36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

308 Reach Ranges

Accessible reach ranges are specified according to the approach (forward or side) and the depth of reach over any obstruction. The proposed rule, consistent with the original ADAAG, specified maximum heights of 48 inches for a forward reach and 54 inches for a side reach. In the final rule, the maximum side reach has been lowered to the height specified for forward reaches. Exceptions to this requirement and a related provision for reaches over obstructions have been added for gas pumps, laundry equipment, and elevators.

The ADAAG Review Advisory Committee’s report, upon which the proposed rule was largely based, recommended that the side reach range, including obstructed reaches, be changed to those required for forward reaches. This recommendation was based on a report from the Little People of America which considered the 54 inch height beyond the reach for many people of short stature. The advisory committee also considered the 48 inch maximum for side reaches as preferable for people who use wheelchairs. The Board proposed retaining the 54 inch side reach maximum pending further information on the need for, and impact of, such a change in view of its application to a wide and varied range of controls and elements. However, the Board acknowledged that the ANSI A117.1‒1998 standard included such a change, which would mitigate the impact of similar action by the Board in view of new codes based on the ANSI A117.1 standard.

Comment. Several hundred comments, almost a fifth of the total received in this rule making, addressed the merits of lowering the side reach maximum. The vast majority urged lowering the side reach, consistent with the advisory committee’s recommendation. Most of these comments were submitted by persons of short stature and disability groups. These commenters, as well as the ANSI A117 Committee and the Little People of America, stated that the unobstructed high reach range requirement should be lowered to 48 inches to help meet the needs of people of short stature, people with little upper arm strength and movement, and people with other disabilities. This change would enhance consistency between the guidelines and other codes and standards. Comments called attention to difficulties people encounter accessing ATMs, vending machines, and gas pumps. Various trade and industry groups opposed lowering the side reach range due to concerns about the impact and cost on various types of equipment, including those highlighted by other comments as difficult to reach. In particular, gas pump manufacturers outlined the difficulties in designing a fuel dispenser that would meet the 48 inch requirement. Gas pumps are often located on curbs at least 6 inches high for safety reasons. In addition, safety and health regulations require distance between the electronics of the pump and the dispenser. Comments from the elevator industry noted that a 48 inch maximum height would adversely impact the design of elevator controls.

The Board held a public meeting in October, 2000 to collect further information on this issue. Persons of short stature and disability groups reiterated the need for lowering the side reach to 48 inches. ATM manufacturers noted that they could meet the 48 inch maximum height for most new models of ATMs. Gas pump manufacturers demonstrated the difficulties in meeting the 48 inch height requirement in view of their current designs and safety and health design requirements. The gas pump manufacturers impressed upon the Board the great difficulty of installing a redesigned gas pump on an existing curb. They contended that although it would be possible to redesign gas pumps to be 48 inches to the highest operable part, even when installed on a curb, such gas pumps would have non-uniform fittings. They noted that installing them would be costly and could necessitate removing the entire curb.

Response. The maximum side reach height has been lowered from 54 to 48 inches. An exception is provided for the operable parts of fuel dispensers, which are permitted to be 54 inches high maximum where dispensers are installed on existing curbs. This exception responds to industry’s concern regarding costs associated with alterations and will permit the existing stock of gas pumps that are currently within 54 inches to be used. In addition, certain exceptions are provided for elevators in section 407, consistent with the ANSI A117.1 standard.

Comment. Requirements for side reaches over an obstruction in 308.3.2 limit the height of the obstruction to 34 inches maximum. A major manufacturer of laundry equipment indicated that this specification would significantly impact the standard design of clothes washers and dryers, which have a standard work surface height of 36 inches. Complying with a 34 inch maximum height would decrease machine capacity and involve substantial redesign and retooling to develop compliant top loading and front-loading machines.

Response. An exception has been added that permits the top of washing machines and clothes dryers to be 36 inches maximum above the floor.