REQUIREMENTS FOR ACCESSIBLE AND STANDARD HEIGHTS OF COAT HOOKS IN TOILET ROOMS

Coat hooks are not required in accessible toilet rooms or stalls; however, where they are provided code requires that at least one must comply. If a second one is provided, it is not required to be accessible. Also, coat hooks placed in non-accessible stalls are not required to be at an accessible height.

The code states that coat hooks must be located within one of the reach ranges of 48" (1220 mm) maximum & 15" (380 mm) minimum above the finish floor. Accessible coat hooks are usually placed at 44" (1115 mm) measured to the center line of the unit. While it is acceptable to place them lower, it would be difficult to reach them and jackets or other clothing that are hung could drag against the floor.

The non-accessible standard height of a coat hook is usually based on the average adult human size. Based on standard human dimensions of shoulder to eye height coat hooks should be placed at 60" (1520 mm) to 66" (1680 mm). A standard height coat hook is not required or specified by the accessibility standards.

 

Accessible & Standard Height Coat Hooks

REQUIREMENTS FOR ACCESSIBLE REACH RANGES

Reach ranges are a basic building block in the accessibility code.  They are used throughout to determine the height of elements.  Below is a list of elements where reach ranges are specified in the code.  Review each element in the code as some have special considerations or exceptions.

1. Coat Hooks and Shelves

2. Elevator Call Buttons, Keypads, Controls & Emergency Communication

3. Food Service Lines

4. Fuel Dispensers

5. Lockers

6. Operable Parts

7. Self-Service Shelving & Dispensing Devices

8. Soap Dispensers

9. Storage

10. Telephone TTYs

11. Towel Dispensers

12. Washing Machines

Accessibility Standards Requires:

308.2.1 Forward Reach - Unobstructed. 

• Where a forward reach is unobstructed, the high forward reach must be 48" max & the low forward reach shall be 15" min above the finish floor or ground. Refer to Figure A.

Figure A - Forward Reach - Unobstructed

308.2.2 Forward Reach - Obstructed.

• Where a high forward reach is over an obstruction, the clear floor space must extend beneath the element for a distance not less than the required reach depth over the obstruction.

• The high forward reach shall be 48" max where the reach depth is 20" max. Refer to Figure B.

• Where the reach depth exceeds 20", the high forward reach shall be 44" max & the reach depth shall be 25" max. Refer to Figure C.

Figure B - Forward Reach - Obstructed

Figure C - Forward Reach - Obstructed

308.3.1 Side Reach - Unobstructed.

• Where a clear floor or ground space allows a parallel approach to an element & the side reach is unobstructed, the high side reach shall be 48" max & the low side reach shall be 15" min above the finish floor or ground. Refer to Figure D.

Figure D - Side Reach - Unobstructed

308.3.2 Side Reach - Obstructed.

• Where a clear floor or ground space allows a parallel approach to an element & the high side reach is over an obstruction, the height of the obstruction shall be 34" max & the depth of the obstruction shall be 24" max. (308.3.2 Obstructed High Reach)

• The high side reach shall be 48" max for a reach depth of 10" max. Refer to Figure E. (308.3.2 Obstructed High Reach)

• Where the reach depth exceeds 10", the high side reach shall be 46" max for a reach depth of 24" max. Refer to Figure F. (308.3.2 Obstructed High Reach)

Figure E - Side Reach - Obstructed

Figure F - Side Reach - Obstructed

UNDERSTANDING THE DIFFERENCE BETWEEN A BREAK ROOM AND A KITCHEN

Ever wonder what the difference is between a break room and a kitchen? There have been 3 technical memorandums issued from TDLR trying to resolve this question. The first, TM 2012-09 Employee Break Rooms, explains the difference between a break room and a kitchen. Memos, TM 2013-22 and 2013-23, provide clarifications to the storage requirements for each.

According to TDLR, the difference between a break room and a kitchen can be determined by answering one simple question: does the space contain cooking facilities that are built-in or fixed? Cooking facilities, defined as cooktops, ranges, ovens, convection ovens or microwaves, are considered built-in or fixed if they are attached to a cabinet, shelf or wall; connected to plumbing or gas; or hardwired to electricity. 

Why is it important to differentiate? Each type of room has its own requirements with regards to approach to the sink and storage. Establishing whether a room is a break room or kitchen will help you determine whether a parallel approach to a sink is permitted and what type and how much storage space must be compliant. There are some other differences, as well, which we will outline and discuss below.

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BREAK ROOM

No fixed or built-in cooking facilities

Sink

• A break room is required to have a forward approach to a sink. Refer to Figure G. (606.2 Clear Floor Space)

• Clear floor space and knee and toe clearance under the sink is required. Refer to Figure H. (606.2 Clear Floor Space)

• Sinks must be installed with the front of the higher of the rim or counter surface 34" max above the finish floor or ground. Refer to Figure J. (606.3 Height)

Figure G - Break Room Sink Forward Approach

Figure H - Break Room Sink Knee & Toe Clearance

Figure J - Sink Height

Storage Elements

• For storage elements, at least one of each type must be within the standard reach ranges. (225.2 Storage)

• Type refers to the design of the element (i.e. closets, cabinets, shelves , clothes rods, hooks and drawers) as well as the intended use (i.e. coat closets and supply closets). (Advisory 225.2 Storage and Technical Memorandum 2013-23)

• In order to comply with TAS 225.2, base and wall cabinets shall be considered the same type if designed the same (i.e. both have doors), used for the same purpose and located in the same room. Refer to Figure K . (Technical Memorandum 2013-23)

Figure K - Break Room Storage One of Each Type

Appliances

• Appliances are not required to comply.

• Microwaves are permitted to be placed on an open shelf out of reach range, but there must be another open shelf within reach range that could be used for the same purpose.

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KITCHEN

Fixed or built-in cooking facilities

Sink

• A kitchen is permitted to have a parallel approach to a sink, unless a cook top or range is provided. A parallel approach to a wet bar is always permitted. Refer to Figure L.

Figure L - Kitchen Parallel Approach

Storage Elements

• For the storage elements, at least 50% of shelf spaces shall comply with reach ranges. This can be derived by calculating the linear distance of all shelf spaces and drawers and dividing that total in half. Refer to Figure M.

Figure M - 50% Shelf Space in Reach Range

Appliances

• Appliances must comply with the requirements of 804.6 Appliances.

• Clear floor space must be provided at each kitchen appliance. (804.6.1 Clear Floor or Ground Space)

• All appliance controls must comply with operable parts and be within reach ranges. (804.6.2 Operable Parts)

• There are additional requirements for appliances, which will not be discussed here. For full details, refer to 804.6 Appliances.