Would a Hand Sink in a Utility Room be Considered a "Wet Bar" Under CBC?

[arwat23]

This one may be a bit of a stretch, but under the California Building Code, would a hand washing sink in a utility room in a professional office of a healthcare provider be considered a "wet bar" as defined in code?

I have some built-in cabinets with a counter and a hand sink in a utility room that one party says needs to be accessible with a forward approach, but other party says it doesn't. Since CBC 11B-223.4 and 11B-805.6 require that all hand washing fixtures be accessible, they're trying to use 11B-606.2, exception 1 to explain why it doesn't need to have a forward approach.

Going strictly by the definitions in Chapter 2, this sink seems to meet the definition of "wet bar", which would allow a side approach under 11B-606.2. However, logically, I don't know if you could consider this a "wet bar" since it's a utility space and meets basically no other definition of "wet bar" (defined outside of Building Code). Since the remainder of the exception is specific to kitchen areas, it would make sense that a "wet bar" is meant to be defined more specifically than what's in Chapter 2, at least for this exception. Or maybe I'm reading way to much into this.

Does anyone have advise they could give me on how to approach a situation like this? Anyone else run into this argument before?

 

[Yikes]

If the purpose of the sink is to wash hands, then CBC 202 would define it as a lavatory and it would need to be accessible per CBC 11B-606.2 with a forward approach.

However, it is located in a utility room. So it may have originally been placed there not for hand washing purposes but for utility-related purposes, such as rinsing out equipment, maybe as a water source for thinning concentrated cleaning products, etc. Under those purposes, it might be more appropriately classified as an employee workstation.
CBC 11B does not require all workstation components to be accessible - - see 11B-203.9 for the limitations. If there is a common use circulation path at a workstation, that path needs to be accessible.

 

[arwat23]

If the purpose of the sink is to wash hands, then CBC 202 would define it as a lavatory and it would need to be accessible per CBC 11B-606.2 with a forward approach.

However, it is located in a utility room. So it may have originally been placed there not for hand washing purposes but for utility-related purposes, such as rinsing out equipment, maybe as a water source for thinning concentrated cleaning products, etc. Under those purposes, it might be more appropriately classified as an employee workstation.
CBC 11B does not require all workstation components to be accessible - - see 11B-203.9 for the limitations. If there is a common use circulation path at a workstation, that path needs to be accessible.

This is all new construction. There are two sinks in this room. One is for utility cleaning and one is for handwashing. It's a medical facility (not OSHPD), so they have devices that need regular cleaning. The separate hand washing sink is, I believe, a request by the client for a separate hand washing sink in the same room as this utility sink.

My understanding is that all handwashing sinks, except scrub sinks, need to comply with 11B-606.

11B-223.4 Professional Offices of Health Care Providers​

Professional offices of health care providers shall comply with Section 11B-805.

11B-805.6 Hand Washing Fixtures, Lavatories and Sinks​

All hand washing fixtures, lavatories and sinks shall comply with Section 11B-606.
Exception: Scrub sinks, as defined in California Plumbing Code Section 221.0, shall not be required to comply with Section 11B-606.

11B-805.7 Built-In Cabinets and Work Surfaces​

Built-in cabinets, counters and work surfaces shall be accessible, including: patient wardrobes, nurse stations, administrative centers, reception desks, medicine preparation areas, laboratory work stations, equipment consoles, clean and soiled utility cabinets and storage areas; and shall comply with Sections 11B-225 and 11B-902.


Regardless, assuming compliance with 11B-606 is required (there are a few other sinks that seem to exist in a grey area in code), would the "wet bar" argument be reasonable for allowing a side approach to these sinks? Or would a forward approach be required.

 

[Yikes]

The Owner has to state the purpose of the sink.
CBC 202 has definitions for "lavatory", "wet bar" and "sink".
"Lavatory" is for washing body parts: washing hands or bathing.
"Sink" is for washing "dishes, clothing, etc."
I personally would put the owner's declaration on the plans.

 

[arwat23]

The Owner has to state the purpose of the sink.
CBC 202 has definitions for "lavatory", "wet bar" and "sink".
"Lavatory" is for washing body parts: washing hands or bathing.
"Sink" is for washing "dishes, clothing, etc."
I personally would put the owner's declaration on the plans.

Oh, I see. I made the mistake of not defining "sink". Thanks!

 

[JPohling]

I would provide roll under access if the intended purpose is for hand washing