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

ETA Editor's Note

The Office of Statewide Health Planning and Development (OSHPD), which has jurisdiction over hospitals and long-term care facilities in California, issued Code Application Notice CAN 2-11B, dated 9/9/14, which includes the following interpretation of Section 11B-805.6:

The requirements of Section 11B-606 apply to all lavatories, sinks, and handwashing fixtures for public use, patient use, and employee use, unless otherwise specifically exempted by the code. Lavatories, sinks, and handwashing fixtures are common use areas and therefore, require accessibility.

Exceptions:

• Scrub sinks (due to impracticality)
• Specific workstations (see Section 11B-203.9). This applies only where the sink is the actual workstation.

Example: A sink used exclusively for cleaning endoscopes. The sink is the actual area where work is performed as opposed to a place where the employee cleans up before and after performing work elsewhere in the room.

Knee clearance requirement - All accessibility requirements of Section 11B-606 apply to lavatories, sinks and handwashing fixtures required to be accessible. Lavatories are subject to Section 11B-306.3.3, Exception 1 which states: "At lavatories required to be accessible by Section 11B-213.3.4, the knee clearance shall be 27 inches (686 mm) high minimum above the finish floor or ground at a depth of 8 inches (203 mm) minimum increasing to 29 inches (737 mm) high minimum above the finish floor or ground at the front edge of a counter with a built-in lavatory or at the front edge of a wall-mounted lavatory fixture."

This requirement applies to all lavatories. "Handwashing fixtures" are special application "sinks" and not subject to the exception. Handwashing fixtures, as sinks, are subject to Section 11B-306.2.3, Exception 1 which states" "The toe clearance shall extend 19 inches minimum under sinks required to be accessible by Section 11B-212.3."

Consequently, handwashing fixtures must have a minimum depth of 19 inches in order to comply with the minimum toe clearance. They shall also have a minimum knee clearance of 27 inches at the depth and reduction described in Sections 11B-306.3.3 and 11B-306.3.4.

The implications of this interpretation are that a wall-mounted china fixture of the most common size, nominally 20 inches wide x 18 inch projection, cannot serve as a handwashing fixture. See also the ETA Editor's Note at 11B-212.3.

As of the initial publication of this Guide, OSHPD has not updated CAN 2-11B for applicability to 2022 CBC. Since there is no change to the wording of Section 11B-805.6, there is no reason to expect that OSHPD will change its interpretation.