Upper Cabinet Reach Range

[BayPointArchitect]

The code review comment provided during the permit application:
Ref. 2010 ADA 308.2-309.4, Figures 308.2.2 or 308.3.2; Please indicate... how the upper cabinets will comply with the referenced codes for reach range.

The pull handles for the proposed upper wall cabinets are eleven inches too high. But the upper wall cabinets are typical for every other commercial office building constructed within the last twenty years.

Question:
How have you seen this issue dealt with? Do folks introduce one wall cabinets with the bottom shelf flush with the top of the base cabinet? Do they introduce a single shelf that fits in between the lower base cabinet and upper wall cabinet? Do they rip the wall cabinets off the wall and put them back up after final inspection?

The attached illustration shows the upper wall cabinets lowered from the "normal" height down eleven inches. The end result looks stupid.

As always, thanks in advance.

ICC Certified Plan Reviewer
NFPA Certified Fire Plan Examiner

 

[redeyedfly]

See 212.2/804.5 & 225. You're in building blocks; those sections are scoped in other parts of the standard, they only apply to items which are scoped elsewhere.

 

[Yikes]

The is labeled as a private break room, and judging by the graphics it is a kitchenette (sink, refrigerator). So kitchen storage compliance scoping falls under ADAS 804.5, which requires 50% of your kitchenette shelf space to comply with 811.3, which in turn requires a reach range of 15-46" in ADAS 308.3.2.

Before looking at the upper cabinets:
Your first step is to see if you can achieve 50% accessible shelf storage with your base cabinets, because if you do, then you don't need the upper cabinets to be accessible. Note that there has been much ink and blood spilled on whether a drawer bottom is a type of storage "shelf". In City of LA, the court -appointed accessibility consultant has determined that a drawer that is at least 8.5" tall and has its handle is between 15-46" AFF can count as a "storage shelf".

There is no definitive statement from USDAJ, and no court case that has settled this issue nationwide. Even the famous Chevron case which urges plain reading words (like "shelf") was partially struck by the Supreme court this year. If you say "yes", the base cabinet drawer bottoms are shelves, you might make it calc to 50%.

If not, then let's move on and look at look at your options for making the upper cabinets accessible.
ADAS Fig 308.3.2(b) shows a maximum obstructed reach over the base cabinets of 46" AFF to the top of the lowest shelf to make that shelf accessible.

Most cabinet boxes are made of 3/4" wood, so the underside of the cabinet will be at 45 1/4" AFF. On all our projects, we turn the upper cabinet handles horizontal and put them along the bottom of the door, typically around 45 3/4" high.

But think about this:
If your sink rim is at 34", that leaves you only 13.25"-13.5" clear beneath the cabinets. That's not enough room for many coffee makers, toasters and microwaves. Here's what we've done instead:
1. Provide no upper cabinets. At an office, they usually just get filled with holiday decorations anyway.
2. Make a tall "pantry" cabinet as shown in blue below, and provide a bunch of full-pullout shelves between 15-46" AFF to meet 50% accessibility requirements.

 

[walker.t]

how the upper cabinets will comply with the referenced codes for reach range.

Are you sure the wall cabinets qualify for a 48” high reach? I thought that was limited to a 10” deep horizontal reach measured from the front of the obstruction, so if you have nominal 24” deep base cabinets and 12” nominal deep wall cabinets, that’s a 12” horizontal distance and you have to go down to 46”.

Also, if you’re reaching into the cabinet (meaning your horizontal reach is greater than 10”) you’re limited to a 24” deep obstruction if you want to reach to the back of the wall cabinet, so the front edge of the counter won’t be able to extend beyond the front of the base cabinets.

Make a tall "pantry" cabinet

I like that idea.

 

[Yikes]

And by the way, if your break room cabinets really are filled with holiday decorations and junk, and you want to keep it that way, then put the junk a big deep cabinet over the refrigerator and label it "general storage", so it doesn't get calculated as storage shelving related to kitchenette.

 

[BuildingOfficial89]

Although the intent of the ADA is noble, and I support the intent, ADA often stands for Attorney's Dreams Answered.

 

[BayPointArchitect]

In this particular case, I am going to argue that
2010 ADA III-1.6000 Private membership clubs are exempt from the ADA regulations under title II of the Civil Rights Act of 1964.
1) The organization exercises a high degree of control over club operations.
2) The membership selection process is highly selective.
3) Substantial membership fees are charged.
4) The entity is operated on a nonprofit basis.
5) The organization was not founded specifically to avoid compliance with Federal civil rights laws.

 

[Yikes]

In this particular case, I am going to argue that
2010 ADA III-1.6000 Private membership clubs are exempt from the ADA regulations under title II of the Civil Rights Act of 1964.
1) The organization exercises a high degree of control over club operations.
2) The membership selection process is highly selective.
3) Substantial membership fees are charged.
4) The entity is operated on a nonprofit basis.
5) The organization was not founded specifically to avoid compliance with Federal civil rights laws.

I'm confused - - I thought you said this was a plan check comment. What Authority Having Jurisdiction has formally adopted ADA as their local code for plan check?

 

[Paul Sweet]

ADA doesn't apply to churches and private clubs because they are specifically exempted from the 1964 Civil Rights Act it was based on.

Apparently ANSI A117.1, which was identical to ADASAD before 2009, has been amended more than I realized. The initial post got me worried about a catering kitchen and break room I'm redesigning. Virginia used ADASAD for state buildings until they adopted the 2021 IBC and 2017 ANSI A117.1 last year. I found that ANSI A117.1 did away with the 50% accessible shelf requirement in the 2009 edition.

 

[BayPointArchitect]

I'm confused - - I thought you said this was a plan check comment. What Authority Having Jurisdiction has formally adopted ADA as their local code for plan check?

The Nebraska Accessibility Code (N.A.G.) is patterned after the 2010 ADA. The logic being that - if the federal government FAILS to condense three or more different accessibility regulations into one reference, then our local legislative body may select one of those standards and run with it. Chapter 11 of the IBC is deleted by amendment and points the design professional to the N.A.G. However, there are those in Omaha who believe that the application of ALL of the accessibility regulations and a zealous interpretation of those regulations, will result in a handicap features that are above reproach. Meanwhile, I think that Missouri and other midwest states have the same logic. More regulations is not always better. California is always proud to be on a "better standard". My opinion is that regulations and more regulations become a ridiculous burden at some point.

 

[Yikes]

I thought that Nebraska had kept and modified chapter 11 solely for scoping, and then Chapter 11 refers over to the Nebraska Accessibility Code, which is basically a couple of sentences referring to ANSI 117.1 for technical requirements.

The technical requirements in the 2010 ADA Standards are formatted similar to the technical requirements in ANSI 117.1.
However, ADAS has its own scoping that is not found in ANSI 117.1.
But unless your jurisdiction has adopted the 2010 ADA Standards as a local code, I think that a Nebraska AHJ can only enforce the scoping found in the locally adopted code.

So in the case of this break room kitchen:
If you are the AHJ, you only enforce the locally adopted code. You look to chapter 11 for scoping (finding out what applies to the project) and to ADAS 117.1 for technical requirements (how to confirm the design complies with what applies).
If you are DPOR, you design to the locally adopted code AND to ADA, whichever is more restrictive.