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

Comment. Commenters noted that baby changing tables should not be permitted in accessible compartments since they can interfere with access. On the other hand, some comments advised that baby changing tables need to be accessible.

Response. The specified dimensions of toilet compartments provide the minimum amount of space necessary for wheelchair maneuvering into the compartment, positioning at the fixture, and exit from the compartment. Certain elements are permitted to overlap space at water closets, such as grab bars, paper dispensers, and coat hooks (604.3.2). Other elements, including baby changing tables, are not allowed to overlap the minimum amount of space required in compartments. Where such elements are provided in accessible compartments, they must be located outside the minimum space dimensions (when folded up in the case of baby changing tables). In addition, convenience fixtures, such as baby changing tables, must be accessible to persons with disabilities under scoping provisions for operable parts (205) and work surfaces (226). This information is provided in the final rule in an advisory note at section 604.8.1.1.