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

Comment. Clearance requirements for water closets are covered in section 604.3. The proposed rule stated that no fixtures (other than the water closet) or obstructions were to be located within the clear floor space (604.3.1). Comments noted that this seemed to contradict a subsequent provision that allowed grab bars and dispensers to overlap this space (604.3.2).

Response. Language prohibiting fixtures and obstructions within the required clearances in section 604.3.1 has been removed. Section 604.3.2 recognizes those elements that are permitted to overlap this clearance.

Comment. The proposed rule identified certain elements that could overlap the clear floor space at water closets: associated grab bars, tissue dispensers, accessible routes, clear floor space at other fixtures, and wheelchair turning space (604.3.2). Commenters advised that other elements, such as coat hooks should be included, as well as other types of dispensers, such as those for toilet seat covers. In addition, the new ANSI A117.1 standard includes a reference to sanitary napkin disposal units.

Response. In the list of elements permitted to overlap water closet clearances, the Board has added references to "dispensers," "sanitary napkin disposal units," "coat hooks," and "shelves" (604.3.2).