Accessibility For All

Proposed changes in ADA guidelines would affect school designs.

Whether for new construction or renovation, educational facility professionals must adhere to the guidelines of the Americans with Disabilities Act. The ADA Access Guideline (ADAAG) Review Advisory Committee has proposed revisions to accessibility guidelines that, if adopted, would affect schools and universities.

Because washroom accessibility is such an important issue, numerous manufacturers offer products designed for this purpose. However, compliance involves more than installing certain types of products. How and where these products are installed will determine whether an educational facility truly is accessible.

Water closets and urinals

For both new buildings and retrofits, the ADAAG specifies that flush controls for water closets and urinals be hand-controlled or automatic. Battery-operated or hardwire sensor-operated fixtures typically function by emitting an invisible beam of infrared light. As a user enters the monitored area, this light reflects back to a sensor that controls the flushing device, putting it on hold. Once the user leaves the area, the loss of reflected light triggers the “one-time” flushing mechanism. After the cycle, the circuit automatically resets for the next user.

Manual fixtures also meet the proposed accessibility guidelines if the flushing mechanism of hand-controlled units can be operated easily with one hand and does not require grasping, pinching or twisting of the wrist, and can be actuated with less than 5 pounds of force. For adult use, the flush control must be installed within 44 inches of the floor. The typical toilet requires a maximum of 44 inches between the handle and the floor.

A clarification for urinals is addressed in the proposed ADAAG, which specifies a minimum dimension of 13.5 inches for the rim of elongated-type fixtures, measured from the outer face of the urinal rim to the back of the fixture. Although this is less than the 20-inch maximum stated in section 308.2.2, section 605.4 states specifically that 44 inches is the maximum height for urinal handles, superseding any other criteria.

Age

Maximum

Minimum

3 - 4

36"

20"

5 - 8

40"

18"

9 - 12

44"

16"

12 +

44"

15"

Height specifications for flush controls for child use:

Along with handle heights, the proposed ADAAG specifies these units must be mounted to a toilet where the top of the seat is 17 inches minimum to 19 inches maximum from the floor for adult use. Age-specific toilet seat heights:

Age

Maximum

Minimum

3 - 4

11"

12"

5 - 8

12"

15"

9 - 12

15"

17"

12 +

17"

19"

Other changes are proposed concerning the placement of water closets and clear floor space in toilet rooms. The previous standard for adults, which mandated the water closet centerline to be 18 inches from the adjacent sidewall, has been revised to allow the centerline to be 16 to 18 inches from the sidewall.

Additional revisions address rear grab bars. Rear grab bars may be split or shifted if administrative authorities require flush controls to be situated in a position that conflicts with the location of the rear grab bar.

The administrative authorities that can cause this conflict — usually interference or a tight fit between the valve and the rear grab bar, are the plumbing codes that require a minimum height of 6 inches between the critical line of the valve's vacuum breaker and the top of the water closet. This vacuum breaker requirement limits how low the valve can be installed.

Allowing the grab bar to be split or shifted to the wide side of the stall eliminates the need for offsetting flush valve models that have higher installation away from the wall so they are in front of the grab bar. While these “offset” valve models meet the requirements of the ADA, they do not meet the intent of the ADA requirements as they increase the possibility of the user coming in contact with the product.

The proposed ADAAG also would permit the use of a shorter grab bar of 24 inches if wall space is not available for a 36-inch grab bar. The grab bar must be centered on the water closet (provided there is no interference with the flush controls as noted above), and where space permits, the additional length of the grab bar must be provided on the transfer side of the water closet.

Faucets and lavatories

The ADAAG mandates lavatory and sink faucets meet requirements for operable controls and lists acceptable products that meet accessibility requirements, such as electronically controlled fixtures, lever fixtures or push fixtures. The ADAAG also states that if hand-operated, self-closing valves are used, a faucet shall remain open for at least 10 seconds and placement of all faucets must be within defined reach ranges.

Electronically controlled or “touchless” faucets employ sensors to activate on demand and comply with accessibility guidelines. Once a user's hands enter the sensing zone, water flows until there is no detection of a user or at the end of a pre-determined amount of time. The hands-free operation meets accessibility requirements.

Accessible faucets must be mounted onto ADA-compliant lavatories that are designed to meet the requirements for students of different age groups. The proposed guidelines state that accessible lavatories must be placed to provide the necessary clearance to allow a forward approach and have counter surfaces no higher than 34 inches above the floor for adult use; lavatories used primarily for children ages 6 to 12 will have counter surfaces 31 inches maximum above the floor. For children ages 5 and younger, a parallel approach to lavatories and sinks would be permitted in lieu of a forward approach.

In the proposed ADAAG, the requirement for a minimum 29-inch-high apron clearance on lavatories and sinks has been removed. New specifications clarify knee and toe clearances, making these provisions consistent with requirements for other elements, such as tables and counters. For example:

  • Forward approach

    Floor clearance space is measured in relation to the usable clear floor space, which allows for turning and maneuvering by people in wheelchairs. The clear floor or ground space for a forward approach to a lavatory shall be 30 inches minimum by 48 inches minimum including knee and toe space.

  • Parallel approach

    In applications where clear floor or ground space is in an alcove or is confined on all or part of three sides, additional maneuvering clearance should be provided. For a parallel approach, where the depth of the alcove or other restriction exceeds 15 inches, the length of the clear floor space shall be 60 inches minimum.

  • Knee and toe clearances

    The maximum depth that knee clearance will extend under an object is 25 inches (previously this dimension was 19 inches). Where clearance is required under an object as part of clear floor space, clearance shall be 11 inches minimum in depth at 9 inches above the floor, and 8 inches minimum in depth at 27 inches above the floor. Knee clearance may reduce at a rate of 1 inch for each 6 inches in height between 27 and 9 inches above the floor, and the minimum width must be at least 30 inches. A knee clearance of 24 inches minimum above the floor or ground shall be permitted at lavatories and sinks used primarily by children ages 6 to 12 where the rim or counter surface is 31 inches maximum above the floor.

The requirement for knee and toe clearance applies to only one bowl in a multi-bowl sink or lavatory and does not apply to a bathing facility for a single occupant that is accessed only through a private office and not for common use.

The proposed guidelines state that no sharp or abrasive surfaces shall be under lavatories or sinks unless insulated or configured to protect users. Also, mirrors shall be mounted with the bottom edge of the reflecting surface no higher than 40 inches above the floor, with the top edge at a minimum of 74 inches from the floor. However, a single, full-length mirror can accommodate a greater number of people, including children.

Another revision states that clearance around a water closet shall be 60 inches minimum measured perpendicular from the sidewall and 56 inches minimum measured perpendicular from the rear wall. No other fixtures or obstructions shall be within the required water closet clearance. This differs from the previous guideline that allowed lavatories on the same plumbing wall to be mounted as close as 18 inches from the centerline of the water closet. The proposed guidelines recommend that fixtures, including lavatories, not be permitted to overlap the 60-inch-wide space at water closets, which will allow space for side transfers. The toilet paper dispenser and grab bars are allowed to encroach in this space.

The proposed changes in the ADAAG can be viewed at www.access-board.gov/ada-aba/guidenprm.htm.

Notable

Age-specific toilet-seat and height requirements in the proposed ADAAG:

  • 3 TO 4 YEARS OLD

    Flush controls: 20 to 36 inches Toilet seat: 11 to 12 inches

  • 5 TO 8 YEARS OLD

    Flush controls: 18 to 40 inches Toilet seat: 12 to 15 inches

  • 9 TO 12 YEARS OLD

    Flush controls: 16 to 44 inches Toilet seat: 15 to 17 inches

  • 12+ YEARS OLD

    Flush controls: 15 to 44 inches Toilet seat: 17 to 19 inches

Lauer is director of technical support services with Sloan Valve Company, Franklin Park, Ill.

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