# Button



## Rick18071 (Dec 28, 2012)

Button in hall at dentist office for X-ray is 5' high. I think it can only be 48" high for accessibility. There are 5 exam rooms and a button outside of each room in the hall. 2009 IBC & 2003 ANSI. Does any one know of an exemption for this button to not need to be accessible?


----------



## ICE (Dec 28, 2012)

The person that needs access to the button is an x-ray technician.  One couldn't be an x-ray technician and also be confined to a wheelchair.


----------



## codeworks (Dec 28, 2012)

and why is that ?


----------



## steveray (Dec 28, 2012)

1103.2.3 Employee work areas.

Spaces and elements within employee work areas shall only be required to comply with Sections 907.9.1.2, 1007 and 1104.3.1 and shall be designed and constructed so that individuals with disabilities can approach, enter and exit the work area. Work areas, or portions of work areas, that are less than 150 square feet (14 m2) in area and elevated 7 inches (178 mm) or more above the ground or finish floor where the elevation is essential to the function of the space shall be exempt from all requirements.


----------



## ICE (Dec 28, 2012)

codeworks said:
			
		

> and why is that ?


They must be able to stand.


----------



## Doorman (Dec 28, 2012)

> They must be able to stand.


Are individuals with proportionate dwarfism allowed to hold the position of x-ray tech? How about disproportionate dwarfism?


----------



## mark handler (Dec 28, 2012)

ICE said:
			
		

> The person that needs access to the button is an x-ray technician.  One couldn't be an x-ray technician and also be confined to a wheelchair.


WRONG

A wheelchair user *MAY or may Not* be able to do the job, not for you to say.

A wheelchair user is not* confined to a wheelchair,* they *use* a wheelchair for mobility.


----------



## mark handler (Dec 28, 2012)

steveray said:
			
		

> 1103.2.3 Employee work areas.


A hallway is not defined as an Employee work area.

ADASAD 106.5 Defined Terms.

Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.


----------



## brudgers (Dec 28, 2012)

codeworks said:
			
		

> and why is that ?


  Because HR would never hire one of those people.


----------



## mark handler (Dec 28, 2012)

Rick18071 said:
			
		

> Button in hall at dentist office for X-ray is 5' high. I think it can only be 48" high for accessibility. There are 5 exam rooms and a button outside of each room in the hall. 2009 IBC & 2003 ANSI. Does any one know of an exemption for this button to not need to be accessible?


The switch must be lowerd


----------



## mark handler (Dec 28, 2012)

brudgers said:
			
		

> Because HR would never hire one of those people.


And what if that person was injured while employed... you cannot fire that person, you need to make Reasonable accommodations


----------



## ICE (Dec 28, 2012)

I guess a button on the floor would cover them all.


----------



## mark handler (Dec 28, 2012)

ICE said:
			
		

> I guess a button on the floor would cover them all.


You mean 15" above the floor... max lower reach range....


----------



## ICE (Dec 28, 2012)

mark handler said:
			
		

> A hallway is not defined as an Employee work area.ADASAD 106.5 Defined Terms.
> 
> Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.


Pushing a button is work.  I know people that can't do more than that.


----------



## mtlogcabin (Dec 28, 2012)

In the real and praticle world only one of the 5 exam rooms would have to be accessible for the patient. All the other rooms the owner would be required to make reasonable accomodations for any injured or disabled employees. So brudgers is correct a person restricted to a wheel chair would never be hired in the first place because they would not meet the job requirements of, standing, lifting, sitting or squating that is required by most jobs.


----------



## ICE (Dec 28, 2012)

mark handler said:
			
		

> You mean 15" above the floor... max lower reach range....


It's a button....roll the chair over the button, stab it with a crutch, hire a tap dancer


----------



## Doorman (Dec 28, 2012)

Hey Rick, I would be curious...

Just what do these buttons do?  It is inferred it is not for a door operator...


----------



## globe trekker (Dec 28, 2012)

> Just what do these buttons do? It is inferred it is not for a door operator...





> Button in hall at dentist office for X-ray is 5' high.


To operate / activate the X-ray mo-sheen.

.


----------



## mark handler (Dec 28, 2012)

mtlogcabin said:
			
		

> In the real and praticle world only one of the 5 exam rooms would have to be accessible for the patient. All the other rooms the owner would be required to make reasonable accomodations for any injured or disabled employees. So brudgers is correct a person restricted to a wheel chair would never be hired in the first place because they would not meet the job requirements of, standing, lifting, sitting or squating that is required by most jobs.


A wheelchair user is not restricted to a wheel chair

 "....would never be hired in the first place.... "

No blacks, jews or Irish need apply, they wont get along with "us".......

Would not meet the job requirements....You cant make that decision

Tell this guy he cant do the "lifting"







I have never seen an xray tech do any lifting.....


----------



## Doorman (Dec 28, 2012)

> To operate / activate the X-ray mo-sheen.


To operate / activate the X-ray mo-sheen? So any patient strolling down the hall can energize the imaging equipment?  That doesn't sound very sanitary.


----------



## mark handler (Dec 28, 2012)

Doorman said:
			
		

> So any patient strolling down the hall can energize the imaging equipment? .


Make it a key switch... but mount it at 48" max.


----------



## Rick18071 (Dec 28, 2012)

Button

It operates the X-ray machine. They want it high so people won't use it. The trouble is that you can't have a work area in a hall. I'm going to tell them it must be lowered or use a lock box.


----------



## mark handler (Dec 28, 2012)

Not "or"

it must be lowered


----------



## steveray (Dec 28, 2012)

And make sure it does not stick out more than 4"..........

1003.3.3 Horizontal projections.

Structural elements, fixtures or furnishings shall not project horizontally from either side more than 4 inches (102 mm) over any walking surface between the heights of 27 inches (686 mm) and 80 inches (2032 mm) above the walking surface.



			
				Rick18071 said:
			
		

> It operates the X-ray machine. They want it high so people won't use it. The trouble is that you can't have a work area in a hall. I'm going to tell them it must be lowered or use a lock box.


   I am going to have to respectfully disagree with Mark on this one.....the switch is the work area not the hall.  Under ADA, for employees, I think it would be the right thing to do, but not under a code I can enforce....Now lets see...if they put the electrical panel in the hall........


----------



## mtlogcabin (Dec 28, 2012)

Mark

A certain people can not qualify or do certain jobs because of physical limits, Police, fire, construction trades and medical technicians,

I doubt the guy in the picture can squat and lift 50lbs box of records and put it on a shelve 5 ft off the ground



> No blacks, jews or Irish need apply, they wont get along with "us".......


Is not the same as someone who canot physically do a specific job

Rick

The hall is not a "work area" is correct however the wall is providing over exposure to the X-Ray technician from the machine he or she operates numerous times a day.

My dentist office is set up exactly like this. In fact the x-ray equipment is mounted inside a cabinet door above the counter and is located at least 5 ft off the ground.

My advice is let it go the botton is not intended for use by any one but the technician.

1109.12 Controls, operating mechanisms and hardware.

Controls, operating mechanisms and hardware intended for operation by the occupant, including switches that control lighting and ventilation and electrical convenience outlets, in accessible spaces, along accessible routes or as parts of accessible elements shall be accessible .

Exceptions:

1. Operable parts that are intended for use only by service or maintenance personnel shall not be required to be accessible .


----------



## brudgers (Dec 28, 2012)

A radiologist or radiology technician is not a service or maintenance person.

  I will never understand why people go to lengths to rationalize ADA non-compliance.

  It's like defiant child syndrome.


----------



## mark handler (Dec 28, 2012)

brudgers said:
			
		

> A radiologist or radiology technician is not a service or maintenance person.   I will never understand why people go to lengths to rationalize ADA non-compliance.
> 
> It's like defiant child syndrome.


And they wonder why there are a plethora of lawsuits

And why is it mostly access issues that Builder inspectors, plancheckers and building Officials that try to find exceptions to the code.


----------



## Doorman (Dec 28, 2012)

Mark, you said



> Make it a key switch... but mount it at 48" max.


 Okay, I'm with you, that satisfies the end user need to eliminate tampering.

This is getting interesting.

I have had discussions with clients and architects about key switches in the past... is a key operated electric switch compliant with a requirement that operating the device not require grasping or twisting?  Is that phrase applicable here at all?


----------



## globe trekker (Dec 28, 2012)

> I have had discussions with clients and architects about key switches in the past... is a key operated electric switch compliant with a requirement that operating the device not require grasping or twisting? Is that phrase applicable here at all?


It is! 2003 Edition, ICC / ANSI A117.1, Section 309.4, and Section 1109.13 in

the 2006 IBC.

.


----------



## Francis Vineyard (Dec 28, 2012)

These doors have automatic lock when the machine is in operation to prevent unauthorized entry and risk to exposure.  The button is no more secured from entry whether at 5 ft. or 3 ft. AFF.

Accessibility includes all forms of ambulatory impairments, not just for wheel chairs.

Francis


----------



## mtlogcabin (Dec 28, 2012)

brudgers said:
			
		

> A radiologist or radiology technician is not a service or maintenance person.


*Advisory 205.1 General.* Controls covered by            205.1 include, but are not limited to, light switches, circuit            breakers, duplexes and other convenience receptacles, environmental and            appliance controls, plumbing fixture controls, and security and            intercom systems.

This is not a control switch for a portion of the building equipment it is remote switch for a specific piece of equipment. If the button was installed on the x-ray equipment at 52 inches above the finished floor would you make them move it? how about the button on a drill press or a bridgeport mill that is located more than 48 inches above the floor?







Floor Drill Press, Belt Drive, Swing (In.) 17, Motor HP 1, Phase Single, Voltage 120/240, Hz 60, Amps AC 10.2 / 5.1, Capacity Cast Iron (In.) 3/4, Capacity Steel (In.) NA, Spindle Speed (RPM) 144 to 3615, Number of Speeds 16, Chuck Size (In.) 5/8, Spindle Taper MT2, Spindle Travel (In.) 5, Overall Height (In.) 67-1/2, Overall Width (In.) 30-1/4, Overall Depth (In.) 16


----------



## mark handler (Dec 28, 2012)

mtlogcabin said:
			
		

> *Advisory 205.1 General.* Controls covered by            205.1 include, but are not limited to, light switches, circuit            breakers, duplexes and other convenience receptacles, environmental and            appliance controls, plumbing fixture controls, and security and            intercom systems.This is not a control switch for a portion of the building equipment it is remote switch for a specific piece of equipment. If the button was installed on the x-ray equipment at 52 inches above the finished floor would you make them move it? how about the button on a drill press or a bridgeport mill that is located more than 48 inches above the floor?
> 
> 
> 
> ...


It mostly access issues that Builder inspectors, plancheckers and building Officials that try to find exceptions to the code.


----------



## mtlogcabin (Dec 28, 2012)

I don't have to look for an exception to the code about the location of aremote switch to operate a piece of machinery. It is already granted by the state. As for ADA I don't enforce that.

(24) The building official may waive minor building code violations that do not constitute an imminent threat to property or to the health, safety, or welfare of any person.


----------



## mark handler (Dec 28, 2012)

mtlogcabin said:
			
		

> I don't have to look for an exception to the code about the location of aremote switch to operate a piece of machinery. It is already granted by the state. As for ADA I don't enforce that. (24) The building official may waive minor building code violations that do not constitute an imminent threat to property or to the health, safety, or welfare of any person.


And they wonder why there are a plethora of lawsuits


----------



## mtlogcabin (Dec 28, 2012)

In reality what would happen under he federal ADA. A complaint would be made and maybe it might have to moved to make reasonable accomodations for a specific employee not the general public

In CA somebody could make a couple of grand off of this


----------



## mark handler (Dec 29, 2012)

mtlogcabin said:
			
		

> In reality what would happen under he federal ADA. A complaint would be made and maybe it might have to moved to make reasonable accomodations for a specific employee not the general public In CA somebody could make a couple of grand off of this


Four grand per violation, but who's counting.... it would be a violation


----------



## brudgers (Dec 29, 2012)

mtlogcabin said:
			
		

> *Advisory 205.1 General.* Controls covered by            205.1 include, but are not limited to, light switches, circuit            breakers, duplexes and other convenience receptacles, environmental and            appliance controls, plumbing fixture controls, and security and            intercom systems.   This is not a control switch for a portion of the building equipment it is remote switch for a specific piece of equipment. If the button was installed on the x-ray equipment at 52 inches above the finished floor would you make them move it? how about the button on a drill press or a bridgeport mill that is located more than 48 inches above the floor?
> 
> 
> 
> ...


   I'll take this seriously...which is probably a mistake.   A switch on a piece of equipment is not covered by ADAAG - the third "A" stands for "architectural."

  A switch mounted on a wall which controls a piece of equipment, is covered by ADAAG.

  The switch on a piece of equipment may or may not comply with ADA or may be outside its scope.

  A switch on the wall, is not outside the scope.


----------



## mark handler (Dec 29, 2012)

brudgers said:
			
		

> I'll take this seriously...which is probably a mistake.


Proposed Accessibility Standards for Medical Diagnostic Equipment

Published in the Federal Register on February 9, 2012.

36 CFR Part 1195

Docket No. ATBCB 2012-0003

http://www.access-board.gov/mde/nprm.pdf

M307 Operable Parts

M307 provides technical criteria for operable parts used by patients to activate, deactivate, or adjust the diagnostic equipment (see defined terms in M102.1).  For example, equipment used for an auditory examination may require the patient to press a button when sounds are heard.  M307 does not apply to *controls used only by health care personnel or others who are not patients.*

* THESE ARE PROPOSED STANDARDS AND NOT IN EFFECT AT THIS TIME*

*AT THIS TIME, THE SWITCH IS REQUIRED TO BE LOWERED*


----------



## lunatick (Dec 30, 2012)

Rick18071 said:
			
		

> Button in hall at dentist office for X-ray is 5' high. I think it can only be 48" high for accessibility. There are 5 exam rooms and a button outside of each room in the hall. 2009 IBC & 2003 ANSI. Does any one know of an exemption for this button to not need to be accessible?


ADA doesn't mandate absolute accessibility for all.

That stated, it seems that more and more every day, attempts to have it be this way increase.

Hopefully we do not get to the point of filling in the grand canyon so it may be fully enjoyed by all.

That stated, not all employment opportunities require for access and/or are exempt due to nature/need for physical abilities to perform the work.

Among the factors that would determine this answer will be provision not yet enacted.

Board Releases Proposed Standards for Medical Diagnostic Equipment

Concerning Medical Diagnostic Equipment standards.

All of that stated, I would think the switch should be more secured regardless of the height.

For there are plenty of tall morons out there that might activate the equipment with a "Heck I wonder what this does?" response.


----------



## Rick18071 (Jan 1, 2013)

My advice is let it go the botton is not intended for use by any one but the technician.

1109.12 Controls, operating mechanisms and hardware.

Controls, operating mechanisms and hardware intended for operation by the occupant, including switches that control lighting and ventilation and electrical convenience outlets, in accessible spaces, along accessible routes or as parts of accessible elements shall be accessible .

Exceptions:

1. Operable parts that are intended for use only by service or maintenance personnel shall not be required to be accessible .

I don't think that this button is only for maintenance or service. It is for an employee that does not do maintenance.

I only enforce PA law and IBC not ADA or or any other law or code. The state checks our accessibility inspections and I could lose my cert if I don't get it right.

if the button was in a work area I wouldn't care if it was 10' high but the IBC says that you can't have a work area in a hall.

They can go to the apeal board if they don't like it.


----------



## globe trekker (Jan 2, 2013)

> I only enforce PA law and IBC not ADA or or any other law or code.


From the 2006 IBC, Section 1101.2 = Design:Buildings and facilities shall be designed

and constructed to be accessible in accordance with this code and ICC A117.1.

Under Section 1109.13 (2006 IBC), ...the control switch for the X-Ray mo-sheen

will have to be lowered, ..possibly locked to prevent tampering / unauthorized use.

.


----------

