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

Comment. Accessible reach ranges specify a minimum height of 15 inches (308.3) for unobstructed reaches. The appliance industry called attention to certain types of doors that, when fully open, cannot easily meet this specification, such as dishwasher doors and doors of ovens and broilers that are part of free-standing ranges. Compliance with the reach range requirement when the door is fully open would severely impact the design and size of such appliances.

Response. The Board has included an exception for bottom-hinged appliance doors, which do not have to be within reach range requirements specified in 309.3 when open (804.6.2, Exception 2). Ovens are required to have controls on front panels (804.6.5.3). A specification that these controls be to the side of the door has been removed in the final rule as unnecessarily restrictive.