2022 California Standards for Accessible Design Guide (effective January 1, 2023)

ETA Editor's Note

The definition of "Sink" in CBC Chapter 2, adopted by DSA-AC, is as follows: SINK. A fixed bowl or basin with running water and drainpipe, as in a kitchen or laundry, for washing dishes, clothing, etc. (As differentiated from the definition of "Lavatory".). The definition of "Lavatory" in Chapter 2, also adopted by DSA-AC, is as follows: LAVATORY. A fixed bowl or basin with running water and drainpipe, as in a toilet or bathing facility, for washing or bathing purposes. (As differentiated from the definition of "Sink".). It would appear that the difference is that a "Lavatory" is for washing a part of the body, while a "Sink" is for washing anything else. It is unclear whether a "Lavatory" can exist in other places than a toilet room or bathroom, even when specifically intended for washing a part of the body. The ADA requirements and exceptions make no mention of wet bars, scullery sinks or scrub sinks. Both ADA and CBC lack definitions for mop sinks, service sinks, and scullery sinks, so their identifications rely upon definitions in collegiate dictionaries (unspecified) per CBC 11B-106.3. In fact, the 2010 ADA Standards, as well as 1991 ADAAG, decline to define sinks or lavatories at all. Oxford American Dictionaries have no definitions for "Mop Sink," "Service Sink," or "Scullery Sink." "Sink" is defined as: A fixed basin with a water supply and a drain. "Lavatory" is defined as: A sink or washbasin in a bathroom. The definitions for "Mop" and "Service" are of little use, and "Scullery" is defined as: A small kitchen or room at the back of a house used for washing dishes and other dirty household work.

The California Plumbing Code (CPC) definition for "Scrub Sink", referenced in 11B-212.3 Exception 2, is as follows: Scrub Sink [OSHPD 1, 2, 3 & 4]. Is a sink used to wash and scrub the hands and arms during the septic preparation for surgery and equipped with a supply spout and controls as required for a handwashing fixture. Sensor operated fixtures shall be capable of functioning during loss of normal power. CPC does not have a definition for "Sink," "Mop Sink," "Service Sink," or "Scullery Sink," but it does define "Lavatory" as follows: Lavatory [HCD 1 & HCD 2]. "Lavatory" shall mean a plumbing fixture used for washing the hands, arms, face and head. This definition has not been adopted by DSA-AC.

The Office of Statewide Health Planning and Development (OSHPD) has expressed (see ETA Editor's Note at 11B-805.6) that it considers the "Handwashing Fixtures" required at such places as exam rooms, nurses' stations and medication preparation rooms to be "Sinks" for accessibility purposes, and not "Lavatories."

Some sink types are unmentioned in ADA and CBC Chapter 11B, including laundry sinks, clinic sinks (with flushing rims), eyewash fixtures, sinks at dental exam rooms used by patients for rinsing, and others. Except for laundry sinks, these are not in locations included in the CBC definitions for "Sink" or "Lavatory": kitchens, laundries, toilet or bathing facilities. By their omission, one might infer that accessibility requirements do not apply. However, that is not an entirely safe assumption, particularly since the ADA requirements default to the extremely broad definition of "Sink" found in collegiate dictionaries. It is also noteworthy that many sinks serve multiple purposes, such as those at employee break rooms, craft rooms at senior living centers, or school classrooms. Those purposes may include washing a part of the body, as well as other items.

These ambiguities have led to much debate as to the identification of plumbing fixtures, scoping of accessibility to them, and which technical requirements apply. It is beyond the scope of this Guide to resolve those issues. It is generally recommended that, before declining to make a sink accessible, consideration should be given to the number of different users and purposes for which the fixture is intended, unless it is specifically exempted from accessibility requirements.

Agencies responsible for promulgating and enforcing accessibility regulations have previously issued guidance, such as DSA-AC's Access Compliance Reference Manual.