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

606 Lavatories and Sinks

Section 606 provides technical criteria for lavatories and sinks. Various scoping and technical provisions invoke these requirements for lavatories in toilet and bathing facilities and for sinks provided in dwelling unit kitchens, kitchenettes in transient lodging guest rooms, and other spaces, such as break rooms. Revisions made to this section include:

• clarifying the scope of this section (606.1)

• adding a new exception that allows a parallel approach at kitchen sinks in spaces where a cook top or conventional range is not provided (606.2, Exception 1)

• clarifying coverage of metering faucets (606.4)

In addition, allowances specific to lavatories and kitchen sinks in residential dwelling units have been relocated to this section from Chapter 11. These specifications concern clear floor space requirements (606.2, Exception 3) and heights (606.3, Exception 2).

Comment. The proposed rule included references to "lavatory fixtures" and to "vanities." Commenters indicated that such references were redundant or inaccurate and should be removed.

Response. References to "lavatory fixtures" and "vanities" have been removed in the final rule (606.1).

Accessible lavatories and sinks must provide knee and toe clearance for a forward approach (606.2). Consistent with the proposed rule, exceptions from the requirement for forward approach clearances are provided for certain types of spaces and fixtures, such as single-user toilet or bathing facilities accessed only through a private office (Exception 2), lavatories and kitchen sinks in residential dwelling units provided certain conditions to facilitate retrofit for a forward approach are met (Exception 3), and fixtures designed specifically for children 5 years and younger (Exception 5).

Comment. Commenters recommended that a parallel approach should be allowed at kitchen sinks in spaces without a cook top or conventional range, consistent with the ANSI A117.1 standard. Several comments considered a parallel approach to be appropriate at kitchenette sinks in transient lodging guest rooms, consistent with the original ADAAG, and sinks in employee break rooms, since such fixtures are typically used for limited purposes or durations.

Response. The final rule includes an exception, consistent with the ANSI A117.1 standard, that allows a complying parallel approach to kitchen sinks in spaces where a cook top or conventional range is not provided (606.2, Exception 1). This exception also applies to wet bars.

Comment. Faucets, including hand-operated metering faucets, must remain open for at least 10 seconds (606.4). The proposed rule referred to these as "self-closing" faucets. Commenters indicated that "metering" is a descriptor that is more accurate and consistent with plumbing codes.

Response. The reference to "self-closing" faucets has been replaced with "metering" faucets in the final rule.