finished floor.
- Volume control is mounted at 59.5”. Highest operable part cannot exceed 48” above the finished floor.
- Thermostats are mounted at 60”. Highest operable part cannot exceed 48” above the finished floor.
- Volume controls and thermostats are mounted above a counter higher than 34”.
All control devices / operable parts shall be mounted at 48” max to the highest operable part for an unobstructed forward or side approach or as indicated in 308. Note: Per TDLR, a toggle light switch in the “on” position mounted at 48” to the centerline of the device violates the reach range requirement of 308. Per 104.1.1, tolerances are not permitted where the requirement is stated as a range. Reach ranges shall comply with 308."
My research
In reviewing the Texas Accessibility Standards, it appears that except for light switches, you are allowed to have redundant controls. The code from TAS is below and here is a link to a better description of redundant controls from access-board.gov
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.
Advisory 205.1 General. Controls covered by 205.1 include, but are not limited to, light switches, circuit breakers, duplexes and other convenience receptacles, environmental and appliance controls, plumbing fixture controls, and security and intercom systems.
BACKGROUND
There are 3 items called out for not meeting accessibility standards.
- Our 2 HVAC thermostats (Honeywell T9) are mounted near our POS system and are above a built-in counter and are at 60", well above the 48" requirement and also above a counter which impacts forward reach.
Since these thermostats are smart and can be controlled via the Resido smartphone app, I mounted an older iPhone with the app on a nearby wall that is below the 48" requirement. Since redundant controls are allowed except for light switches, would this suffice to meet the requirement?
- We have 3 volume controls also mounted about 60" high and near the POS above a counter. The main controller for the music system (with volume controls) is accessible inside a cabinet directly below the POS counter. This cabinet is accessible with side / forward reach etc. Would this qualify as a redundant control?
- Lastly, there is a 5 gang set of light switches installed at the front entrance were installed above 48" to the top of the switch (yes - the electrician should have known better). I looked at what it would take to lower the entire box, and unfortunately the electrician barely left enough wire to actually reach the switches, so even lowering the 5 gang box 3 inches would be problematic. I supposed someone could run new wire from the panel in the back and to each of the 5 sets of lighting they control - but that seems crazy.
However, I had already replaced the toggle switches with Lutron Caseta dimmers so we could set our lighting on timers (there was no neutral wire or I would have used a different switch type where I could have a single toggle that would meet the 48" requirement to the toggle instead of 50").
Lutron makes a companion switch that can mounted anywhere and it can be programed to perform different scenes and to control other Caseta switches / dimmers. I programed the companion to turn on and off the 5 main switches all at the same time. I mounted this switch on same wall at less than 48" to the topmost control.
The code says no redundant controls for light switches, but just wanted to get thoughts here or ideas to correct the issue. Both the on/off capabilities / buttons need to be moved from 50" to below 48". Ideas???
- Dining Room Lighting Control is mounted at 50” to the top button. Highest operable part cannot exceed 48” above the finished floor.
- Light switches are mounted at 50” to the top of the toggle. Highest operable part cannot exceed 48” above the finished floor.
- Volume control is mounted at 59.5”. Highest operable part cannot exceed 48” above the finished floor.
- Thermostats are mounted at 60”. Highest operable part cannot exceed 48” above the finished floor.
- Volume controls and thermostats are mounted above a counter higher than 34”.
All control devices / operable parts shall be mounted at 48” max to the highest operable part for an unobstructed forward or side approach or as indicated in 308. Note: Per TDLR, a toggle light switch in the “on” position mounted at 48” to the centerline of the device violates the reach range requirement of 308. Per 104.1.1, tolerances are not permitted where the requirement is stated as a range. Reach ranges shall comply with 308."
My research
In reviewing the Texas Accessibility Standards, it appears that except for light switches, you are allowed to have redundant controls. The code from TAS is below and here is a link to a better description of redundant controls from access-board.gov
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.
Advisory 205.1 General. Controls covered by 205.1 include, but are not limited to, light switches, circuit breakers, duplexes and other convenience receptacles, environmental and appliance controls, plumbing fixture controls, and security and intercom systems.
