February 2017 - Abadi Access Abadi Access

Sinks and Lavatories

In the 2010 ADA and the 2012 TAS requires that 5% but no less than 1 sink must be accessible. One of the requirements of accessibility at sinks is to have a knee space under the sink. But there is a few exceptions. The one we will focus on this time is the first exception:

606.2 Clear Floor Space Exception 1: A parallel approach complying with 305 shall be permitted to a kitchen sink in a space where a cook top or conventional range is not provided, and to wet bars.

The Texas Department of Licensing and Regulation issued a bulletin whichdefines “kichen sink” And another technical memo that explains when this exception can be taken and when it cannot. This newsletter will explain it as well.

Does my sink at a break room have to have a knee space?

It depends (don’t you love that answer?)…..

It depends on whether the break room is a kitchen or not. But it can’t be our definition of a “kitchen”, but the dictionaries definition. When dealing with terms that the ADA and TAS do not define, we are directed by the US Access Board to use the Webster’s definitions:

-Kitchen: A place (as a room) with cooking facilities.

-Kitchenette: A small kitchen or alcove containing cooking facilities.

-Wet Bar: A bar for mixing drinks that contains a sink with running water.

-Cooking Facilities: Fixed or built-in range, cook top, oven, microwave, or convection oven.

-Fixed Appliance: When attached to a cabinet, shelf or other surface or to a gas supply.

-Built -In Appliance: When cabinetry design or location of utilities (i.e.. gas supply or 220V electrical outlets) creates a dedicated shelf or space for the appliance.

So, if a break room has no fixed “cooking facilities” within, then it is not considered a “kitchen” and therefore it must have a proper knee clearance at the sink.

This break room has a microwave in a shelf, but it is not fixed or built in. Because it is not considered a “fixed cooking facility”, this space is not a ‘kitchen” and the sink will require a knee space.

If on the other hand, the break room has a fixed cooking appliance, like a fixed microwave, wall ovens, or a range, then it is a kitchen.

If it is a kitchen and has a cook top or a range, then a knee space at the sink will be required.

This break room is a kitchen because it has both a range and a fixed microwave oven. Therefore the sink must have a knee space. In addition, all appliances must be accessible, and 50% of the shelving must be within reach. This breakroom should follow section 804 for kitchens.

But if the break room has a built in microwave or oven, then it will still be considered a “kitchen” but now the sink can take the exception and have a parallel approach rather than a front approach.

This break room has a built in oven, but no range or cook top. This break room is considered a “kitchen”, but can take the exception for the knee space per 606.2

Wet bars and other sinks

According to Exception #1, another location where a knee space at a sink is not required is at wet bars. Wet bars is a place where drinks are mixed.They are typically found either at hotels or sometimes even at waiting rooms. According to TDLR, a break room is not a wet bar.

This is a wet bar and does not require a knee space

Sinks that are part of a “work” area and only used for work related things, like a commercial kitchen, teacher’s work room, medical labs etc., are exempted from having to comply.