ADA for Emergency Equipment

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 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.

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.