January 2018: Questions and Answers

Posted on - Thursday, January 4th, 2018
This past year I have received some questions that I thought would be good to share with my readers.  I hope you find these useful

Question:

Is there a requirement in the ADA to always provide a double unit for drinking fountains?

Answer:

No. The requirement for drinking fountains per section 211.2 is that no fewer than two drinking fountains be provided. If you have just one, you must add a second one. One of the drinking fountains should be for people who use wheelchairs and the second drinking fountain should be for people who cannot bend down and will be standing. Keep in mind that this provision is also for exterior sites on a floor or within a secured area. Therefore, if there are any drinking fountains in those areas, there should be two of them.
You may use a “hi-lo” unit or you can have them as two separate units. This section also does not require that you provide them in the same place. As long as your count yields 50% for wheel chairs and 50% for standing persons located somewhere in the facility.

This is a hi-lo unit that also has a bottle filler. A bottle filler by itself cannot substitute one of the drinking fountains

In case you are designing for children, you cannot substitute one of the required drinking fountains for a child height drinking fountain. The child drinking fountain will have to be a third one that is provided.

Question:

What is the difference between a toilet compartment and a toilet room?

Answer:

A toilet compartment generally is located in a toilet room where other toilet fixtures are provided as well. They are typically located in a multi-user restroom. What can get confusing is when the toilet compartment partitions are constructed out of gypsum walls instead of the typical metal or plastic laminate partitions.

this is a toilet compartment that is made of walls that go from floor to ceiling

Even if the toilet compartments are made out of gypsum walls that go from floor to ceiling, they are still considered “compartments” and not toilet rooms.

this is a multi-user toilet room with toilet compartments within

A toilet room, on the other hand, has more than just a toilet within. It typically will have a lavatory or sometimes even a shower. A toilet room could also have two water closets, or a urinal and a lavatory. In those scenario, there are other requirements that you must adhere to, such as door maneuvering clearances, and turning space.

this plan shows a toilet room with a water closet and lavatory

Unlike a toilet room, a toilet compartment does not require a turning space within, although door maneuvering clearances will be required.

Question:

If a restroom is not a public space per se, but for a worker or staff, are we still required to provide it as accessible?

Answer:

Yes. 100% of all toilet rooms are required to be accessible. A staff toilet or a non-public toilet are not exempted. There are some exceptions for single user unisex restrooms that are clustered together. Those will only require 50% of them to be accessible. And even private toilet rooms that are accessed by someone’s office only are not fully exempted and must comply with certain requirements. I wrote a newsletter about that if you would like more information.

Question:

Is the distance of a double toilet paper dispenser from the edge of the toilet seat measured to the middle of the dispenser as a unit? to the closest roll? or to the furthest roll?

Answer:

We measure the toilet paper dispenser to the centerline of the double roll.

Question:

We are designing in an existing campus that has 4 main buildings on it with 9 parking lots and 1 parking garage. In reading TAS, it says that each parking “facility” shall have its own accessible spaces and that parking “facility” is the same as a parking “lot”. We understand that Lot E (for example) would need its own calculation for ADA spots (223 total = 7 ADA), but you wouldn’t locate them in Lot E, would you? I would think that you would want those 7 spots to be located in Lot B, closer to the buildings. Can we designate them as ADA spots in one Lot for a different Lot?

Answer:

Their assumption was correct. Even though the ADA and TAS require that each parking facility have its own set of accessible parking spaces, there is also a requirement (208.3.1) that the accessible parking spaces be located on the closest accessible route to the entrance of the building they serve.
There is an exception under 208.3.1 #2 that states that “parking spaces shall be permitted to be located in different parking facilities if substantially equivalent or greater accessibility is provided in terms of distance from an accessible entrance , or entrance fee and user convenience.”