36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)
Chapter 6: Plumbing Elements and Facilities
Chapter 6 provides criteria for drinking fountains (602), toilet and bathing rooms (603), water closets and toilet compartments (604), urinals (605), lavatories and sinks (606), bathtubs (607), shower compartments (608), grab bars (609), tub and shower seats (610), laundry equipment (611), and saunas and steam rooms (612). Alternate specifications are provided for plumbing elements designed for children’s use as exceptions to requirements based on adult dimensions. These exceptions address drinking fountains, water closets, toilet compartments, lavatories and sinks.
602 Drinking Fountains
Specifications for drinking fountains in section 602 address access for people who use wheelchairs (602.2 through 602.6) and for people who do not, but who may have difficulty bending or stooping (602.7). Substantive changes to this section include:
Comment. The proposed rule, consistent with the original ADAAG, addressed both drinking fountains and water coolers. Comments advised that the guidelines should not address "water coolers," a term which is often used to refer to bottled units that are not plumbed or permanently fixed.
Response. The Board has removed the references to "water coolers" in section 602.1 for clarity and consistency with the scope of the guidelines.
Comment. For wheelchair access, the proposed rule required a forward approach at cantilevered units but allowed a parallel approach at other types of units, such as those that are floor mounted. A forward approach provides easier access than a parallel approach for people using wheelchairs. The Board sought comment on whether it should require a forward approach, which includes knee and toe clearances below the unit, at all wheelchair accessible drinking fountains (Question 24). Commenters overwhelmingly supported such a requirement as more appropriate for wheelchair access.
Response. The Board has revised the rule to require a clear floor space for a forward approach at all wheelchair accessible drinking fountains (602.2). Corresponding changes have been made to the specifications for spout location (602.5). An existing exception for units designed specifically for children’s use permits a parallel approach if certain criteria for spout height and location are met.
Comment. The proposed rule required spouts to provide a flow of water at least 4 inches high "to allow the insertion of a cup or glass." A comment noted that the rationale for this specification is not needed in the text of the requirement and might be misinterpreted as allowing cup dispensers as an alternative to accessible units.
Response. Language concerning the insertion of cups has been removed as unnecessary to the water flow specification. The minimum 4 inch height is intended to allow use of cups for persons who may need to use them. However, providing cup dispensers as an alternative to a compliant unit is not recognized by these guidelines in new construction or alterations.
Comment. Specifications for drinking fountains for standing persons address the height of the spout outlet (602.7). The proposed rule required a height of 39 to 43 inches above the floor or ground, a range that derives from the standard height of models on the market. A drinking fountain manufacturer requested that the minimum height be changed from 39 to 38 inches, consistent with referenced ergonomic data. This commenter advised that a 38 inch height will accommodate units that are intended to serve both adults and children.
Response. The minimum height for the spout outlet of units designed for use by standing persons has been lowered from 39 to 38 inches.
603 Toilet and Bathing Rooms
Section 603 covers toilet and bathing rooms and includes requirements for clear floor space, wheelchair turning space, permitted overlaps of various space requirements, and doors. Doors are not permitted to swing into clear floor space or clearance required for any fixture except under certain conditions (603.2.3). The Board has added clarification to this requirement, previously located in an advisory note, that doors are permitted to swing into the required wheelchair turning space.
The guidelines specify that accessible mirrors be mounted so that the bottom edge of the reflecting surface is no higher than 40 inches (603.3). The ANSI A117.1‒2003 standard contains a new requirement that specifies a height of 35 inches maximum for accessible mirrors not located above a lavatory or counter top. This specification was adopted to accommodate persons of short stature. The Board has included a similar requirement in the final rule.
604 Water Closets and Toilet Compartments
Section 604 addresses access to water closets and toilet compartments. Revisions to the requirements for water closets concern:
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location (604.2)
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clearance (604.3)
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grab bars (604.5)
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flush controls (604.6)
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dispensers (604.7)
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toilet compartments (604.8), including those designed for children’s use (604.9)
In addition, provisions specific to water closets in residential dwelling units that were located in Chapter 11 in the proposed rule have been incorporated into this section. These include requirements for space at water closets (604.3), seat height (604.4), and grab bars (604.5).
Water closets are to be located so that the centerline is 16 to 18 inches from the side wall compartment partition (604.2). Water closets can be located so that this dimension is met on either the left side or the right side of the fixture. The Board has added clarification in the final rule that water closets shall be arranged for a left-hand or a right-hand approach. The proposed rule specified that water closets in ambulatory accessible stalls (which are required to be 36 inches wide) be "centered." In the final rule, the Board has revised this provision to recognize a range (17 to 19 inches) for the centered location that is consistent in scope (2 inches) with the specification for water closets in wheelchair accessible compartments. A corresponding change has been made to the provisions for water closets designed for children’s use (604.9.1).
Comment. Clearance requirements for water closets are covered in section 604.3. The proposed rule stated that no fixtures (other than the water closet) or obstructions were to be located within the clear floor space (604.3.1). Comments noted that this seemed to contradict a subsequent provision that allowed grab bars and dispensers to overlap this space (604.3.2).
Response. Language prohibiting fixtures and obstructions within the required clearances in section 604.3.1 has been removed. Section 604.3.2 recognizes those elements that are permitted to overlap this clearance.
Comment. The proposed rule identified certain elements that could overlap the clear floor space at water closets: associated grab bars, tissue dispensers, accessible routes, clear floor space at other fixtures, and wheelchair turning space (604.3.2). Commenters advised that other elements, such as coat hooks should be included, as well as other types of dispensers, such as those for toilet seat covers. In addition, the new ANSI A117.1 standard includes a reference to sanitary napkin disposal units.
Response. In the list of elements permitted to overlap water closet clearances, the Board has added references to "dispensers," "sanitary napkin disposal units," "coat hooks," and "shelves" (604.3.2).
Comment. Water closets not in compartments require clearance that is at least 60 inches wide and 56 inches deep. Many comments urged the Board to increase this depth so that at least 48 inches is provided in front of the water closet. Others recommended an overall depth of 78 inches.
Response. The Board has not revised the minimum dimensions for the clear floor space at water closets. Other criteria for toilet rooms, including turning space, maneuvering space at doors, and clearances at other fixtures, typically results in additional clearance at water closets not in compartments. The 48 inch specification measured from the leading edge of the water closet is derived from the ANSI A117.1-1992 standard. That specification was removed from the 1998 edition of the ANSI standard because it was extremely difficult to enforce due to the varying installation styles and sizes of water closets. However, the Board has revised the specified depth in residential dwelling units where lavatories are permitted to overlap the space aside water closets.
Other fixtures, such as lavatories, generally are not permitted to overlap the clearance required at water closets. However, in residential dwelling units, an accessible lavatory adjacent to water closets can overlap this space (18 inches minimum from the water closet centerline) if additional space is provided in front of the water closet. Specifically, the depth of the clearance must be at least 66 inches instead of 56 inches (604.3.2, Exception). The proposed rule required this additional space in front of the fixture where only a forward approach to the water closet is provided (1102.11.5.2). It did not require additional space where a side approach to the water closet is provided. Locating lavatories outside the specified water closet clearance allows more options in the approach and transfer to water closets. The overlap of an adjacent lavatory effectively precludes side transfers to the water closet. The Board believes that additional space where lavatories overlap water closet clearances can be beneficial regardless of the approach direction. In the final rule, the 66 inch minimum depth applies whether a forward or a parallel approach to the water closet is provided. The proposed rule also allowed a minimum width for the clearance of 48 inches instead of 60 inches where a lavatory overlaps the space, regardless of the approach (1102.11.5.2). In effect, however, space at least 60 inches wide is needed in meeting other requirements, such as the clear floor space required at the adjacent lavatory and wheelchair turning space. Consequently, the Board has removed the 48 inch specification in the final rule.
Specifications for grab bars are addressed in section 604.5. Grab bars are required on one side wall and the rear wall. Exceptions from this requirement are provided for residential dwelling units, where grab bars can be installed later so long as the proper reinforcement is installed in walls as part of design and construction (Exception 2), and for holding or housing cells specially designed without protrusions for purposes of suicide prevention (Exception 3). In the proposed rule, these exceptions were located in the chapter on residential dwelling units (1102.11.5.4) and the scoping section for detention and correctional facilities (233.3).
Comment. The proposed rule specified that the rear grab bar be 24 inches long minimum, centered on the water closet, or at least 36 inches long "where wall space permits" (604.5.2). Commenters considered this provision confusing and requested clarification on where the 24 inches would be permitted. Some comments urged removal of the 24 inches specification.
Response. The proposed rule included provisions that make clear floor space requirements at water closets more stringent by not allowing other fixtures, such as lavatories to overlap the space. Saving space by locating a lavatory closer to the water closet on the same plumbing wall could only be accomplished by recessing the lavatory so that it does not overlap the clear floor space at the water closet. A grab bar 36 inches long would limit the amount of space saved in recessing an adjacent lavatory. For clarity, the Board has revised this allowance as an exception. In the final rule, section 604.5.2 requires the rear grab bar to be 36 inches long minimum. An exception allows a 24 inch long minimum grab bar, centered on the water closet, "where wall space does not permit a length 36 inches minimum due to the location of a recessed fixture adjacent to the water closet" (604.5.2, Exception 1).
Comment. Section 604.6 covers flush controls, which must be hand operated or automatic. Hand operated types are subject to requirements for operable parts, including reach ranges, addressed in section 309. The original ADAAG specified that the controls be located on the wide side of the water closet. Comments requested that this specification be restored since controls on the wide side of water closets are easier to access.
Response. The final rule includes a requirement that "flush controls shall be located on the open side of the water closet except in ambulatory accessible compartments" (604.6).
Comment. Requirements for toilet paper dispensers in section 604.7 include specifications for height. They must be mounted at least 1 ½ inches below grab bars or, according to the proposed rule, at least 12 inches above. Commenters noted that the 12 inch minimum was inconsistent with provisions for grab bars in section 609 which specify a minimum clearance of 15 inches between grab bars and protruding objects above them (609.2). Some commenters felt that toilet paper dispensers should not be allowed above grab bars in any case since the large roll type, which often cannot fit below grab bars, compromise the usability of the grab bar.
Response. In the final rule, the specified clearance between grab bars and dispensers mounted above them has been revised for consistency with the grab bar specifications in section 609. Specifications in section 604.7 concerning this clearance have been removed since the required clearance between dispensers and grab bars is adequately covered in section 609, which, as revised, requires a minimum clearance of 12 inches above grab bars and a minimum clearance of 1 ½ inches below grab bars (609.3). This may effectively preclude some dispensers from being located above grab bars in view of the minimum mounting height of grab bars (33 inches, measured to the top of the gripping surface) and the maximum height for the dispenser outlet (48 inches). Since some dispensers may be recessed, the Board has added clarification in section 604.7 that dispensers cannot be located behind grab bars.
Section 604.8 provides requirements for wheelchair accessible compartments and those that are designed to accommodate persons with disabilities who are ambulatory.
Comment. Commenters noted that baby changing tables should not be permitted in accessible compartments since they can interfere with access. On the other hand, some comments advised that baby changing tables need to be accessible.
Response. The specified dimensions of toilet compartments provide the minimum amount of space necessary for wheelchair maneuvering into the compartment, positioning at the fixture, and exit from the compartment. Certain elements are permitted to overlap space at water closets, such as grab bars, paper dispensers, and coat hooks (604.3.2). Other elements, including baby changing tables, are not allowed to overlap the minimum amount of space required in compartments. Where such elements are provided in accessible compartments, they must be located outside the minimum space dimensions (when folded up in the case of baby changing tables). In addition, convenience fixtures, such as baby changing tables, must be accessible to persons with disabilities under scoping provisions for operable parts (205) and work surfaces (226). This information is provided in the final rule in an advisory note at section 604.8.1.1.
Comment. Specifications are provided for doors, including their location. The proposed rule specified the location of doors in the front partition, which were required to be hinged 4 inches from the side wall or partition farthest from the water closet (604.8.1.2). Comments suggested that an alternate location in the side partition farthest from the water closet should be allowed, consistent with the original ADAAG. Commenters also pointed out that the specified location should refer to the door opening, instead of the hinge.
Response. Specifications for the location of compartment doors in side partitions are included in the final rule, consistent with the original ADAAG. The specified location in either front and side locations has been revised to apply to the door opening, instead of the hinge.
Comment. The proposed rule referred to ambulatory accessible compartments as "non-wheelchair accessible" compartments. Commenters considered this term confusing since it also encompasses inaccessible compartments. Preference was expressed for "ambulatory accessible" compartments, the term used by the advisory committee.
Response. The term "non-wheelchair accessible" compartments has been replaced with "ambulatory accessible" compartments.
Ambulatory accessible compartments were specified to be 36 inches wide absolute in the proposed rule, consistent with the original ADAAG. Throughout the new guidelines, the Board has sought to specify dimensions as a range instead of in absolute terms where practicable to facilitate compliance without compromising accessibility. The width of ambulatory compartments is specified to ensure that the grab bars required on both sides are simultaneously within reach. In the final rule, the Board has replaced the 36 inch wide specification with a range of 35 to 37 inches.
Section 604.9 provides specifications for water closets designed for children’s use. In the proposed rule, this section included criteria for wheelchair accessible compartments. In the final rule, requirements have been integrated in the section covering wheelchair accessible compartments for adults (604.8.1) to reduce redundancy.
605 Urinals
Section 604.5 provides criteria for accessible urinals, including the height and depth, clear floor space, and flush controls.
Comment. In the proposed rule, the Board sought to clarify the requirement in the original ADAAG that accessible urinals have an "elongated" rim by specifying a minimum dimension of 13 ½ inches, measured from the outer face of the urinal rim to the back of the fixture (605.2). Comments were evenly divided on this new specification.
Response. The Board has retained the minimum depth specification without modification. However, in the final rule scoping for accessible urinals has been revised to apply only where more than one urinal is provided in a toilet or bathing room (213.3.3).
Requirements for urinal flush controls are provided in section 605.4. The proposed rule specified a maximum height of 44 inches (the maximum height for obstructed forward reaches). In the final rule, this requirement has been revised to reference section 309 which provides specifications for operable parts, including accessible reach ranges. This change is consistent with the ANSI A117.1‒2003 standard.
606 Lavatories and Sinks
Section 606 provides technical criteria for lavatories and sinks. Various scoping and technical provisions invoke these requirements for lavatories in toilet and bathing facilities and for sinks provided in dwelling unit kitchens, kitchenettes in transient lodging guest rooms, and other spaces, such as break rooms. Revisions made to this section include:
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clarifying the scope of this section (606.1)
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adding a new exception that allows a parallel approach at kitchen sinks in spaces where a cook top or conventional range is not provided (606.2, Exception 1)
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clarifying coverage of metering faucets (606.4)
In addition, allowances specific to lavatories and kitchen sinks in residential dwelling units have been relocated to this section from Chapter 11. These specifications concern clear floor space requirements (606.2, Exception 3) and heights (606.3, Exception 2).
Comment. The proposed rule included references to "lavatory fixtures" and to "vanities." Commenters indicated that such references were redundant or inaccurate and should be removed.
Response. References to "lavatory fixtures" and "vanities" have been removed in the final rule (606.1).
Accessible lavatories and sinks must provide knee and toe clearance for a forward approach (606.2). Consistent with the proposed rule, exceptions from the requirement for forward approach clearances are provided for certain types of spaces and fixtures, such as single-user toilet or bathing facilities accessed only through a private office (Exception 2), lavatories and kitchen sinks in residential dwelling units provided certain conditions to facilitate retrofit for a forward approach are met (Exception 3), and fixtures designed specifically for children 5 years and younger (Exception 5).
Comment. Commenters recommended that a parallel approach should be allowed at kitchen sinks in spaces without a cook top or conventional range, consistent with the ANSI A117.1 standard. Several comments considered a parallel approach to be appropriate at kitchenette sinks in transient lodging guest rooms, consistent with the original ADAAG, and sinks in employee break rooms, since such fixtures are typically used for limited purposes or durations.
Response. The final rule includes an exception, consistent with the ANSI A117.1 standard, that allows a complying parallel approach to kitchen sinks in spaces where a cook top or conventional range is not provided (606.2, Exception 1). This exception also applies to wet bars.
Comment. Faucets, including hand-operated metering faucets, must remain open for at least 10 seconds (606.4). The proposed rule referred to these as "self-closing" faucets. Commenters indicated that "metering" is a descriptor that is more accurate and consistent with plumbing codes.
Response. The reference to "self-closing" faucets has been replaced with "metering" faucets in the final rule.
607 Bathtubs
Specifications for bathtubs in section 607 address clear floor space, seats, grab bars, operable parts, shower spray units, and enclosures. Changes made to this section include:
Two parallel grab bars are required on the back wall of bathtubs with seats (607.4.1.1) and without seats (607.4.2.1). The proposed rule, consistent with the original ADAAG, specified that the lower grab bar be located 9 inches absolute above the bathtub rim. In finalizing this rule, the Board has sought to specify dimensions as a range instead of in absolute terms where possible to facilitate compliance without compromising accessibility. With respect to the lower grab bar at bathtubs, the specified mounting height has been changed to a range of 8 inches minimum to 10 inches maximum above the rim of the bathtub.
Comment. The guidelines require tubs to have shower spray units that can be used as both a fixed position shower head and a hand-held shower (607.6). In the proposed rule, the Board included a requirement that shower spray units have a water on/off control for greater access. It was also specified that units deliver water that is thermal shock protected to 120 degrees. Comments from persons with disabilities strongly supported the requirement for the on/off control. However, comments from the plumbing industry indicated that the requirement, as worded, would pose cross connections and thermal shock hazards and would conflict with model codes and industry standards. Comments also noted that delivered water should be "temperature limited" to the specified maximum (120 degrees) for consistency with American Society of Safety Engineers (ASSE) standards.
Response. In response to concerns raised about the on/off control for spray units the Board has modified this requirement to include an on/off control "with a non-positive shut-off." This will prevent cross connections and does not conflict with plumbing codes. In addition, while the phrase "temperature limited" was not deemed necessary, the specification for water temperature has been revised to require that delivered water be 120 degrees maximum for consistency with ASSE standards. Corresponding revisions have been made to similar requirements for shower compartments (608.6).
608 Shower Compartments
Section 608 addresses transfer showers and roll-in showers and provides specifications for size and clearances, grab bars, seats, operable parts, shower spray units, thresholds, and enclosures. Revisions made to this section address:
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clearance requirements for roll-in showers (608.2.2)
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alternate roll-in showers (608.2.3)
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shower seats (608.4)
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the location and operation of controls, faucets, and spray units (608.5)
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shower spray units and water temperature (608.6)
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a new exception for fixed shower heads (608.6)
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thresholds (608.7)
In addition, provisions specific to showers in residential dwelling units that were located in Chapter 11 have been incorporated into this section. These provisions concern grab bars (608.3, Exception 2) and shower seats (608.4, Exception).
Comment. Specifications for roll-in shower compartments indicate that an accessible lavatory can overlap the required clear floor space opposite the end with a seat and shower controls (608.2.2). Comments recommended that this provision be revised to recognize that a seat may not always be located in a roll-in shower.
Response. The Board has clarified that accessible lavatories are permitted to overlap clear floor space "opposite the shower compartment side where shower controls are positioned or where a seat is positioned" (608.2.2.1, Exception). Clarification is also provided that lavatories can be provided at either end of the space at roll-in showers without seats where controls are mounted on the back wall.
Comment. Specifications are provided for alternate roll-in showers, including their size and the location of entries (608.2.3). Comments indicated that this provision should be more specific in detailing the design illustrated (Figure 608.2.3).
Response. More detail is provided in the final rule for the configuration of alternate roll-in type showers consistent with the intent of the proposed rule. The revised language clarifies the location of the entry at the end of the long side of the compartment (608.2.3).
Comment. Seats are required in transfer compartments and roll-in showers in transient lodging guest rooms (608.4). The proposed rule indicated that transfer compartments may have "attachable or integral seats," while folding seats were specified for roll-in showers provided in transient lodging guest rooms.
Response. The Board has revised the rule to permit "folding or non-folding" seats in transfer compartments. A certain portion of accessible guest rooms are required to have bathrooms with roll-in showers (224.2). The requirement for folding seats has been revised to apply only to those roll-in showers "required" in transient lodging guest rooms. For example, a hotel with 100 guest rooms would be required to have at least 5 guest rooms that are accessible, one of which would have to provide a roll-in shower; the shower provided in this room would be required to have a folding seat, while the other 4 rooms could be equipped with either tubs, transfer showers, roll-in showers with or without seats, or some combination thereof.
Comment. In transfer compartments, controls, faucets, and shower spray units were to be located no more than 15 inches on either side of the seat centerline, according to the proposed rule (608.5.1). Comments indicated that this specification was not consistent with a corresponding figure showing the location on the side closest to the shower opening.
Response. The final rule has been revised to require that controls and operable parts be located 15 inches maximum from the centerline of the seat toward the shower opening. This is consistent with the intent of the specification so that users can activate the controls before entering the shower.
Specifications for controls, faucets, and shower spray units for alternate roll-in showers are provided in section 608.5.3. In the final rule, the Board has clarified these specifications and provided more detail on their location depending on whether the shower is equipped with a seat. In addition, the final rule allows shower controls, faucets, and shower spray units to be located on the wall adjacent to the seat, as proposed, or on the back wall opposite the seat. These revisions are consistent with similar clarifications in the latest edition of ANSI A117.1 standard.
Showers, like bathtubs, are required to be equipped with movable shower spray units that can be used as a fixed-position shower head and a hand-held shower (608.6). Specifications have been revised in the final rule, consistent with similar requirements for bathtubs, in response to concerns raised by commenters about the on/off control and water temperature as specified in the proposed rule, discussed above at section 607.6.
Comment. The original ADAAG allowed fixed shower heads 48 inches high maximum to be used instead of the required hand-held unit in "unmonitored facilities where vandalism is a consideration." This exception had been removed in the proposed rule due to a lack of clarity on the types of facilities that qualify for this exception. Commenters urged the Board to retain this exception due to problems with vandalism which would increase maintenance at accessible transfer showers.
Response. The final rule includes an exception permitting a fixed shower head in certain facilities (608.6, Exception). The Board has limited this exception so that it does not apply to facilities where vandalism is less likely to occur because the use of bathing facilities is controlled or because incidents of vandalism are traceable. These include bathing facilities in medical care facilities, long term care facilities, transient lodging guest rooms, and residential dwelling units.
Comment. The proposed rule specified a maximum threshold height of ½ inch, provided that those greater than ¼ inch are beveled with a slope of 1:2 maximum (608.7). This provision applied to roll-in showers and to transfer showers. Commenters recommended that a higher threshold be permitted for transfer showers since wheelchair maneuvering over the threshold is not necessary in using the shower.
Response. The Board retained the ½ inch threshold height since positioning for transfer to the seat of transfer showers can be aided where a close approach enables footrests to clear the threshold. However, the Board has revised the specification to allow thresholds at transfer compartments to be vertical or rounded instead of beveled. In addition, the Board has provided an exception for existing facilities to address situations where meeting the maximum threshold height, which is typically achieved by recessing shower pans into the floor, is difficult, if not infeasible, due to certain floor slabs. The final rule includes an exception that permits a threshold up to 2 inches high at transfer showers in existing facilities where providing a ½ inch threshold would disturb the structural reinforcement of the floor slab (608.7, Exception).
609 Grab Bars
Section 609 covers grab bars at water closets, bathtubs, and showers. Specifications address size, spacing, position, surfaces, fittings, and structural strength. Changes to this section address:
The proposed rule specified 1 ¼ to 1 ½ circular cross sections. Non-circular cross sections were to have maximum cross section dimensions of 2 inches, a perimeter dimension between 4 and 4‒11/16 inches, and edges with a c inch minimum radius. For consistency with specifications for handrails, the Board has revised requirements for size (609.2) and spacing (609.3). In the final rule, the maximum circular cross section has been changed from 1 ½ inches to 2 inches. Edges must be rounded, and the requirement that edges have a c [sic] inch minimum radius (609.2 in the proposed rule) has been removed. The Board has clarified that the space between grab bars and projecting objects below and at the ends shall be 1 ½ inches minimum, consistent with criteria for water closets, tubs, and showers (609.3). In addition, the minimum clearance between grab bars and protruding objects above has been changed from 15 inches to 12 inches (609.3), consistent with specifications for toilet paper dispensers included in the proposed rule (604.7) and the ANSI A117.1‒2003 standard.
Comment. Commenters pointed out the proposed rule was not clear on whether the height of grab bars was to be measured to the top or to the centerline.
Response. The Board has clarified that the height of grab bars is measured to the top of the gripping surface (609.4).
610 Seats
Requirements for bathtub and shower seats are provided in section 610.
Comment. Specifications are provided for rectangular and L-shaped shower seats (610.3). The Board sought comment on whether one shape is more usable and accessible than the other (Question 25). Comments were evenly divided in supporting one design over the other. Some comments supported both designs or indicated that there was little difference in access or usability between the two.
Response. No changes have been made to the specifications for shower seats. Either rectangular or L shaped seats may be provided in transfer and roll-in showers.
The guidelines specify the location of seats in tubs, transfer-type showers, and roll-in showers. In the final guidelines, the Board has clarified the location of seats in roll-in showers and alternate roll-in type showers. These changes are consistent with revisions to the placement of shower controls and spray units in alternate roll-in shower stalls (605.8.3).
611 Washing Machines and Clothes Dryers
Section 611 covers washing machines and clothes dryers and provides specifications for clear floor space, operable parts, and height.
Comment. The proposed rule required the door of top loading machines and the door opening of front loading machines to be 34 inches maximum above the floor (611.4). This dimension stems from specifications for obstructed side reaches (308.3). Laundry machine manufacturers stated that this specification is inconsistent with standard industry design, which allows a 36 inch height. Commenters indicated that compliance with the proposed specification would reduce machine capacity and would be difficult to achieve.
Response. The Board has revised the maximum height for doors on top loading machines and the door opening of front loading machines from 34 inches to 36 inches (611.4).
612 Saunas and Steam Rooms
Section 612 provides requirements for saunas and steam rooms and includes requirements for benches and turning space. This section derives from the guidelines the Board developed for recreation facilities and has been included in the final rule without substantive change.
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