904 Sales and Service Counters

This section covers the approach to counters (904.2), check-out aisles (904.3), sales and service counters (904.4), food service lines (904.5), and security glazing (904.6).

Comment. Specifications are provided for the counter surface height of check-out aisles, including the height of counter edge protection, which is limited to 2 inches above the counter surface (904.3.2). Commenters requested that clarification be added that the edge protection height limitation applies only to the aisle of the check-out counter.

Response. The Board has added clarification that the specified height for edge protection at check-out aisle counters applies to the aisle side of the counter (904.3.2).

Comment. The counter surface of check-out aisle counters is required to be 38 inches high maximum. Comments from persons with disabilities considered 38 inches to be too high.

Response. The Board has clarified requirements for check-out aisles by adding a provision specific to check-writing surfaces (904.3.3). Under this requirement, the height of check-writing surfaces, where provided, is to comply with the height of work surfaces addressed in section 902.3 (34 inches maximum), consistent with the Board’s intent in the proposed rule.

Comment. Accessible sales or services counters, or portions of them, must be no higher than 36 inches where either a parallel or forward approach is provided (904.4). Comments from persons with disabilities considered this too high to be used as a writing surface. Where only a portion of a counter is made accessible, these commenters advised that the maximum height should be 32 inches. Comments from the retail industry advised that a higher surface height is needed to accommodate various types of counters, such as glass display cases, which are typically manufactured at a height of 38 inches.

Response. The Board has retained the specified height of 36 inches for sales and service counters, which is consistent with the original ADAAG, to accommodate both persons who use wheelchairs and those that do not. Even where only a portion of the counter is accessible, in some cases that portion may serve as the transaction area for all customers. In the final rule, the Board has clarified that the accessible portion of counters must extend the full depth of the counter (904.4.1 and 904.4.2), consistent with the new ANSI A117.1 standard. Where a parallel approach is provided, the accessible portion must be at least 36 inches long. The Board has added an exception that where a provided counter surface is less than 36 inches long, the entire surface shall be accessible to clarify that in such cases the counter does not have to be lengthened (904.4.1, Exception). Section 904.6 requires that where counter or teller windows have security glazing to separate personnel from the public, at least one of each type must provide a method to facilitate voice communication.

Comment. The proposed rule referenced examples of acceptable methods (grilles, slats, talk-through baffles, intercoms, and telephone handset devices) and required access both for persons who use wheelchairs and for persons who may have difficulty bending or stooping. Commenters indicated that access for persons who have difficulty bending or stooping is unclear absent specific technical criteria. Such criteria should be provided or the requirement removed according to these comments. In addition, it was recommended that the requirement for volume control for "hand-operable communication devices" be revised for clarity as applying to telephone handset devices.

Response. The requirement that methods to facilitate voice communication be accessible both to persons who use wheelchairs and to persons who may have difficulty bending or stooping has been removed in the final rule (904.6). The Board has also clarified that the requirement for volume controls applies to telephone handset devices, where provided. In addition, the Board has relocated information concerning acceptable types of communication methods to the corresponding advisory note which is a more appropriate location for this kind of information.