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

Comment. Requirements for accessible toilet and bathing rooms include a provision for vanity counter top spaces, which in the past have been omitted from accessible guest rooms even where provided for inaccessible rooms. This provision requires accessible vanity counter tops at lavatories in accessible guest rooms if vanity counter tops are provided in other guest rooms (806.2.4.1). The proposed rule required the vanity top in accessible rooms to be at least 2 square feet. Industry commenters considered this specification unduly restrictive while persons with disabilities considered it inadequate in ensuring equivalent access. The proposed rule also applied requirements for reach ranges and operable parts (sections 308 and 309) which would have effectively required knee and toe clearances below the vanities.

Response. The Board has removed the minimum surface requirement (2 square feet) for vanity counter tops. The revised provision requires vanity counter top space in accessible rooms to be comparable, in terms of size and proximity to lavatories, to those provided in other rooms of the same type. In addition, the requirement for compliance with sections 308 and 309 has been removed in the final rule. This change is consistent with the ANSI A117.1 standard.