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

Requirements for appliances include provisions for operable parts (804.6.2), which are required to be accessible according to section 309. Section 309 includes specifications for clear floor space (309.2), height (309.3), and operating characteristics (309.4). The proposed rule contained an exception for controls mounted on range hoods. This provision has been replaced by an exception to general scoping provisions for operable parts that addresses redundant controls (205.1, Exception 6). In the addition, the Board has added exceptions for appliance doors and door latching devices in section 804.6.2.

Comment. Operable parts must be designed so they can be operated with one hand and without tight grasping, pinching, twisting of the wrist, or more than 5 pounds of force (309.4). Appliance manufacturers called attention to various appliances that cannot be easily redesigned to meet the maximum 5 pounds of force. At refrigerator and freezer doors, a tight seal is necessary for energy efficiency, as required by other Federal laws, which may result in an opening force that exceeds 5 pounds of force. The latch used to secure dishwasher doors and create a water-tight seal also typically requires a force that may exceed 5 pounds which would be difficult and costly to reduce.

Response. The final rule provides an exception under which appliance doors and their latching devices are not required to comply with the specified operating characteristics for operable parts in section 309.4, including the maximum pounds of force for operation (804.6.2, Exception 1).