2013 California Standards for Accessible Design Pocket Guide

ETA Editor's Note

The ADA requirements included at Section 11B-226 are provided for information only. The 2013 CBC scoping requirements are more inclusive.

Baby changing tables were not specifically addressed by the original 2013 CBC.  If located in a toilet room required to be accessible, they were indirectly addressed by the requirement to make at least one of each accessory accessible.  This has been generally understood to include the technical requirements for accessible routes, clear floor space, reach ranges, knee and toe space, worksurface heights, operable parts and protruding objects.

Although a 2010 ADAS Advisory strongly cautions otherwise, there was no prohibition in the original 2013 CBC or 2010 ADAS against installing baby changing tables in accessible water closet compartments, provided that all of the technical requirements were met.  There was also no specification that baby changing tables could not intrude into the accessible routes when deployed.  Therefore, existing baby changing tables that are installed in accessible water closet compartments, or that protrude more than 4" into accessible routes when deployed, are not presently subject to path of travel barrier removal obligations if, and only if, they meet all other technical requirements for accessibility.  If they must be modified, for example, to comply with the maximum work surface height of 34 inches, their noncompliant location (i.e., inside an accessible water closet compartment, or obstructing an accessible route when deployed) would also require correction.

When evaluating whether to take advantage of this Safe Harbor, Pocket Guide users are urged to consider:

1. If alterations are performed in an area served by the subject toilet room in the future, permitted under a subsequent edition of CBC, the baby changing table in a noncompliant location will have to be relocated at that time;

2. When a baby changing table in an accessible toilet compartment is being used, that compartment becomes unavailable for its intended use;

3. Parents dealing with a young child's needs are not always mindful of the needs of others, and poorly located baby changing tables that are left in the deployed position can limit door movement, blocking access for anyone who cannot negotiate tight spaces, a circumstance prohibited under CBC 11B-108, Maintenance of accessible features;  and,

4. Baby changing tables left in the deployed position in a circulation path can be a hazard to persons with vision impairment, also prohibited under CBC 11B-108.