Common ADA Violations - Exposed Drain and Supply Lines at Lavatories

I often get asked about common ADA violations. There are many different ones that I see while doing inspections. Often it seems that they can be the same violations. I hope these images help to understand the requirements.

The image above illustrates a common violation that I see a lot. ADA requires that the drain lines and water supply lines be fully insulated or concealed to protect against contact. People in wheelchairs often don’t have feelings in the legs. Whenever these surfaces get hot they can burn flesh and cause infections. Also, there shall be no sharp or abrasive surfaces underneath the lavatory.

There are several manufacturers that make the wrap to put around the drain lines and water supply lines. They should be checked regularly to make sure that they are still there. I often see them missing or just falling apart.

Below are some examples of this requirement being achieved in different ways. I have also included some violations that I have run into. You never know what you are going to find during inspections.

Insulation provided, very clean install, well done

This has a shroud over everything, no insulation required

This is a common solution with a panel covering everything

Insulation is provided at drain but it does not go all the way to the top and water supply insulation is sitting behind one and the other is completely missing

The panel is missing and there is no insulation covering the pipes

This is a weird one, it has a panel, but the bottom of the pipe is partially exposed, no insulation. Would you note this as a violation or is it close enough?

ADA Requirements:

606.5 Exposed Pipes and Surfaces. Water supply and drain pipes under lavatories and sinks shall be insulated or otherwise configured to protect against contact. There shall be no sharp or abrasive surfaces under lavatories and sinks

Feel free to posts any comments or questions.

Clint Ryan, RAS | Owner

Does This Teller Counter Comply With The ADA Standards?

This image is from a bank that I inspected a while back. Unfortunately, they did not pay the original RAS to do the Plan Review or Inspection and they ended up getting a letter from the state threatening fines if they did not get them completed. They asked me to get involved. When I starting reviewing the construction documents I noticed that they showed the ADA portion of the teller counter being built incorrectly. When I got to the site I realized that it was built just like the drawings, which was not compliant. I hate to see this happen because I or any other RAS could have prevented this from happening.

As you can see from the image they built the back counter at 42” all the way across and then attached an “ADA” counter to the front of the millwork. However, the accessible portion is required to be the same depth as the adjacent surface. Also, the counter appears that it provides a forward approach, but the depth is not compliant for knee and toe clearance. These types of counters allow for a parallel approach, but the length of the counter must be 36” wide or the entire length of the counter must be 36” above the finish floor.

ADA Requirements:

Scoping (How Many):

227.3 Counters. Where provided, at least one of each type of sales counter and service counter shall comply with 904.4. Where counters are dispersed throughout the building or facility, counters complying with 904.4 also shall be dispersed.

Advisory 227.3 Counters. Types of counters that provide different services in the same facility include, but are not limited to, order, pick-up, express, and returns. One continuous counter can be used to provide different types of service. For example, order and pick-up are different services. It would not be acceptable to provide access only to the part of the counter where orders are taken when orders are picked-up at a different location on the same counter. Both the order and pick-up section of the counter must be accessible.

Technical:

904.4 Sales and Service Counters. Sales counters and service counters shall comply with 904.4.1 or 904.4.2. The accessible portion of the counter top shall extend the same depth as the sales or service counter top.

904.4.1 Parallel Approach. A portion of the counter surface that is 36 inches (915 mm) long minimum and 36 inches (915 mm) high maximum above the finish floor shall be provided. A clear floor or ground space complying with 305 shall be positioned for a parallel approach adjacent to the 36 inch (915 mm) minimum length of counter.

EXCEPTION: Where the provided counter surface is less than 36 inches (915 mm) long, the entire counter surface shall be 36 inches (915 mm) high maximum above the finish floor.

904.4.2 Forward Approach. A portion of the counter surface that is 30 inches (760 mm) long minimum and 36 inches (915 mm) high maximum shall be provided. Knee and toe space complying with 306 shall be provided under the counter. A clear floor or ground space complying with 305 shall be positioned for a forward approach to the counter.

Feel free to posts any comments or questions.

Clint Ryan, RAS | Owner

Does This Deadbolt Comply With ADA?

This image shows a door with a deadbolt and a thumbturn. There are a lot of manufacturers that make these types of locks, but the lever must be easily rotated with a loose grip or closed fist. A smaller lever may require tight grasping, pinching or twisting of the wrist, which is not allowed. Most manufacturers will list if their product complies with ADA standards. This is not always true but without that certification you should at least continue looking elsewhere.

ADA Requirements:

ADA requires that door and gate hardware including handles, pulls, latches, locks and other operable parts comply with Operable Parts. (309.4 and 404.2.7).

309.4 Operation. Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.

404.2.7 Door and Gate Hardware. Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4…

Also, the height of the door hardware shall be installed between 34” and 48” above the finish floor, (404.2.7). I usually see this done correctly but occasional it will be placed outside of this range.

404.2.7 Door and Gate Hardware. …Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground…

Feel free to posts any comments or questions.

Clint Ryan, RAS | Owner