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

607 Bathtubs

Specifications for bathtubs in section 607 address clear floor space, seats, grab bars, operable parts, shower spray units, and enclosures. Changes made to this section include:

• revision of grab bar mounting heights (607.4)

• integration of provisions for grab bars specific to residential dwelling units that were located in Chapter 11 (607.4, Exception 2)

• revision of specifications for shower spray units and water temperature (607.6)

Two parallel grab bars are required on the back wall of bathtubs with seats (607.4.1.1) and without seats (607.4.2.1). The proposed rule, consistent with the original ADAAG, specified that the lower grab bar be located 9 inches absolute above the bathtub rim. In finalizing this rule, the Board has sought to specify dimensions as a range instead of in absolute terms where possible to facilitate compliance without compromising accessibility. With respect to the lower grab bar at bathtubs, the specified mounting height has been changed to a range of 8 inches minimum to 10 inches maximum above the rim of the bathtub.

Comment. The guidelines require tubs to have shower spray units that can be used as both a fixed position shower head and a hand-held shower (607.6). In the proposed rule, the Board included a requirement that shower spray units have a water on/off control for greater access. It was also specified that units deliver water that is thermal shock protected to 120 degrees. Comments from persons with disabilities strongly supported the requirement for the on/off control. However, comments from the plumbing industry indicated that the requirement, as worded, would pose cross connections and thermal shock hazards and would conflict with model codes and industry standards. Comments also noted that delivered water should be "temperature limited" to the specified maximum (120 degrees) for consistency with American Society of Safety Engineers (ASSE) standards.

Response. In response to concerns raised about the on/off control for spray units the Board has modified this requirement to include an on/off control "with a non-positive shut-off." This will prevent cross connections and does not conflict with plumbing codes. In addition, while the phrase "temperature limited" was not deemed necessary, the specification for water temperature has been revised to require that delivered water be 120 degrees maximum for consistency with ASSE standards. Corresponding revisions have been made to similar requirements for shower compartments (608.6).