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

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.