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Texas Department of Licensing and Regulation
Kitchens, Kitchenettes & Comparable Spaces Texas Accessibility Standards
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Texas Department of Licensing and Regulation Architectural Barriers Program
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This presentation will identify the compliance requirements of the 2012 Texas Accessibility Standards (TAS) for kitchens, kitchenettes, and other comparable spaces such as break rooms.
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Kitchens, Kitchenettes,
This topic is also addressed in: RAS Bulletin Kitchens, Kitchenettes, and Comparable Spaces The contents of this bulletin have been incorporated into this presentation.
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Portions of the following scoping and technical sections of the 2012 TAS will be discussed during this presentation:
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Chapter 2: Scoping Requirements 106.3 Undefined Terms 201.1 Scope 212
Kitchens, Kitchenettes, and Sinks 225 Storage Chapter 6: Plumbing Elements and Facilities 606 Sinks Chapter 8: Special Rooms, Spaces, and Elements 804 Kitchens and Kitchenettes 811
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Scoping: 106 Undefined Terms
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106.3 Undefined Terms The meaning of terms not specifically defined in or in regulations issued by TDLR to implement Chapter 469, or in referenced standards, are as defined by collegiate dictionaries in the sense that the context implies. The following terms are not defined in TAS, therefore, based on 106.3, they shall have the following meanings:
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Kitchen Kitchenette A place (as a room) with cooking facilities.
A small kitchen or alcove containing cooking facilities. These terms are used interchangeably. Excerpt from
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Cooking Facilities This term is not defined in collegiate dictionaries, however, “Cook” means “To prepare food for eating especially by means of heat.” Therefore, based on this definition and input from the U.S. Access Board, cooking facilities shall include the following: Range Oven Cooktop Microwave Oven Convection Oven Excerpt from
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A bar used for purposes other than drink preparation is not a wet bar.
A bar for mixing drinks that contains only a sink with running water. A bar used for purposes other than drink preparation is not a wet bar.
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Scoping: 201.1 Scope Fixed or Built-In
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201.1 Scope These standards apply to fixed or built-in elements of buildings…
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Since TAS only applies to fixed or built-in elements based on 201
Since TAS only applies to fixed or built-in elements based on 201.1, the “cooking facilities” provided in a space must be fixed or built-in for the space to be considered a kitchen or kitchenette. The following is the criteria to be used when determining if an appliance is fixed or built-in:
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Fixed The appliance is attached to a cabinet, shelf, or other surfaces or to a gas supply. Built-In The cabinetry design or location of utilities (i.e. gas supply or 220V electrical outlet) creates a dedicated shelf or space for the appliance. The following are examples of fixed and built-in cooking facilities:
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Fixed Microwave Ovens Attached to Cabinet Attached to Shelf
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Built-In Microwave Ovens
Cabinetry design and location of electrical outlet creates dedicated space for the microwave oven.
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Built-In Convection Oven
Cabinetry design and location of 220V outlet creates a dedicated space for the convection oven.
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These microwaves are NOT
built-in or fixed.
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Fixed and Built-In Ranges
Cabinetry design and location of electrical and gas outlets create a dedicated space for the range.
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Attached to a Gas Supply
Fixed Gas Range Attached to a Gas Supply
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Fixed or Built-in Cooktop
Appliance is attached and the cabinetry design and location of electrical outlet creates a dedicated space for the cooktop.
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SUMMARY
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Built-In Cooking Facilities
Spaces With Fixed or Built-In Cooking Facilities The space must comply with 212 and 804 if at least one of the following fixed or built-in cooking facilities is provided: Range Oven Cooktop Microwave Oven Convection Oven
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Spaces Without Fixed or Built-In Cooking Facilities
The space is not required to comply with 212 and 804 if no fixed or built-in cooking facilities are provided. However, the space must still comply with applicable provisions of TAS.
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This space has no fixed or built-in cooking facilities
Example: NOT a Kitchen This space has no fixed or built-in cooking facilities
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Compliance Requirements
Not a Kitchen: Compliance Requirements Compliance with TAS is based on the elements provided. Example: Typical requirements for spaces that are not kitchens Operable parts must comply with 309 based on 205. At least one of each type of storage must comply with 309 based on 5% of the sinks must comply with 606 based on
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Counter Height Not a Kitchen
No counter height requirement (except at a sink) for spaces that are not kitchens since is applicable only to work surfaces in residential and transient lodging kitchens. Example: Storage and operable parts must comply but not the counter height. Excerpt from
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Test Your Knowledge
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Yes! Is This A Kitchen? Space has a cooking facility (range).
Compliance with 212 and 804 is required. Yes!
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Kitchen? Yes! Space has a cooking facility (fixed microwave).
Compliance with 212 and 804 is required.
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Scoping: 201.1 Scope, Contd. How Many?
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201.1 Scope These requirements (TAS) are to be applied to all areas of a facility: Unless exempted* or Where scoping limits the number of multiple elements required to be accessible. *Exemptions are identified in Rule and TAS 203 and will not be discussed during this presentation.
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common and public use spaces?
How does apply to common and public use spaces? Common and public use spaces (defined below) such as break rooms and classroom kitchens are not exempted by Rule or TAS 203. Common Use: …spaces made available for the shared use of two or more people. ( ). Public Use: …spaces in privately or publically owned buildings that are made available to the public. ( ).
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Where provided, kitchens, kitchenettes,
In addition, the scoping for kitchens (noted below) does not limit the number of common or public use kitchens required to be accessible. Where provided, kitchens, kitchenettes, and sinks shall comply with 212. (212.1). Therefore, 100% of all common and public use kitchens must be accessible.
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The following slides identify additional entities that must comply with 804 (Kitchens and Kitchenettes).
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Residential
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Residential Facilities
Residential facilities include the following: Social Service Establishments (See 224.1, Exception 2) Graduate Student and Faculty Housing (See 224.6, Exception 3) Crew Quarters for Emergency Response Personnel (See RAS Bulletin )
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809 Residential Dwelling Units
809.3 Kitchen. Where a kitchen is provided, it shall comply with 804. Excerpt from
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Major Differences Between Kitchens in Residential Facilities & Other Kitchens
Accessible work surface is required based on (optional in other types of kitchens but recommended except in housing at a place of education based on Exception 1). Knee and toe spaces under sinks and work surfaces can contain cabinetry if the exception criteria of 606.3(2) and are met. 804.3 and the referenced exceptions will be discussed later in the presentation.
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Transient Lodging
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Transient Lodging Facilities
Transient lodging facilities include the following: Hotels, Motels, and Other Places of Lodging Including Timeshares (224.1) Housing at a Place of Education (224.6 and Exception 1)
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806 Transient Lodging Guest Rooms
806.2 Guest Rooms with Mobility Features Kitchens and Kitchenettes. Kitchens and kitchenettes shall comply with 804. Excerpt from
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Employee Spaces
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Not Required to be Accessible
Employee Work Areas Not Required to be Accessible Employee work areas are not required to be accessible except to the extent required by based on the following definition: All or any portion of a space used only by employees and used only for work ( ).
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Examples: Employee Work Areas
Restaurant Kitchen Work Area of Demonstration Kitchen
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Required to be Accessible
Break Rooms Required to be Accessible Kitchenettes and break rooms are not employee work areas also based on the definition of “Employee Work Area” in
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Kitchens & Kitchenettes
Scoping: 212 Technical: 804 Kitchens & Kitchenettes
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212 Kitchens & Kitchenettes
Scoping
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212.2 Kitchens and Kitchenettes
Kitchens and kitchenettes shall comply with 804.
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804 Kitchens and Kitchenettes
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Kitchen Types U‐Shaped Pass Through
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Pass Through Kitchen 804.2 Clearance
Where a pass through kitchen is provided, clearances shall comply with
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Pass Through Kitchens In pass through kitchens where counters, appliances or cabinets are on two opposing sides, or where counters, appliances or cabinets are opposite a parallel wall, clearance between all opposing base cabinets, counter tops, appliances, or walls within kitchen work areas shall be 40” minimum.
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804.1 Advisory Measuring Clearances
Clearances are measured from the furthest projecting face of all opposing: base cabinets counter tops appliances walls… …excluding hardware.
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Pass through kitchens shall have two entries (804.2.1).
Cabinets on opposing sides. Cabinets opposite a wall. 40” min. 40” min.
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Example: Measuring Clearances
Furthest projecting face of appliance Furthest projecting face of wall A B 40” min.
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Example: Measuring Clearances
Measured from all opposing base cabinets
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U-Shaped Kitchen 804.2 Clearance
Where a U-shaped kitchen is provided, clearances shall comply with
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U-Shaped Kitchen In U-shaped kitchens enclosed on three contiguous sides, clearance between all opposing base cabinets, counter tops, appliances, or walls within kitchen work areas shall be 60” minimum.
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Acceptable: The 30” clear floor space for the work surface can be used as part of a T-shape turning space, if the clear floor space is increased to 36” ( Advisory). EXAMPLE: Knee and toe clearance at base of “T”. 60” front of “T” shall always be unobstructed. Base Arm
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Unacceptable: Both clearances cannot be used under the work surface and the sink, as part of a T-shape turning space, since the knee and toe clearance is permitted only: Arm At the end of the base or One arm. Base (see and )
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Clear Floor Space in Alcoves
A forward approach requires 6” of additional maneuvering clearance when the clear floor space is located in an alcove deeper than 24” ( ). >24” >24” 36” If, therefore, the counter depth is more than 24”, the clear floor space must be 36” min. in lieu of 30” min. ( ).
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(Spaces without Cooktop or Range)
804.2 Exception: Clearances (Spaces without Cooktop or Range) Spaces that do not provide a cooktop or conventional range are not required to comply with the clearance requirements of (804.2 Exception).
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These U-shaped kitchen designs can be used without the 60” clearance where there is no conventional range or cooktop is provided based on the Exception to
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804.3 Kitchen Work Surface
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804.3 Kitchen Work Surface In residential dwelling units required to comply with 809, at least one 30” wide minimum section of counter shall provide a kitchen work surface that complies with Residential Dwelling Units Required to Comply with 809 Social Service Establishments 224.1, Exception 1 Crew Quarters for Emergency Response Personnel Graduate Student and Faculty Housing at Places of Education 224.6, Exception 3
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Housing at a Place of Education
Kitchen Work Surface Housing at a Place of Education Although housing at a place of education is subject to transient lodging requirements based on 224.6, kitchen work surfaces must also comply with based on 224.6, Exception 1.* *Exception: Housing for graduate students and faculty is subject to residential requirements based on (3).
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804.3.1 Clear Floor or Ground Space: Kitchen Work Surface
A clear floor space complying with 305 positioned for a forward approach shall be provided. The clear floor or ground space shall be centered on the kitchen work surface and shall provide knee and toe clearance complying with 306.
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804.3.1 Exception: Clear Floor Space: Kitchen Work Surface
Cabinetry is permitted under the kitchen work surface provided that all of the following conditions are met: (a) the cabinetry can be removed without removal or replacement of the kitchen work surface; (b) the finish floor extends under the cabinetry; and (c) the walls behind and surrounding the cabinetry are finished.
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Example: Removal Cabinetry
Standard sink Knee clearance Pipe protection Fair Housing Design Manual
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804.3.2 Height Kitchen Work Surface
The kitchen work surface shall be 34” maximum above the finish floor or ground.
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Height: Kitchen Work Surface
Exception: Height: Kitchen Work Surface A counter that is adjustable to provide a kitchen work surface at variable heights, 29” minimum and 36” maximum is permitted ( Exception)
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804.3.3 Exposed Surfaces Kitchen Work Surface
There shall be no sharp or abrasive surfaces under the work surface counters. This requirement was formerly only applicable to sinks and lavatories.
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Kitchens and Kitchenettes
804.4 Sinks Kitchens and Kitchenettes
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804.4 Sinks Sinks shall comply with 606.
The sinks required by are considered “kitchen” sinks for purposes of compliance with 606.2, Exception 1.
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606 Sinks
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606.1 Sinks If soap and towel dispensers are provided, they shall be located within the reach ranges specified in 308 (606.1 Advisory).
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606.2 Clear Floor Space The following shall be provided:
Clear floor space complying with 305. Positioned for a forward approach. Knee and toe clearance complying with 306. Unless specifically noted in the standards, clear floor space is not required to be centered on the element.
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606.2 Exception 1: Clear Floor Space Kitchen Sinks
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 (606.2 Exception 1)
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Kitchen Not a Kitchen Parallel approach Front approach
With cooking facility; Must comply with 212 and 804. Parallel approach allowed to kitchen sink based on 606.2, Exception 1 since there is no cooktop or stove. Not a Kitchen No cooking facilities; Must comply with applicable provisions of TAS. Front approach required since Exception 1 is applicable only to kitchen sinks.
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Length of Accessible Sink Counter
30” min. length of accessible sink counter required for a forward approach (305.5). 48” min. length of counter required for a parallel approach (305.5). Forward Approach (305.5) Parallel Approach (305.5)
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606.2 Exception 1, Contd.: Clear Floor Space Wet Bars
A parallel approach complying with 305 shall be permitted to wet bars (606.2, Exception 1) Example: Wet Bar
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Clear Floor Space: Lavatories/Sinks Residential Dwelling Units
606.2 Exception 3: Clear Floor Space: Lavatories/Sinks Residential Dwelling Units In residential dwelling units, cabinetry shall be permitted under lavatories and kitchen sinks provided that all of the following conditions are met: (a) the cabinetry can be removed without removal or replacement of the fixture; (b) the finish floor extends under the cabinetry; and (c) the walls behind and surrounding the cabinetry are finished.
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Examples: Removal Cabinetry
A kitchen sink and a lavatory (in a residential dwelling unit) that meets the criteria under 606.2, Exception 3 (a),(b),&(c). When the cabinetry is removed to allow for the clear floor space, it is important that exposed pipes and surfaces comply with
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606.2 Exception 4 & 5: Clear Floor Space Children’s Use
6 through 12 years: Knee clearance of 24” min. above the finish floor or ground is permitted at lavatories and sinks where rim or counter surface is 31” maximum (606.2 Exception 4). 5 years and younger: A parallel approach is permitted to lavatories and sinks (606.2 Exception 5). Clear floor space not required to be centered on the element except where specified in the standards
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606.2 Exception 6: Clear Floor Space Overflow
The dip of the overflow is not considered in determining knee and toe clearances.
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606.2 Exception 7: Clear Floor Space Multi-Bowl Sink
No more than one bowl of a multi-bowl sink is required to provide knee and toe clearance.
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Sink: Depth No specific requirements in the 2012 TAS for sink depth since depth is dependent on the approach allowed or required. Forward Approach: 27” min. knee clearance ( ). 34” maximum sink height (606.3). Typically, the maximum sink depth will be 7”. Parallel Approach: Knee clearance not required so no maximum sink depth.
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606.3 Height Sinks Sinks shall be installed with the front of the higher of the rim or counter surface 34” maximum above the finish floor or ground (606.3).
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Residential Dwelling Units
606.3 Exception 2: Height: Kitchen Sink Residential Dwelling Units In residential dwelling unit kitchens, sinks that are adjustable to variable heights, 29” minimum and 36” maximum are permitted where rough-in plumbing permits connections of supply and drain pipes for sinks mounted at the height of 29” (603.3 Exception 2).
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606.4 Faucets 606.5 Exposed Pipes and Surfaces
Faucet controls shall comply with operable part requirements in 309 (606.4). Hand operated metering faucets shall remain open 10 seconds min. (606.4). Water supply and drain pipes shall be insulated or configured to protect against contact (606.5).
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Kitchens and Kitchenettes
804.5 Storage Kitchens and Kitchenettes
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Kitchens and Kitchenettes
804.5 Storage Kitchens and Kitchenettes At least 50% of shelf space in storage facilities shall comply with the storage requirements of 811.
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Storage: Kitchens & Kitchenettes
Calculate storage by linear feet. 15” min. to 48” max. EXAMPLE: Unobstructed forward reach ( ).
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Storage: Not a Kitchen Storage in comparable spaces must comply with 225 and 811, therefore, at least one of each type of storage must be accessible (225.2).
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811 Storage
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811 Storage General. Storage shall comply with 811.
Clear Floor or Ground Space. A clear floor or ground space complying with 305 shall be provided (811.2). Height. Storage elements shall comply with at least one of the reach ranges specified in 308 (811.3).
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Obstructed High Reach: 10” Obstruction
This scenario is unlikely due to the depth of base cabinets. 48 max Figure (a) shows wheelchair user reach of 48” maximum when the counter is at 34” maximum and the depth of the counter is 10” maximum ( ).
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Obstructed High Reach: 24” Obstruction
46 max This scenario is will apply the most often due to the depth of base cabinets. Figure (b) shows the upper reach lowered to 46” maximum when the counter top is 34” maximum but the depth of the counter exceeds 10” (24” maximum) ( ).
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811.4 Operable Parts – Storage
Operable parts shall comply with 309.* *309 (Operable Parts) includes requirements for clear floor space, height, and operation.
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Kitchens and Kitchenettes
804.6 Appliances Kitchens and Kitchenettes
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Appliances All kitchen appliances must be comply with:
– Clear Floor or Ground Space – Operable Parts However, there are more specific requirements for the following: Dishwashers Ranges or Cooktops Ovens Refrigerators/Freezers
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Kitchens and Kitchenettes
804.6 Appliances Kitchens and Kitchenettes Where provided, kitchen appliances shall comply with Clear Floor or Ground Space A clear floor or ground space complying with 305 shall be provided at each kitchen appliance. Clear floor or ground spaces are permitted to overlap.
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804.6.2 Operable Parts Appliances
All appliance controls shall comply with 309.
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Operable Parts: Appliances
Exceptions 1 & 2: Operable Parts: Appliances Appliance doors and door latching devices shall not be required to comply with (operation requirement of) ( , Exception 1). Bottom-hinged appliance doors, when in the open position, shall not be required to comply with (height requirements of) ( , Exception 2). Examples of accessible appliance controls
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Dishwasher Clear floor or ground space shall be positioned adjacent to the dishwasher door. The dishwasher door, in the open position, shall not obstruct the clear floor or ground space for the dishwasher or the sink.
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Example: Dishwasher 30” x 48” Clear Floor Space Adjacent to Dishwasher
Not obstructed by open dishwasher door
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Clear floor space is not required to be centered.
Range or Cooktop Where a forward approach is provided, the clear floor or ground space shall provide knee and toe clearance complying with 306. 30” x 48” Clear floor space is not required to be centered.
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, Contd. Where knee and toe space is provided, the underside of the range or cooktop shall be insulated or otherwise configured to prevent burns, abrasions, or electrical shock.
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Parallel Approach: Range or Cooktop
48” 36” Either a forward or parallel approach is allowed to ranges and cooktops( ).
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, Contd. The location of controls shall not require reaching across burners.
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804.6.5.1 Side-Hinged Door Ovens
Side-hinged door ovens shall have the work surface required by positioned adjacent to the latch side of the oven door.
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Bottom-Hinged Door Ovens
Bottom-Hinged Door Ovens Bottom-hinged door ovens shall have the work surface required by positioned adjacent to one side of the door. Work Surface 804.3 30” x 48” Work surface must be at least 30” in length since a forward approach is required by
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804.6.6 Refrigerator / Freezer
Combination refrigerators and freezers: shall have at least 50% of the freezer space 54” maximum above the finish floor or ground. Clear Floor or Ground Space: shall be positioned for a parallel approach to the space dedicated to a refrigerator/freezer with the centerline of the clear floor or ground space offset 24” maximum from the centerline of the dedicated space.
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Example: Clear Floor Space: Refrigerator/Freezer
Note: 36” is the typical size of the dedicated space for a refrigerator/freezer.
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Test Your Knowledge
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No! Yes! This is a kitchen since it has cooking facilities.
Is a parallel approach allowed to the kitchen sink? The kitchen does not meet Exception 1 because it has a cooktop. Yes! Does 50% of the storage have to be accessible? Kitchens must comply with based on
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Yes! No! This is a wet bar with no cooking facilities.
Is a parallel approach allowed to the sink? Wet bars are allowed to have a parallel approach based on Exception 1. Does 50% of the storage have to be accessible? No! Only one of each type is required based on
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This is a not kitchen since it has no cooking facilities.
Is a parallel approach allowed to the sink? No! 606.2, Exception 1 is applicable only to kitchen sinks. No! Only one of each type is required to be accessible based on Does 50% of the storage have to be accessible?
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Other Applicable Requirements
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1 of these 3 outlets is not required to comply.
205.1 Exception 3: Kitchen Outlets Where two or more outlets are provided in a kitchen above a length of counter top that is uninterrupted by a sink or appliance, one outlet is not be required to comply with 309 (205.1, Exception 3). Electrical outlet EXAMPLE: 1 of these 3 outlets is not required to comply.
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Summary Kitchens & Comparable Spaces
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What is a Kitchen or Kitchenette?
A place (as a room) with cooking facilities. Definition based on (Undefined Terms)
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What are Cooking Facilities?
They include the following fixed or built-in appliances used to cook food: Range Oven Cooktop Microwave Oven Convection Oven Definition and types of appliances based on 201.1 (Scope) and (Undefined Terms) and input from the U.S. Access Board Excerpt from
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Scoping & Technical Requirements Kitchens and Kitchenettes
Kitchens and kitchenettes shall comply with 804. Conclusion: If a subject kitchen or kitchenette is provided (including those provided in a space used as a break room), it must comply with 804 based on Excerpt from
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Specifically Addressed in TAS
Compliance with 804 Specifically Addressed in TAS Compliance with 804 is also specifically referenced in the 2012 TAS for the following: Transient lodging facilities ( ) Residential dwelling units (809.3) Excerpt from
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Scoping & Technical Requirements
Kitchen Sinks 804.4 Sinks shall comply with 606. (Applicable to all sinks provided in a kitchen or kitchenette.) The scoping for sinks that are not provided in kitchens or kitchenettes is in (Requires at least 5%, but not fewer than one of each type to comply with 606.) Excerpt from
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606.2 Exception 1: Clear Floor Space Kitchen Sinks
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.
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Summary – Kitchen Sink Range Oven Cooktop Microwave Oven
Convection Oven A parallel approach is allowed by with a kitchen that has a fixed or built-in oven, microwave, or convection oven.
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Spaces Without Fixed or Built-In Cooking Facilities
The space without fixed or built-in cooking facilities is not considered a kitchen or kitchenette, therefore, the sink provided in these space is not considered a “kitchen” sink.” A front approach to the sink is required by
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SUMMARY: Kitchens, Kitchenettes, and Comparable Spaces
2012 Public or Common Use Residential (233 & 809)¹ Transient Lodging (224 & 806)² Employee Work Areas WITH Cooking Facilities Kitchens and Kitchenettes (212 and 804) Yes (100% based on 212.2) (As required by 809.3) (As required by ) No (Based on 203.9) Kitchen Work Surface (804.3) (Based on 804.3) (Based on (1)) Storage (804.5) Yes (Based on 212.2) Yes (Based on 809.3) Yes (Based on ) WITHOUT Cooking Facilities Applicable provisions of TAS ¹Applicable to social service establishments, graduate student and faculty housing, and crew quarters for emergency response personnel . ²Applicable to places of lodging including timeshares and housing at a place of education.
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Information Resources
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Website developed through a contract with DBTAC* and the U.S. Access Board. *Disability and Business Technical Assistance Center
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U.S. Department of Justice
Guidance on the 2010 ADA Standards for Accessible Design Title II – Revised* Title III – Revised* Primer for Small Businesses *Appendix A to each regulation includes a section-by-section analysis of the rule and responses to public comments on the proposed rule. *Appendix B to the title III regulation discusses major changes in the 2010 ADA and responds to public comments received on the proposed rules.
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Updated Small Business Guide
U.S. Department of Justice ADA UPDATE: A PRIMER FOR SMALL BUSINESS Updated Small Business Guide
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Texas Department of Licensing and Regulation
Texas Department of Licensing and Regulation AB Advisory Board Working Document October 1, 2010 1994 TAS Comparison to 2010 ADA and ABA
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Fair Housing Design Manual
U. S. Department of Housing and Urban Development (HUD) Fair Housing Design Manual
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Texas Department of Licensing and Regulation
2012 TAS Technical Assistance Toll Free in Texas (512) (Phone) (512) (Fax)
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United States Access Board
2010 ADA Technical Assistance Voice: (202) or (800) TTY: (202) or (800)
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Thank You.
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