Welcome back!
For this installment, we will cover restroom accessibility. For considerations regarding facility management or considerations on how to modify the restroom beyond simple, readily achievable items, I would recommend listening to this podcast found on facilitiesnet.com. You can find the podcast here:
ADA consideration tips for Contractors and Property Managers
Now, if you had listened to this podcast, and you’re a leasee or a small business owner, you’re probably thinking that can’t be something I can do… in a long term solution, that may have to be done eventually but not right now. Since this post is about providing tips on what can be done right now it’s got to be simpler and less intrusive on the structure of your restroom. This is what readily acheivable means.
What is a Readily Achievable Accommodation?
Readily achievable is defined as providing alterations to existing facilities that are “to the maximum extent feasible”. The maximum extent feasible has to do with an entity’s financial threshold. If you are a smaller entity, your financial resources would be much less than a larger entity. So readily achievable accommodations changes depending on who you are. If you want a larger picture as to how readily achievable accommodations, you can go here to read more about the larger picture:
How to Determine your ADA Liability Cost
There isn’t any magical fixes, this is simply a matter of knowing what the laws are. We will cover four pictures.
Discussion of ADA Accommodations
Restroom Picture #1: Proper Signage
If you’ve looked online for signage requirements, you’ll understand there are height and space requirements. Those are pretty specific — and we won’t get into that right now ( we will cover this later). My point, is that’s not well understood how to go about purchasing the proper signs. Proper restroom signs need braille and raised lettering. Whether this goes on the door, depends a great deal on the door swing. For instance, these doors open out, so having raised letter and braille on these door signs would be a hazard. For more detailed information about this, you can go here:
In this picture though, you can see how the sign blends with the color of the wall. The requirement for “contrasting color” applies not only to the pictogram and the lettering against the background of the sign but also between the sign and the wall. It’s understandable that the owner of this restaurant probably wanted signage that would blend into the color of his wall so as to be unobtrusive. But that does defeat the point, doesn’t it? For someone who is legally blind, they may not be able to see the sign is there if it’s too small. The large size of the sign contrasting with the color of the wall is meant to draw attention to the presence of the sign. An individual who is blind could then walk up to the sign and touch it, and read the braille or trace the lettering and understand if this restroom is or is not meant to service them.
Restroom Picture #2: Amenity Height
One of the most common requirements for the accessibility of restroom amenities is the height of restroom amenities. The point of providing these items to the public is so that the public can use them. Providing goods and services to everyone equally is the point of the ADA. The height is not the only dimension to be considered. Height is part of something called “reach range”. There’s not enough space to go over in detail how the reach range is affected by approach or over-reaches but in general, the California Code of References specifies that at least one of the each type of restroom amentities must be at maximum 40 inches above the finished floor. This means that if paper towels AND a dryer is made available than one of each must be at 40 inches to the operating point. For mirrors, this should be at 40 inches. For towels with controls, the control must be at 40 inches. For soap dispensers, the dispenser must be at 40 inches.
In this restroom, the mirror here is at the threshold of 40 inches. You can scale the mirror height through the titles and it’s pretty close to 40. They definitely need to measure that height to the reflective edge. Now, knowing what is at 40 inches looks like in this restroom, you can note that the paper towel dispensers are too high. This can be resolved by either lowering one of the dispensers or by installing a lower dispenser in order to make paper towels available to everyone. (This can be as simple as providing paper towels on the counter itself. Of course such a ‘fix’ would require active monitoring so that the paper towels will always be available.)
For the soap dispensers, there are two. One is too high. One is lower than 40 inches but has a reach depth that is too deep. In fact, it’s likely that all four amenities are too deep. (I did not measure this restroom.) In general, each amentity must have clear floor space under it so that someone in a chair can have enough space to go up to the item and reach it. A good rule of thumb is that at 40 inches…
Restroom Picture #3: Sinks
The ADA 2010 simplified the knee clearance under sinks. This sink has an interesting design and probably meets the requirements for knee clearance. (I did not measure this sink). But just from looking at it, I see 2 other issues.
The second issue has to do with the pipes wrapping. Wrapping pipes requires that the hot water input and the drainage be wrapped in insulating materials. From this picture, it’s clear that the sink on the left is wrapped. What isn’t clear is that that this sink is identical to the sink on the right. If one sink of all of them were lowered, then that would be the accessible sink. But if the dimensions of all the sinks are the same and there is no identifying sign that the sink on the left were otherwise the accessible sink, then this business might as well not have wrapped their sink. They are still at risk to having their customer be burned by the hot water pipes simply because there is little in way of identifying the wrapped sink.
The second issue has to do with the bowl height. While the code says that the top of the sink apron, or the sink counter, shall be no higher than 34 inches. The issue isn’t just so the counter top is at 34 inches, but also so that someone can get their hands in the bowl to wash their hands or wash their face. The bowl looks to add 6 inches, so even if they had knee clearance at 29 inches which is the minimum, adding another 6 inches puts them at 35, too high to be compliant.
Restroom Picture #4: Urinal
The last image we will discuss is the urinal. The urinal requirements are pretty much the same as any other point of operation although there are two added requirements specific to urinals. This urinal has the needed depth (the rim extends far enough from the back wall) but the height is too high. Urinals are required to have the projecting edge to be 14 inches from the back wall minimum. The rim height should be a maximum of 17 inches from the finished floor (judging from the picture, this one looks to be at least 2 feet from the finished floor.)
There are three additional considerations, the clear floor space, the slope of the floor and the flush control.
From the photo there are no obvious floor slope issues, but you can tell that the trash can is awfully close to the urinal. It may interfere with the clear floor space. This is a matter of policy, this large facility should instruct their janitorial staff to place the trash can somewhere else.
Also visible from the photo is the flush control. You’d recognize this control to be automatic, as it has a sensor. But if this control should have an additional push button for added flushing ability, then this urinal control should be within 54 inches of the finished floor. Remember, 40 inches applies to the amenities. 54 inches is the side reach range if the wheelchair user reached up from the side of the chair. 48 inches is the front reach range.
This concludes our discussion.
ADA Compliance Takeaway
So you understand, the point of all these articles is to educate you readers about what ADA compliance entails. Both what to do, how to approach it, how to best comply and what the common pitfalls for complete ADA compliance are.
Education is mostly free. I have to spent a few hours, maybe a day and a half each week, working on articles, and you have to take time to read it, to shift through the multitude of available information.
Ultimately, though, we make a living doing ADA inspections and ADA consultation.
We do know the laws and ADA regulations, but we don’t know your facility.
I can write about the most common and glaring problems, but I can’t advise you on your particular site. Even if you submitted pictures, I can’t measure slope or spot issues you may not know about. If you find this information helpful, feel free to drop an email or a comment. Submit a picture too, if you like. I can email you back with an opinion. (Money is even more appreciated!)
But seriously, give me some genuine feedback and let me know if this was helpful or if you would like me to cover a specific topic. If I get enough requests, I’ll take the time to write an article on it. If you’re interested in having us apply our knowledge to your place of business/place of public accommodation in the form of an ADA consultation, by all means call us at 866 982 3212 or email us athelp@accesssolutionllc.com.
**Note: The California Building Code may have changed its requirements since the writing of this article.
41 Replies to “ADA Accommodation #2: Readily Achievable Restroom*”