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

Comment. Requirements for toilet paper dispensers in section 604.7 include specifications for height. They must be mounted at least 1 ½ inches below grab bars or, according to the proposed rule, at least 12 inches above. Commenters noted that the 12 inch minimum was inconsistent with provisions for grab bars in section 609 which specify a minimum clearance of 15 inches between grab bars and protruding objects above them (609.2). Some commenters felt that toilet paper dispensers should not be allowed above grab bars in any case since the large roll type, which often cannot fit below grab bars, compromise the usability of the grab bar.

Response. In the final rule, the specified clearance between grab bars and dispensers mounted above them has been revised for consistency with the grab bar specifications in section 609. Specifications in section 604.7 concerning this clearance have been removed since the required clearance between dispensers and grab bars is adequately covered in section 609, which, as revised, requires a minimum clearance of 12 inches above grab bars and a minimum clearance of 1 ½ inches below grab bars (609.3). This may effectively preclude some dispensers from being located above grab bars in view of the minimum mounting height of grab bars (33 inches, measured to the top of the gripping surface) and the maximum height for the dispenser outlet (48 inches). Since some dispensers may be recessed, the Board has added clarification in section 604.7 that dispensers cannot be located behind grab bars.