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Protrusion limits

FLArch

Registered User
Joined
Jan 25, 2023
Messages
2
Location
Florida
I’m doing a peer review of another architect’s project, and I have a head scratcher. The facility is a board and care facility (large group home), renovation in NY State. The project value is over 50% so full ADA compliance is required.

The question is about §307.2 Protrusion limits. The architect proposes television enclosures around flat screen TVs that protrude further than the 4” allowed in the standard. The project architect says they don't apply because the TVs are in a rec room and not in a “circulation path.” I’m arguing that any place a person is required to walk around objects in a room, like furniture, is considered a circulation path. In Definitions §106.5 a circulation path is defined very broadly and inclusively. A furniture plan is not provided. The ADA Guidance document doesn’t offer any meaningful aid here.

My comments have the ability to stop the project, so I don't want to completely blow up this project schedule over something small.
 
I work for a large financial company in the project management side. We try to be very proactive and conservative with regard to ADA items just like you mention because there are people out there who make a living finding issues like that. We don’t allow anything to protrude more than 4”, anywhere. It might not be in the circulation path today, but next month the staff is going to rearrange the furniture.
 
I work for a large financial company in the project management side. We try to be very proactive and conservative with regard to ADA items just like you mention because there are people out there who make a living finding issues like that. We don’t allow anything to protrude more than 4”, anywhere. It might not be in the circulation path today, but next month the staff is going to rearrange the furniture.
I also like to take the risk-conservative approach here for exactly this reason. Also, it's the "right" thing to do, but not everyone is as scrupulous as me...
 
This is similar to an earlier discussion thread regarding protruding objects in single-user restrooms. At what point does the open area within a space become a circulation path? I agree with those that take the conservative route, especially if a space is designed for more than one occupant.
 
You are asking for a code response to a subjective question: in a big room, where is the circulation path?
I've had some CASPs claim that the side of a lavatory constitutes a protrusion next to a toilet circulation path, and must be at 27" max.

1674668358406.png

Back to your project:

The AOR's comment there are plenty of ways to get through the space that would avoid this protrusion, therefore it is not necessarily in the circulation path. If you "stop" the project with your comment, the AOR will claim that in absence of a less-subjective, more specific code rationale, you are the one causing project delay.

The AOR may even be implying that the TV is FF&E, not a part of his design scope. But that simply shifts the burden back to the owner.

If the goal of your peer review is to protect the interests of the owner, then a suggested resolution is this:
1. Have the AOR indicate the intended path of travel on the plans.
2. Inform the owner that they have 2 options:
  • (a) Take day-to-day management responsibility to ensure that no one ever walks near the TV; OR
  • (b) Require the AOR to add some permanent guard (such as a shelf or cabinet) at max. 27" AFF below the protruding TV. The guard ought to be at least as permanent as the TV above it. In other words, if the TV is bracket-mounted with screws onto the wall, then the cabinet below it should be affixed/screwed to the wall or floor.
I am certain that 99.99% of owners would go with option "B".

If you do this, you have not "stopped" the project, but you've made it clear that the AOR needs to be responsive to the owner's interests.
 
You are asking for a code response to a subjective question: in a big room, where is the circulation path?
I've had some CASPs claim that the side of a lavatory constitutes a protrusion next to a toilet circulation path, and must be at 27" max.

View attachment 10022

Back to your project:

The AOR's comment there are plenty of ways to get through the space that would avoid this protrusion, therefore it is not necessarily in the circulation path. If you "stop" the project with your comment, the AOR will claim that in absence of a less-subjective, more specific code rationale, you are the one causing project delay.

The AOR may even be implying that the TV is FF&E, not a part of his design scope. But that simply shifts the burden back to the owner.

If the goal of your peer review is to protect the interests of the owner, then a suggested resolution is this:
1. Have the AOR indicate the intended path of travel on the plans.
2. Inform the owner that they have 2 options:
  • (a) Take day-to-day management responsibility to ensure that no one ever walks near the TV; OR
  • (b) Require the AOR to add some permanent guard (such as a shelf or cabinet) at max. 27" AFF below the protruding TV. The guard ought to be at least as permanent as the TV above it. In other words, if the TV is bracket-mounted with screws onto the wall, then the cabinet below it should be affixed/screwed to the wall or floor.
I am certain that 99.99% of owners would go with option "B".

If you do this, you have not "stopped" the project, but you've made it clear that the AOR needs to be responsive to the owner's interests.
If that lavatory wasn't in a corner and you would have to walk around it from a water closet to a door or a hand dryer I would say it's protruding.
What is a circulation path was always a very subjective subject.
 
Except the tv is fastened to the wall in a specific location, unlike a chair that can be easily moved.
Which is why I also said:
The guard ought to be at least as permanent as the TV above it. In other words, if the TV is bracket-mounted with screws onto the wall, then the cabinet below it should be affixed/screwed to the wall or floor.
 
Keep in mind that many TV brackets are made to allow the TV to extend and rotate far beyond the wall, so the cane detection dimensions need to take that into account.

1674761592510.png
 
Keep in mind that many TV brackets are made to allow the TV to extend and rotate far beyond the wall, so the cane detection dimensions need to take that into account.
One could argue that the extension mount is only for servicing the tv.
 
One could argue that the extension mount is only for servicing the tv.
True. One could make many arguments about intended use and operation, and they may be valid. My point is that it shifts more responsibility to the owner and how they monitor ADA compliance post-construction. As long as the owner is aware of that, and all parties agree that the owner accepts the responsibility instead of the architect for day-to-day position of the TV, then the architect could design the cane detection (and document accordingly) for the TV in the closest-to-the-wall position.
 
I’m doing a peer review of another architect’s project, and I have a head scratcher. The facility is a board and care facility (large group home), renovation in NY State. The project value is over 50% so full ADA compliance is required.

The question is about §307.2 Protrusion limits. The architect proposes television enclosures around flat screen TVs that protrude further than the 4” allowed in the standard. The project architect says they don't apply because the TVs are in a rec room and not in a “circulation path.” I’m arguing that any place a person is required to walk around objects in a room, like furniture, is considered a circulation path. In Definitions §106.5 a circulation path is defined very broadly and inclusively. A furniture plan is not provided. The ADA Guidance document doesn’t offer any meaningful aid here.

My comments have the ability to stop the project, so I don't want to completely blow up this project schedule over something small.
If the TV or other objects are more than 80 inches above the finished floor it can protrude all you need it to beyond the 4". The circulation path is limited to 36" wide by 80" high continuously without obstruction (except for the 4"). The architect may have considered this for objects adjacent to the accessible route. There are many ways to provide detectable tactile surfaces below objects the protrude further than 4". There are many ways to alleviate this possible problem and too little information to go on.
 
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