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Article By: Kelly Gilfoy
Haws Representative

Some have commented that emergency shower & eyewash equipment has no "accessible" dimensional requirements, because this type of equipment is not mentioned in the A.D.A. Accessibility Guidelines. Some have gone so far as to disregard the accessibility of this equipment entirely. I feel that this misconception could be the result of a fundamental misunderstanding of the A.D.A.

If the A.D.A. and the A.D.A. Accessibility Guidelines were just another plumbing or building code, then I would agree that we need not pursue anything that is not specifically required of us in print. However, the A.D.A. is not a plumbing code. It is a civil rights law, which prohibits any form of discrimination against people with physical disabilities.

The A.D.A. states that "No individual shall be discriminated against on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place of public accommodation", (Sec.36.201, General Requirements.) So to deny a disabled person free and unfettered access to anything within a facility, that is freely available to any non-disabled person, is a violation of that disabled person's civil rights. Equal rights in this case means equal access.

ADAAG Section 4.3.1, Accessible Buildings: New Construction, Paragraph (18), requires that "If fixed or built-in seating or tables (including, but not limited to, study carrels and student laboratory stations), are provided in accessible public or common use areas, at least five percent (5%), but not less than one, of the fixed or built-in seating areas or tables shall comply with 4.32." Then in Section 4.1.5 "Building Additions", and again in Section 4.1.6 "Building Alterations", the ADAAG requires that these building modifications conform to the rules prescribed in Section 4.3.1 for New Construction, (above). Finally, in Section A4.1.1(3) "Work Areas Used by Employees" the ADAAG elaborates on Section 4.1.3 by adding that "Where there are individual work stations (e.g., laboratories, service counters, ticket booths), 5%, but not less than one, of each type of work station should be constructed so that an individual with disabilities can maneuver within the work stations." So we can see that the A.D.A. states that all laboratories, public and private, new construction and remodel, must have provision to be accessible to and usable by the disabled.

If the disabled cannot be denied access to the laboratory to utilize the lab equipment at an accessible workstation, and thereby be exposed to the chemical hazards present, then would the Court find that the disabled person's civil rights would be violated for denying him access to the only lifesaving emergency shower and eyewash in that laboratory room? Would the Court rule in favor of the disabled if they were considering the issue after a laboratory accident, and subsequent injury of a disabled person?

The State of California seems to think that they would, because California's D.S.A. Policy 98-03 now requires a disabled accessible shower and eyewash in every laboratory classroom, for all school modernization or new construction projects, which receive state funding.

Now the dimensional requirements that would make emergency shower and eyewash accessible are also clearly defined in the ADAAG Standards, in the form of general dimensional requirements for the wheelchair, and for the wheelchair user's space requirements.

Section 4.2 "Space Allowance and Reach Ranges" covers the minimum floor space, the width of approach, and the maximum forward reach and side reach ranges. Although, while 4.2.4.1 calls for a 30" wide (minimum) approach for the wheelchair, Section A4.2.1 states that "if the wheelchair must be turned at the opening or if 'sudden' movements are needed then a clear width of 32" is adequate clearance." The 32" wide approach allows for a slightly larger margin of safety, so a 32" minimum should be used for all design considerations wherever emergency equipment, life safety and emergency egress is an issue.

Sections 4.2.5, and 4.2.6, covers the forward and side reach ranges of the wheelchair user, and you can see in Figure 5(b) "Maximum Forward Reach Over an Obstruction", that if the eyewash were to be 20" long or less, that the pull rod handle would have to be 48" above the floor (or less), but that if the eyewash were longer than 20", then the pull rod handle could be no higher than 44" above the floor.

Additional maximum and minimum dimensional information are also shown in Figure A3, and Figure A3(a), including the standard 27" minimum knee clearance.

Wall mounted "Protruding Objects" (like eyewashes), and objects that hang down into the "Head Room" space (like shower heads), are covered in Section 4.4.

"Gratings", if they are used for emergency shower floor drainage, are covered in Section 4.5.4.

"Controls and Operating Mechanisms", their maximum and minimum heights for control location, and the force required to effect the operation of any device, are covered in Section 4.27.

The laboratory work stations, as noted in Section 4.1.3, paragraph (18), are required to meet Section 4.32. And when we look in that section we find the same 27" high knee clearance that we have seen repeated throughout the ADAAG. The counter tops though are allowed to be between 28" and 34" in height, which affects all counter mounted eyewashes. However, given a 5" to 7" deep sink, where ledge-mounted pivoting eyewashes would typically be used, and allowing for the 27" high knee clearance, the counter tops could not be lower than 32".

It is important to note that ANSI Z358.1, Section 5.4.1 allows for the eyewash spray heads to be as low as 33", even for the non-disabled person, so when we consider all of these dimensional ranges we can see that they allow for a single shower & eyewash that can serve either the able bodied or the disabled.¹

Since there is typically only one emergency shower and eyewash per laboratory room or laboratory classroom, and since one accessible device can serve either the able bodied or the disabled, specifying that it be disabled accessible will help to protect the health and safety of the disabled and the able bodied, while protecting the liability exposure of the specifier, and the property owner.

All of the ADA, and the ADAAG Sections referenced in this letter are printed out for your reference on the ensuing pages, along with their related figures and diagrams.

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¹ The use of some types of emergency eyewash that are recessed into the counter top, would require that the counter be no lower than 32", regardless of whether a sink is used or not.

 

The Americans with Disabilities Act of 1990, Public Law 101336, 104, Statute 327, 42 U.S.C. 12101-12213 & 47 U.S.C. 225 & 611.

Title III Regulations, 28 CFR, Part 36, Subpart A, General Requirements

Sec.36.101 Purpose: The purpose of this part is to implement title III of the Americans with Disabilities Act of 1990 (42 U.S.C. 12181), which prohibits discrimination on the basis of disability by public accommodations and requires places of public accommodation and commercial facilities to be designed, constructed, and altered in compliance with the accessibility standards established by this part.

Sec.36.102 Application, (a) General: This part applies to any --

(1) Public accommodation;

(2) Commercial facility; or

(3) Private entity that offers examinations or courses related to applications, licensing, certification, or credentialing for secondary or postsecondary education, professional, or trade purposes

Title III Regulations, 28 CFR, Part 36, Subpart B, General Requirements

Sec. 36.201 General.

(a) Prohibition of discrimination. No individual shall be discriminated against on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place of public accommodation by any private entity who owns, leases (or leases to), or operates a place of public accommodation.

Sec. 36.203 Integrated settings.

(a) General: A public accommodation shall afford goods, services, facilities, privileges, advantages, and accommodations to an individual with a disability in the most integrated setting appropriate to the needs of the individual.

(b) Opportunity to participate: Notwithstanding the existence of separate or different programs or activities provided in accordance with this subpart, a public accommodation shall not deny an individual with a disability an opportunity to participate in such programs or activities that are not separate or different.

The ADA Standards for Accessible Design, (ADAAG)
Title III Regulations, 28 CFR, Part 36, Appendix A

3.5 Definitions.

Element. An architectural or mechanical component of a building, facility, space, or site, (e.g., telephone, curb ramp, door, drinking fountain, seating, or water closet).

Facility. All or any portion of buildings, structures, site improvements, complexes, equipment, roads, walks, passageways, parking lots, or other real or personal property located on a site.

The ADA Standards for Accessible Design, (ADAAG)
Title III Regulations, 28 CFR, Part 36, Appendix A

4.1.3 Accessible Buildings: New Construction.

Accessible buildings and facilities shall meet the following minimum requirements:

(1) At least one accessible route complying with 4.3 shall connect accessible building or facility entrances with all accessible spaces and elements within the building or facility.

(2) All objects that overhang or protrude into circulation paths shall comply with 4.4.

(3) Ground and floor surfaces along accessible routes and in accessible rooms and spaces shall comply with 4.5.

(13) Controls and operating mechanisms in accessible spaces, along accessible routes, or as parts of accessible elements (for example, light switches and dispenser controls) shall comply with 4.27.

(18) If fixed or built-in seating or tables (including, but not limited to, study carrels and student laboratory stations), are provided in accessible public or common use areas, at least five percent (5%), but not less than one, of the fixed or built-in seating areas or tables shall comply with 4.32.

4.1.5 Accessible Buildings: Additions.

Each addition to an existing building or facility shall be regarded as an alteration. Each space or element added to the existing building or facility shall comply with the applicable provisions of 4.1.1 to 4.1.3, Minimum Requirements (for New Construction) and the applicable technical specifications of 4.2 through 4.35 and sections 5 through 10. Each addition that affects or could affect the usability of an area containing a primary function shall comply with 4.1.6(2).

4.1.6 Accessible Buildings: Alterations.

(1) General. Alterations to existing buildings and facilities shall comply with the following:

(a) No alteration shall be undertaken which decreases or has the effect of decreasing accessibility or usability of a building or facility below the requirements for new construction at the time of alteration.

(b) If existing elements, spaces, or common areas are altered, then each such altered element, space, feature, or area shall comply with the applicable provisions of 4.1.1 to 4.1.3 Minimum Requirements (for New Construction). If the applicable provision for new construction requires that an element, space, or common area be on an accessible route, the altered element, space, or common area is not required to be on an accessible route except as provided in 4.1.6(2) (Alterations to an Area Containing a Primary Function.)

(c) If alterations of single elements, when considered together, amount to an alteration of a room or space in a building or facility, the entire space shall be made accessible.

4.2 Space Allowance and Reach Ranges.

4.2.4* Clear Floor or Ground Space for Wheelchairs.

4.2.4.1 Size and Approach. The minimum clear floor or ground space required to accommodate a single, stationary wheelchair and occupant is 30 in by 48 in (760 mm by 1220 mm) (see Fig. 4, see Fig. 4(a)). The minimum clear floor or ground space for wheelchairs may be positioned for forward or parallel approach to an object (see Fig. 4(b) and Fig.4(c)). Clear floor or ground space for wheelchairs may be part of the knee space required under some objects.

4.2.5* Forward Reach. If the clear floor space only allows forward approach to an object, the maximum high forward reach allowed shall be 48 in (1220 mm) (see Fig. 5 and Fig. 5(a)). The minimum low forward reach is 15 in (380 mm). If the high forward reach is over an obstruction, reach and clearances shall be as shown in Fig. 5(b).

4.2.6* Side Reach. If the clear floor space allows parallel approach by a person in a wheelchair, the maximum high side reach allowed shall be 54 in (1370 mm) and the low side reach shall be no less than 9 in (230 mm) above the floor (Fig 6, Fig. 6(a) and Fig 6(b)). If the side reach is over an obstruction, the reach and clearances shall be as shown in Fig 6(c).

4.4 Protruding Objects.

4.4.1* General. Objects projecting from walls (for example, telephones) with their leading edges between 27 in and 80 in (685 mm and 2030 mm) above the finished floor shall protrude no more than 4 in (100 mm) into walks, halls, corridors, passageways, or aisles (see Fig. 8(a)). Objects mounted with their leading edges at or below 27 in (685 mm) above the finished floor may protrude any amount (see Fig. 8(a) and (b)). Free-standing objects mounted on posts or pylons may overhang 12 in (305 mm) maximum from 27 in to 80 in (685 mm to 2030 mm) above the ground or finished floor (see Fig. 8(c) and (d)). Protruding objects shall not reduce the clear width of an accessible route or maneuvering space (see Fig. 8(e)).

4.4.2 Head Room. Walks, halls, corridors, passageways, aisles, or other circulation spaces shall have 80 in (2030 mm) minimum clear head room (see Fig. 8(a)).

4.5 Ground and Floor Surfaces.

4.5.1* General. Ground and floor surfaces along accessible routes and in accessible rooms and spaces including floors, walks, ramps, stairs, and curb ramps, shall be stable, firm, slip-resistant, and shall comply with 4.5.

4.5.4 Gratings. If gratings are located in walking surfaces, then they shall have spaces no greater than 1/2 in (13 mm) wide in one direction (see Fig. 8(g)). If gratings have elongated openings, then they shall be placed so that the long dimension is perpendicular to the dominant direction of travel (see Fig. 8(h)).

4.24 Sinks.

4.24.2 Height. Sinks shall be mounted with the counter or rim no higher than 34 in (865 mm) above the finish floor.

4.24.3 Knee Clearance. Knee clearance that is at least 27 in (685 mm) high, 30 in (760 mm) wide, and 19 in (485 mm) deep shall be provided underneath sinks.

4.24.5 Clear Floor Space. A clear floor space at least 30 in by 48 in (760 mm by 1220 mm) complying with 4.2.4 shall be provided in front of a sink to allow forward approach. The clear floor space shall be on an accessible route and shall extend a maximum of 19 in (485 mm) underneath the sink (see Fig. 32).

4.24.6 Exposed Pipes and Surfaces. Hot water and drain pipes exposed under sinks shall be insulated or otherwise configured so as to protect against contact. There shall be no sharp or abrasive surfaces under sinks.

4.24.7 Faucets. Faucets shall comply with 4.27.4. Lever-operated, push-type, touch-type, or electronically controlled mechanisms are acceptable designs.

4.27 Controls and Operating Mechanisms.

4.27.2 Clear Floor Space. Clear floor space complying with 4.2.4 that allows a forward or a parallel approach by a person using a wheelchair shall be provided at controls, dispensers, receptacles, and other operable equipment.

4.27.3* Height. The highest operable part of controls, dispensers, receptacles, and other operable equipment shall be placed within at least one of the reach ranges specified in 4.2.5 and 4.2.6.

4.27.4 Operation. Controls and operating mechanisms shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls shall be no greater than 5 lbf (22.2 N).

4.32 Fixed or Built-in Seating and Tables.

4.32.3 Knee Clearances. If seating for people in wheelchairs is provided at tables or counters, knee spaces at least 27 in (685 mm) high, 30 in (760 mm) wide, and 19 in (485 mm) deep shall be provided (see Fig. 45).

4.32.4* Height of Tables or Counters. The tops of accessible tables and counters shall be from 28 in to 34 in (710 mm to 865 mm) above the finish floor or ground.

APPENDIX

This appendix contains materials of an advisory nature and provides additional information that should help the reader to understand the minimum requirements of the guidelines or to design buildings or facilities for greater accessibility. The paragraph numbers correspond to the sections or paragraphs of the guideline to which the material relates and are therefore not consecutive (for example, A4.2.1 contains additional information relevant to 4.2.1). Sections of the guidelines for which additional material appears in this appendix have been indicated by an asterisk.

A4.1.1 Application.

A4.1.1(3), (4.1.3 Accessible Buildings ), Areas Used Only by Employees as Work Areas. Where there are a series of individual work stations of the same type (e.g., laboratories, service counters, ticket booths), 5%, but not less than one, of each type of work station should be constructed so that an individual with disabilities can maneuver within the work stations.

Work stations should comply with the applicable provisions of 4.2 through 4.35.

A4.2 Space Allowances and Reach Ranges.

A4.2.1 Wheelchair Passage Width.

(1) Space Requirements for Wheelchairs. Many persons who use wheelchairs need a 30 in (760 mm) clear opening width for doorways, gates, and the like, when the latter are entered head-on. If the person is unfamiliar with a building, if competing traffic is heavy, if sudden or frequent movements are needed, or if the wheelchair must be turned at an opening, then greater clear widths are needed. For most situations, the addition of an inch of leeway on either side is sufficient. Thus, a minimum clear width of 32 in (815 mm) will provide adequate clearance. However, when an opening or a restriction in a passageway is more than 24 in (610 mm) long, it is essentially a passageway and must be at least 36 in (915 mm) wide.

(2) Space Requirements for Use of Walking Aids. Although people who use walking aids can maneuver through clear width openings of 32 in (815 mm), they need 36 in (915 mm) wide passageways and walks for comfortable gaits. Crutch tips, often extending down at a wide angle, are a hazard in narrow passageways where they might not be seen by other pedestrians. Thus, the 36 in (915 mm) width provides a safety allowance both for the person with a disability and for others.

A4.2.4 Clear Floor or Ground Space for Wheelchairs. The wheelchair and user shown in Fig. A3 represent typical dimensions for a large adult male. The space requirements in this guideline are based upon maneuvering clearances that will accommodate most wheelchairs. Fig. A3 provides a uniform reference for design.

A4.2.5 & A4.2.6 Reach. Reach ranges for persons seated in wheelchairs may be further clarified by Fig. A3(a). These drawings approximate in the plan view the information shown in Fig. 4, 5, and 6.

A4.5 Ground and Floor Surfaces.

A4.5.1 General.

The Occupational Safety and Health Administration recommends that walking surfaces have a static coefficient of friction of 0.5. However, a research project sponsored by the Architectural and Transportation Barriers Compliance Board (Access Board) conducted tests with persons with disabilities and concluded that a higher coefficient of friction was needed by such persons. A static coefficient of friction of 0.6 is recommended for accessible routes and 0.8 for ramps.

Although it is recognized that the coefficient of friction varies considerably due to the presence of water or other contaminants.

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