# Why are lavatories, etc. excepted from protrusion limits



## Yikes (Dec 1, 2015)

2010 ADA 306 "Knee Clearance" allows for maneuvering clearance up to 25" deep under "elements" (such as lavatories), if the elements are min 27" above finish floor (AFF).

On the other hand, 2010 ADA 307.2 also considers anything between 27-80" AFF and greater than 4" deep to be a "protrusion".

How do you reconcile the two?

I know that for drinking fountains they require wing walls as a warning.  But other than drinking fountains, what prevents anything else in the 4-25" depth range from simply being called an "element" rather than "protrusion"?


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## Builder Bob (Dec 1, 2015)

307.1 General. Protruding objects on circulation paths

shall comply with Section 307.

circulation path: An exterior or interior way of passage

from one place to another for pedestrians.

Key word is pedestrians ----- more than one people... a sink is contained within a space and is not considered a passage from one place to another


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## mark handler (Dec 1, 2015)

Builder Bob said:
			
		

> 307.1 General. Protruding objects on circulation pathsshall comply with Section 307.
> 
> circulation path: An exterior or interior way of passage
> 
> ...


So a blind person is supposed to know?  He/she is not in a circulation path?


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## Francis Vineyard (Dec 1, 2015)

Though my copy does not say minimum; but would it be better if it were 27-in. maximum?

306.3 Knee Clearance.306.3.1 General. Space under an element between 9 inches (230 mm) and 27 inches (685 mm) above the finish floor or ground shall be considered knee clearance and shall comply with 306.3.

and also note . . .

307.2 Protrusion Limits. Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finish floor or ground shall protrude 4 inches (100 mm) maximum horizontally into the circulation path.


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## JBI (Dec 1, 2015)

I second Builder Bob's assertion that it is not a 'circulation path', certainly not within the context and the plain meaning of the language of the code.

mark handler's blind person actually WOULD know they are not in a circulation path... or would have someone with them.


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## ADAguy (Dec 1, 2015)

Restrooms with gangs of lavs and stalls accommodate more than one with lavs often projecting beyond walls as you enter the rooms.

Placement is critical but often overlooked.


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## Francis Vineyard (Dec 2, 2015)

Where approaching parallel to the wall the lavatory would be permitted to extend up 4 inches beyond the wall.

_Do drinking fountains pose hazards as protruding objects?_

Cantilevered units at standard heights for people who stand must be recessed or protected as protruding objects. This is not required for wheelchair accessible units with no more than a 27” clearance below (the minimum required for knee clearance and the maximum recognized for cane detection).





http://www.access-board.gov/guidelines-and-standards/buildings-and-sites/about-the-aba-standards/guide-to-the-aba-standards/chapter-3-protruding-objects


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## mark handler (Dec 2, 2015)

JBI said:
			
		

> ... blind person actually WOULD know they are not in a circulation path... or would have someone with them.


So you are* Assuming * that all blind persons Should know there is a "protrusion", or several "protrusion" spaced apart, in a path of travel OR that all blind Shall have a person with them when they enter the restroom...


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## mark handler (Dec 2, 2015)

*Are Lavatories Exempt?*

*Does it actually say that?*


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## mtlogcabin (Dec 2, 2015)

I would assume he read the signage at the entrance to the door that indicated he was entering a restroom and experience would would have taught him that there maybe many protruding objects within this room that he has no idea of the size of or where facilities are located or how many.

The photos you provided indicate paper towel dispensers, sinks and possible soap dispenser as protruding objects.

Can you provide a court case example where this has come up in the past twenty years and a possible decision?

Just hard to believe some one in your state is not making a ton of money off of this.


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## Yikes (Dec 2, 2015)

What started the original post was an existing bathroom at a rental office (see attached photo).  I was asked to do an ADA evaluation, and among other violations (such as the cabinet), the paper towel dispenser is suspended over the required floor clearance for the sink.CBC 11B allows for wall-mounted encroachments into the toilet floor clearance, but is silent on encroachments in the sink floor clearance, so I assume encroachments are generally prohibited.  Then I started asking myself, how tall is the required floor clearance for the sink?  If the sink itself can encroach at 27" high, can other elements also encroach at 27" or higher?

View attachment 1255


View attachment 1255


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## mark handler (Dec 2, 2015)

Yikes said:
			
		

> What started the original post was an existing bathroom at a rental office (see attached photo).  I was asked to do an ADA evaluation, and among other violations (such as the cabinet), the paper towel dispenser is suspended over the required floor clearance for the sink.CBC 11B allows for wall-mounted encroachments into the toilet floor clearance, but is silent on encroachments in the sink floor clearance, so I assume encroachments are generally prohibited.  Then I started asking myself, how tall is the required floor clearance for the sink?  If the sink itself can encroach at 27" high, can other elements also encroach at 27" or higher?


There are issues with the picture but encroachment of the sink is not one of them and it is not wall mounted.


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## Yikes (Dec 2, 2015)

mark handler said:
			
		

> There are issues with the picture but encroachment of the sink is not one of them and it is not wall mounted.


Mark, I guess what I'm saying is:  if the code allows for sinks to not be called out/prohibited as a protrusion, what prevents other items (towel dispensers, wall sconces, etc.) from claiming the same territory of the code instead of being called a protrusion?


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## mark handler (Dec 2, 2015)

Yikes said:
			
		

> ... what prevents other items (towel dispensers, wall sconces, etc.) from claiming the same territory of the code instead of being called a protrusion?


Code ....

There is nothing that give any of it from meeting the code, including the sink.


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## Yikes (Dec 2, 2015)

From what I've read in this thread so far, and looking at the photo I supplied above, I think that Builder Bob found the only code difference between calling the towel dispenser an "element" vs a "protrusion":

An "element" becomes a "protrusion" when it is on a "circulation path".

CBC 202 defines "circulation pat"h as:

"[DSA-ACJ An exterior or interior way of passage provided for pedestrian travel, including but not limited to, walks, hallways, courtyards, elevators, platform lifts, ramps, stairways and landings."

So, we are left with a subjective interpretation of whether any given floor space was intended to be a "way of passage for pedestrian travel".


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## Francis Vineyard (Dec 3, 2015)

Does the following code section help answer the intention?

1104.5 Location. Accessible routes shall coincide with or be

located in the same area as a general circulation path. Where

the circulation path is interior, the accessible route shall also

be interior. Where only one accessible route is provided, the

accessible route shall not pass through kitchens, storage

rooms, restrooms, closets or similar spaces.

As a reminder the building code scopes the requirement the standard specs how to comply.


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## Rick18071 (Dec 3, 2015)

Why are lavatories, etc. excepted from protrusion limits

IBC 1003.3 Protruding objects has nothing to do about an accessible route.


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## Builder Bob (Dec 3, 2015)

These times may have a specific application while the protrusion code section is a general.....

604.7 Dispensers. Toilet paper dispensers shall comply

with Section 309.4. Where the dispenser is located

above the grab bar, the outlet of the dispenser shall be

located within an area 24 inches (610 mm) minimum

and 36 inches (915 mm) maximum from the rear wall.

Where the dispenser is located below the grab bar, the

outlet of the dispenser shall be located within an area

24 inches (610 mm) minimum and 42 inches (1065 mm)

maximum from the rear wall. The outlet of the dispenser

shall be located 18 inches (455 mm) minimum and 48

inches (1220 mm) maximum above the floor. Dispensers

shall comply with Section 609.3. Dispensers shall

not be of a type that control delivery, or do not allow

continuous paper flow.

603.5 Diaper Changing Tables. Diaper changing I tables shall comply with Sections 309 and 902


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## JPohling (Dec 4, 2015)

I would have tagged the soap and paper towel dispenser too.



			
				Yikes said:
			
		

> What started the original post was an existing bathroom at a rental office (see attached photo).  I was asked to do an ADA evaluation, and among other violations (such as the cabinet), the paper towel dispenser is suspended over the required floor clearance for the sink.CBC 11B allows for wall-mounted encroachments into the toilet floor clearance, but is silent on encroachments in the sink floor clearance, so I assume encroachments are generally prohibited.  Then I started asking myself, how tall is the required floor clearance for the sink?  If the sink itself can encroach at 27" high, can other elements also encroach at 27" or higher?


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## Builder Bob (Dec 4, 2015)

funny thing is that ADA guidlines don't provide guidance for them as they generally don't protrude more than 4 inches from the wall.


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## greenbubba (Dec 21, 2015)

Unless I'm missing something, to comply with both then the bottom of the sink has to be at 27". I don't see an exception. In fact on a phone call with DOJ a few months back, they indicated any wall is a potential circulation path. They were willing to consider a wall behind an instructor area in a classroom as an 'employee work area', but even that has the potential for a violation if the podium or furniture separating it from the classroom is ever moved. BTW - by coincidence that is the topic of training in January at; http://www.accessibilityonline.org/Schedule/#nextSession


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## Yikes (May 2, 2016)

> Unless I'm missing something' date=' to comply with both then the bottom of the sink has to be at 27". I don't see an exception. In fact on a phone call with DOJ a few months back, they indicated any wall is a potential circulation path. They were willing to consider a wall behind an instructor area in a classroom as an 'employee work area', but even that has the potential for a violation if the podium or furniture separating it from the classroom is ever moved. BTW - by coincidence that is the topic of training in January at; [url']http://www.accessibilityonline.org/Schedule/#nextSession[/url]


Just checking in - - did anyone attend that webinar, and was there any conclusion on this issue?


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## ADAguy (May 3, 2016)

Thank you for brining this up, inquiring minds await responses.

As to toilet paper dispensers adjacent to WC's and below the bar.

This is not so much a cane issue as it is an obstruction of use to those who are large in girth.

TP projections in excess of 4" limit obese access to and from WC's.

In the same way use of Tandom role dispensers with outlets beyond 7-9" limit Users without extremeties who can lose their balance when reaching forward.


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## mark handler (May 3, 2016)

Are toilet paper dispensers adjacent to WC's in the "_potential circulation path"_

*Not in my opinion*


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## greenbubba (May 5, 2016)

Yikes said:


> Just checking in - - did anyone attend that webinar, and was there any conclusion on this issue?


I attended some of it - note it is archived online. I don't recall lavatories being specifically addressed, but I concluded wall hung lavatories are okay if the 27" is max. There is a definition of circulation path; "Circulation Path. An exterior or interior way of passage provided for pedestrian travel, including but
not limited to, walks, hallways, courtyards, elevators, platform lifts, ramps, stairways, and landings."


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