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

608 Shower Compartments

Section 608 addresses transfer showers and roll-in showers and provides specifications for size and clearances, grab bars, seats, operable parts, shower spray units, thresholds, and enclosures. Revisions made to this section address:

• clearance requirements for roll-in showers (608.2.2)

• alternate roll-in showers (608.2.3)

• shower seats (608.4)

• the location and operation of controls, faucets, and spray units (608.5)

• shower spray units and water temperature (608.6)

• a new exception for fixed shower heads (608.6)

• thresholds (608.7)

In addition, provisions specific to showers in residential dwelling units that were located in Chapter 11 have been incorporated into this section. These provisions concern grab bars (608.3, Exception 2) and shower seats (608.4, Exception). 

Comment. Specifications for roll-in shower compartments indicate that an accessible lavatory can overlap the required clear floor space opposite the end with a seat and shower controls (608.2.2). Comments recommended that this provision be revised to recognize that a seat may not always be located in a roll-in shower.

Response. The Board has clarified that accessible lavatories are permitted to overlap clear floor space "opposite the shower compartment side where shower controls are positioned or where a seat is positioned" (608.2.2.1, Exception). Clarification is also provided that lavatories can be provided at either end of the space at roll-in showers without seats where controls are mounted on the back wall.

Comment. Specifications are provided for alternate roll-in showers, including their size and the location of entries (608.2.3). Comments indicated that this provision should be more specific in detailing the design illustrated (Figure 608.2.3).

Response. More detail is provided in the final rule for the configuration of alternate roll-in type showers consistent with the intent of the proposed rule. The revised language clarifies the location of the entry at the end of the long side of the compartment (608.2.3).

Comment. Seats are required in transfer compartments and roll-in showers in transient lodging guest rooms (608.4). The proposed rule indicated that transfer compartments may have "attachable or integral seats," while folding seats were specified for roll-in showers provided in transient lodging guest rooms.

Response. The Board has revised the rule to permit "folding or non-folding" seats in transfer compartments. A certain portion of accessible guest rooms are required to have bathrooms with roll-in showers (224.2). The requirement for folding seats has been revised to apply only to those roll-in showers "required" in transient lodging guest rooms. For example, a hotel with 100 guest rooms would be required to have at least 5 guest rooms that are accessible, one of which would have to provide a roll-in shower; the shower provided in this room would be required to have a folding seat, while the other 4 rooms could be equipped with either tubs, transfer showers, roll-in showers with or without seats, or some combination thereof.

Comment. In transfer compartments, controls, faucets, and shower spray units were to be located no more than 15 inches on either side of the seat centerline, according to the proposed rule (608.5.1). Comments indicated that this specification was not consistent with a corresponding figure showing the location on the side closest to the shower opening.

Response. The final rule has been revised to require that controls and operable parts be located 15 inches maximum from the centerline of the seat toward the shower opening. This is consistent with the intent of the specification so that users can activate the controls before entering the shower.

Specifications for controls, faucets, and shower spray units for alternate roll-in showers are provided in section 608.5.3. In the final rule, the Board has clarified these specifications and provided more detail on their location depending on whether the shower is equipped with a seat. In addition, the final rule allows shower controls, faucets, and shower spray units to be located on the wall adjacent to the seat, as proposed, or on the back wall opposite the seat. These revisions are consistent with similar clarifications in the latest edition of ANSI A117.1 standard.

Showers, like bathtubs, are required to be equipped with movable shower spray units that can be used as a fixed-position shower head and a hand-held shower (608.6). Specifications have been revised in the final rule, consistent with similar requirements for bathtubs, in response to concerns raised by commenters about the on/off control and water temperature as specified in the proposed rule, discussed above at section 607.6.

Comment. The original ADAAG allowed fixed shower heads 48 inches high maximum to be used instead of the required hand-held unit in "unmonitored facilities where vandalism is a consideration." This exception had been removed in the proposed rule due to a lack of clarity on the types of facilities that qualify for this exception. Commenters urged the Board to retain this exception due to problems with vandalism which would increase maintenance at accessible transfer showers.

Response. The final rule includes an exception permitting a fixed shower head in certain facilities (608.6, Exception). The Board has limited this exception so that it does not apply to facilities where vandalism is less likely to occur because the use of bathing facilities is controlled or because incidents of vandalism are traceable. These include bathing facilities in medical care facilities, long term care facilities, transient lodging guest rooms, and residential dwelling units.

Comment. The proposed rule specified a maximum threshold height of ½ inch, provided that those greater than ¼ inch are beveled with a slope of 1:2 maximum (608.7). This provision applied to roll-in showers and to transfer showers. Commenters recommended that a higher threshold be permitted for transfer showers since wheelchair maneuvering over the threshold is not necessary in using the shower.

Response. The Board retained the ½ inch threshold height since positioning for transfer to the seat of transfer showers can be aided where a close approach enables footrests to clear the threshold. However, the Board has revised the specification to allow thresholds at transfer compartments to be vertical or rounded instead of beveled. In addition, the Board has provided an exception for existing facilities to address situations where meeting the maximum threshold height, which is typically achieved by recessing shower pans into the floor, is difficult, if not infeasible, due to certain floor slabs. The final rule includes an exception that permits a threshold up to 2 inches high at transfer showers in existing facilities where providing a ½ inch threshold would disturb the structural reinforcement of the floor slab (608.7, Exception).