What's wrong with these manufacturers?

[Yikes]

I'm trying to train our staff not rely on manufacturers when their literature claims a product is ADA compliant, but to closely examine and verify for themselves.

Here's a cut sheet I came across today from a major fixture manufacturer, with an illustration showing how their lavatory is ADA compliant.
My staff was ready to approve, based on the statement in the lower right corner. Can you tell me what they may be missing here?

 

[Joe.B]

The drain?

 

[RLGA]

The P-trap is correct; however, their dimensions do not add up.

If they showed the lavatory in the section as located per the plan, there would be 5-3/4 inches between the countertop edge and the edge of the lavatory rather than the 2-inch dimension shown on the section. This would definitely move the P-trap beyond the knee and toe clearance profile.

 

[Yikes]

You are both correct, and also, where did they get that knee clearance slope from? It wasn't from the 2010 ADA Standards:




This is more like it:

 

[walker.t]

Thanks for posting this and sharing your observation, this sort of “what’s wrong with this picture” post is good exercise.

I'm trying to train our staff not rely on manufacturers when their literature claims a product is ADA compliant, but to closely examine and verify for themselves.

That sounds like an excellent policy, to confirm such statements. I would say that building departments do that at a higher level in how they would review plans for compliance with codes even if the architect were to put a note on the cover sheet that says, “These drawing comply with all applicable building codes.” - the plans examiner isn’t going to take their word for it.

My staff was ready to approve, based on the statement in the lower right corner. Can you tell me what they may be missing here?

I have a slightly different take on the ADA compliance statement on the cut sheet. In my opinion, no manufacturer can say any sink is ADA compliant because to my knowledge there are no specific requirements in the ADA or A117.1 regarding the sink itself (meaning the thing with the bowl with the holes for the drain, overflow, and fixture.) For example, nothing states the minimum size of the bowl or maximum projection above the counter. The sink is one part of the compete lavatory installation (sink, fixture, water supplies, and drain) and the placement of everything relative to the floor with the required knee and toe clearances and clear floor space. Which by the way, the specification sheet forgot to tell us about that!

I don’t think the sink manufacturer should be making statements regarding the installation of their product, as their section shows it’s possible to install a “compliant” sink in a manner that will result in a non-compliant final installation.

In response to your question, “What wrong with these manufacturers?” - good question! Why does this sink manufacturer think they need to say anything about compliance with accessibility requirements when the element in and of itself doesn’t have requirements? Compare that with a light switch - an operable part with requirements regarding operation with one hand and a maximum amount of force to be used. I checked the specification sheet for the light switch I have in my office, it doesn’t say anything about how it complies with accessibility requirements for operable parts nor does it say anything about clear floor space and mounting height. I wonder if anyone ever selected a different light switch because a competitor’s spec sheet had a statement about compliance with accessibility requirements.

also, where did they get that knee clearance slope from? It wasn't from the 2010 ADA Standards:

I have wondered if a different angle could be used as long as it didn’t project below the 6:1 slope shown in the diagram.

 

[Yankee Chronicler]

Thanks for posting this and sharing your observation, this sort of “what’s wrong with this picture” post is good exercise.


That sounds like an excellent policy, to confirm such statements. I would say that building departments do that at a higher level in how they would review plans for compliance with codes even if the architect were to put a note on the cover sheet that says, “These drawing comply with all applicable building codes.” - the plans examiner isn’t going to take their word for it.

We never accept a manufacturer's "ADA Compliant" statement. Too often we find that it's just an advertising wonk throwing words at us. When we call, what usually transpires is that the sales rep ends up saying something like, "We think it should be okay under the ADA, so it is." Usually, it isn't.

I have a slightly different take on the ADA compliance statement on the cut sheet. In my opinion, no manufacturer can say any sink is ADA compliant because to my knowledge there are no specific requirements in the ADA or A117.1 regarding the sink itself (meaning the thing with the bowl with the holes for the drain, overflow, and fixture.) For example, nothing states the minimum size of the bowl or maximum projection above the counter. The sink is one part of the compete lavatory installation (sink, fixture, water supplies, and drain) and the placement of everything relative to the floor with the required knee and toe clearances and clear floor space. Which by the way, the specification sheet forgot to tell us about that!

Excellent point.

I have wondered if a different angle could be used as long as it didn’t project below the 6:1 slope shown in the diagram.

The ADA diagram doesn't specify an angle. The angle is the resultant of the several horizontal and vertical dimensions that are specified in the text. One can always exceed code minimums. So, for example, if you increase the vertical clearance for the toe space but keep everything else the same, the angle will change. The language is that the knee clearance " ... shall be permitted to reduce at a rate of 1 inch in depth for each 6 inches in height." You don't have to reduce the knee clearance at all -- as is shown by the shaded knee area in the diagram.

It has just become the norm to use the maximum allowable reduction so as to allow more room for pipes. The same thing applies to ramps. We tend to think of "ramp" as always being a 1:12 slope. That's because architects don't want to use up any more interior space than necessary for vertical circulation, so they always make indoor ramps as steep as possible -- 1:12. In reality, anything steeper than 1:20 is a "ramp" and requires all the bells and whistles that ramps are required to have.

 

[Jay Smith]

I think the strange knee clearance comes from this often misunderstood illustration that shows a minimum depth of 8” at the knees and a maximum usable toe clearance of 6”. Design professionals often think that 6” max is a measurement required to be taken from the wall to the bottom edge of the apron that is often shown to hide the plumbing.

 

[wwhitney]

I think the strange knee clearance comes from this often misunderstood illustration that shows a minimum depth of 8” at the knees and a maximum usable toe clearance of 6”.

I'm a novice at this, but I have no idea what the 6" max requirement means in that illustration. Can you explain?

I understand the "knee clearance" to be a minimum of 27" in height and to extend to a minimum of 8" from the front edge of the sink assembly. I understand the "toe clearance" to be a minimum of 9" in height and to extend all the way back to the wall from which the 17" to 19" overall depth of the sink assembly is to be measured.

Is the 6" actually a reduction in the allowable depth of that toe clearance, i.e. it need not extend all the way back to the wall but only extend back to 6" from the wall? If so, that diagram is missing a dashed vertical line to illustrate that.

Also, what is the meaning of the 29" min height figure? It appears to apply only to the front edge of the sink assembly. Which would mean that 1/4" back from that, the sink assembly could drop down a further 2" to the 27" minimum knee height clearance. That strikes me as making the 29" clearance of no benefit to the user.

Thanks,
Wayne

 

[Yikes]

Also, what is the meaning of the 29" min height figure? It appears to apply only to the front edge of the sink assembly. Which would mean that 1/4" back from that, the sink assembly could drop down a further 2" to the 27" minimum knee height clearance. That strikes me as making the 29" clearance of no benefit to the user.

Thanks,
Wayne

In its infinite wisdom, California has increased the knee clearance requirements at lavatories to be 29" per the illustration below.
Oddly, they only require 27" clearance at kitchen sinks, so I don't know how the extra 2" of knee height makes a difference at a bathroom sink.

 

[Jay Smith]

I'm a novice at this, but I have no idea what the 6" max requirement means in that illustration. Can you explain?

I’m attaching the text that explains it better than the illustration did.

 

[bill1952]

To the question of product manufacturer claims their product is ADA compliant, was just looking at a wheelchair lift claiming it was ADA compliant.

"The Virtuoso meets all Americans with Disabilities Act Accessibility Guidelines (ADAAG) and ASME A18.1 regulations and is therefore a fully ADA Compliant wheelchair lift."

What would you check for yourself?

Virtuoso Vertical Platform Lift | Ascension Wheelchair Lifts

The Ascension Virtuoso wheelchair lift is fully ADA compliant, requires no ramp, machine tower or pit, and reaches heights up to 5 ft.

www.ascension-lift.com

 

[walker.t]

I'm a novice at this, but I have no idea what the 6" max requirement means in that illustration. Can you explain?

I understand the "toe clearance" to be a minimum of 9" in height and to extend all the way back to the wall from which the 17" to 19" overall depth of the sink assembly is to be measured.

I’m not sure if I understand your question but I’ll share my understanding of the toe space.

As a general concept, we provide knee and toe space below an element because the forward reach stops at the front of the 30”x48” clear floor space - we need space below the element so we can roll under it to be able to reach over the element. By comparison, a side reach is allowed to extend beyond the side of the clear floor area. If we want to reach to a faucet, the end of the toe space only has to go back that far. But if a soap dispenser is mounted on the wall behind the faucet, we need the toe clearance to go back to the operable part on the soap dispenser. The height of the reach depends on the depth of the reach, see ADA 308.2; knee and toe clearance is in ADA 306.

If we have an outlet on the wall over the lavatory and the counter is 24” deep, our 6” toe space has to reach the wall. But because the toe space is limited to a maximum 6” depth we add the extra depth at the front where it is 27” above the floor. The minimum depth at 27” is 8” minimum, that 8” becomes 15” [24” - 6” (for the toe clearance) - 3” (for the angled part) = 15”].

Also, what is the meaning of the 29" min height figure?

I can’t comment on the 29” height, that’s the first I’ve seen that.

 

[arwat23]

"The Virtuoso meets all Americans with Disabilities Act Accessibility Guidelines (ADAAG) and ASME A18.1 regulations and is therefore a fully ADA Compliant wheelchair lift."

The fact they're referencing ADAAG and not the newer ADAS or ICC A117.1 makes me skeptical of any claim they make.

 

[Yankee Chronicler]

I'm a novice at this, but I have no idea what the 6" max requirement means in that illustration. Can you explain?

I understand the "knee clearance" to be a minimum of 27" in height and to extend to a minimum of 8" from the front edge of the sink assembly. I understand the "toe clearance" to be a minimum of 9" in height and to extend all the way back to the wall from which the 17" to 19" overall depth of the sink assembly is to be measured.

Is the 6" actually a reduction in the allowable depth of that toe clearance, i.e. it need not extend all the way back to the wall but only extend back to 6" from the wall? If so, that diagram is missing a dashed vertical line to illustrate that.

Also, what is the meaning of the 29" min height figure? It appears to apply only to the front edge of the sink assembly. Which would mean that 1/4" back from that, the sink assembly could drop down a further 2" to the 27" minimum knee height clearance. That strikes me as making the 29" clearance of no benefit to the user.

Thanks,
Wayne

Toe clearance does not necessarily extend to the back wall. Refer to section 306 of A117.1-2017.

 

[Mr. Inspector]

I had a few one-piece shower stalls that said ADA compliant on the plans that weren't when inspected.

 

[Yikes]

What I hear Walker.T saying is that the toe space needs to extend at least as far as whatever you are trying to reach that is above the counter, which might include but not be limited to:
- The faucet control and/or drain stopper control in its furthest position away from the front edge of counter
- an electrical outlet
- a medicine cabinet door
- a soap dispenser, paper towel dispenser or other dispenser.

 

[walker.t]

What I hear Walker.T saying is that the toe space needs to extend at least as far as whatever you are trying to reach that is above the counter

Hopefully someone else can comment to confirm my understanding and add additional information. Below are a few extra comments I can add.

- The faucet control and/or drain stopper control in its furthest position away from the front edge of counter

Yes. “Faucet control” could be the point where we place our hands so that a motion detector can start the flow of water.

There is a requirement for “enhanced reach range” when a bathing facility has six or more lavatories, that requires a maximum 11” reach to activate water flow and the soap dispenser. IBC 1109.2.3 states the requirement for enhanced reach range lavatories, A117.1 606.5 gives the specific requirements.

- a medicine cabinet door

I think the toe space would have to extend to the back of the medicine cabinet after the door is opened.

- a soap dispenser, paper towel dispenser or other dispenser.

For dispensers we only have to reach to a depth that lets us activate the device and receive whatever it is dispensing.

For operable parts on towel dispensers and hand dryers for accessible lavatories there is an added requirement in A117.1 that is not in the ADA. This is in A117.1 603.6 which references Table 603.6. Problem is I’m not sure how to apply this, so I’ll only mention that it’s there but can’t offer comments on the correct application of the provision.

I looked up the U.S. Access Board technical guide on lavatories, it has a cross-section through a lavatory similar to what I drew but it shows additional (non-accessible) depth beyond the toe space.

U.S. Access Board - Chapter 6: Lavatories and Sinks

The U.S. Access Board is a federal agency that promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards for the built environment, transportation, communication, medical diagnostic equipment, and...

www.access-board.gov

 

[Jean Tessmer-HI]

I'm trying to train our staff not rely on manufacturers when their literature claims a product is ADA compliant, but to closely examine and verify for themselves.

Here's a cut sheet I came across today from a major fixture manufacturer, with an illustration showing how their lavatory is ADA compliant.
My staff was ready to approve, based on the statement in the lower right corner. Can you tell me what they may be missing here?

View attachment 13388

 

[Jean Tessmer-HI]

Hi Yikes,
Here is what I found after looking at your cut sheet spec. Per ADA 306 knee and toe clearance: Step by step excerpt to keep brief:
306.2.2 Toe Clearance shall extend 25 inches maximum under an element.
306.2.4 Space extending greater than 6 inches beyond the available knee space, 9 inches above the finished floor shall not be considered toe space.
In other words, toe space cannot extend beyond the 9" height at 11" max. from face of rim or counter to that top point of 9" aff.
The maximum depth from the 8" knee space to the lower point of the 9" high by 6" depth is 11". The clear space slope from the 8" in to 9" height at 11" as it is in the spec sheet illustration, would cut into the P-trap even with the wheelchair drain bend. You would not be able to mount a shroud under this sink. See ADA figures 306.2 and 306.3

 

[Jean Tessmer-HI]

Sorry I meant to say 11" min per figure 306.3. According to the US access board the 6:1 slope never changes - https://www.access-board.gov/ada/guides/chapter-6-lavs-sinks/. Illustration attached.

 

[Jean Tessmer-HI]

I'm trying to train our staff not rely on manufacturers when their literature claims a product is ADA compliant, but to closely examine and verify for themselves.

Here's a cut sheet I came across today from a major fixture manufacturer, with an illustration showing how their lavatory is ADA compliant.
My staff was ready to approve, based on the statement in the lower right corner. Can you tell me what they may be missing here?

View attachment 13388

Yikes, like you I never rely on what the manufacturers claim especially when they use the ISA symbol like it is a stamp of approval. These seemingly small issues can all add up when doing multi-family or hotel projects covered by the ADA or FHA.

 

[Yikes]

Yes. “Faucet control” could be the point where we place our hands so that a motion detector can start the flow of water.

I have a lot of ADA projects that are public housing units, and the lav faucet is lever hardware instead of motion sensor.
In that situation, we push the lever as far back as it will go - - typically full hot and/or full cold - - and the depth to the end of the toe space must meet or exceed this.

 

[walker.t]

we push the lever as far back as it will go - - typically full hot and/or full cold - - and the depth to to the end of the tow space must meet or exceed this

That sounds like the thing to do - you identified the worst case (maximum depth to the lever when pushed back) then made sure that the knee and toe space allow you to reach that.

 

[Yankee Chronicler]

Sorry I meant to say 11" min per figure 306.3. According to the US access board the 6:1 slope never changes - https://www.access-board.gov/ada/guides/chapter-6-lavs-sinks/. Illustration attached.

I'm amazed that the Access Board says the 6:1 slope never changes, because obviously it CAN change. It can be perfectly vertical, in fact. And, going the other way, the 6" horizontal toe space is a maximum dimension. Leave everything else unchanged and reduce that to 3 inches. Still compliant, but the 6:1 slope is no longer 6:1.