# Doctors office & ada



## RJJ

I have a small fitout for a Doctor who will have six exam rooms. Each room is designed to have an ada accessible sink.

Now the question has been raised that they want cabinets below the sink and no approach opening. I believe if you have a sink it must comply. If You think different please provide the section from 2009 IBC or A117.


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## Little_Guy

2012 UIBC 1109.3 5% but not less than 1, it is a theme that is through the Accessible codes we enforce, like the parking, it does not require all parking spaces to be accessible but a percentage of them. Your scenario is the same thing, at least one (1) of the six would have to be accessible.


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## steveray

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.


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## globe trekker

RJJ,

Will the 2010 ADA SAD also be applicable in your application? If so, then Section 606.2 will apply

to all sinks, in all Exam Rooms. A Forward Approach clearance must be provided, ..no side

approach!   (i.e. - knee & toe clearances underneath each sink must be provided in each Exam

Room)

.


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## mark handler

June 2007 Building Safety Journal

http://www.mrsc.org/artdocmisc/sinks.pdf

.... within a doctor’s examining room  or a dental treatment area.

Full access must be provided to work areas that also function as public use spaces—such as examining rooms—but, in general, the sink or sinks in an examining or treatment room may be considered to be “elements” within an employee work area and therefore exempt from accessibility requirements per IBC Section 1103.2.3. However, if intended to be used by both employees and patients, sinks would need to be accessible per IBC Section 1109.3 and comply with ICC A117.1 Section 606.

This leads to questions like: “Is it more likely that a sink in a medical doctor’s examining room will be used by patients than one in a dentist’s treatment room?” Although the intuitive answer may be “yes,” that is no guarantee that the designer and users will all agree, while taking an “all or nothing” approach—either at least 5 percent but not less than one sink in every examining or treatment room must be accessible, or none are required to be accessible—is no less likely to result in conflicts. In such situations, a compromise solution should be considered. Allowing the designer some flexibility while assuring that a certain level of accessibility

is provided serves everyone’s best interests and will help the space function better over the long term.

One option would be to apply the scoping limits of IBC Section 1109.3 to either the total number of rooms or to each type of room rather than to each individual room. This will help assure that in every doctor’s or dentist’s office, at least one examining or treatment room containing a sink will serve the needs of any employee or patient who might need to use it.

Another option would be to permit the use of a parallel approach to the sinks instead of the forward approach required by ICC A117.1 Section 606.2. A parallel approach makes sink height and controls accessible while allowing the installation of cabinets underneath. If this option is allowed, it seems reasonable to require that all—or at least a higher percentage—of the sinks in examining or treatment rooms be accessible in this manner.

There are other possibilities for providing accessibility while facilitating flexibility. The code official may decide to allow a combination of the two previous options such that the sinks in some examining or treatment rooms provide a fully compliant forward approach and the remainder provide a parallel approach, or allow the use of removable base cabinets per ICC A117.1 Section 1003.11.5.

Disability advocates may not be completely pleased with some of these options, but at the very least they help illustrate how limiting code officials to an “all or nothing” prescriptive approach can sometimes have the unintended consequence of actually limiting flexibility to adapt to users’ needs, whereas compromise solutions may be available which ensure a level of accessibility that might otherwise not exist at all.

Conclusion

The appropriate application of IBC Sections 1109.3 and 1103.2.3 is not always cut-and-dried. However, by giving careful consideration to the individual situation and the  potential long-term effects on both the project and the people who will be using it, it is possible to reach a solution that serves the best interests of everyone.

Whether required by the applicable code provisions and standards or not, making elements in accessible spaces  accessible or adaptable facilitates the future accommodation of users. In the event that an employee needs accessible  elements—even on a temporary basis—there will ideally be at least one work area available that can be adapted without requiring extensive, and often expensive, alterations. As such, where multiple work stations of the same type are  provided, it may be a good idea to offer future flexibility  by making a minimum of 5 percent of them accessible per ICC A117.1


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## lpiburn

I have had similar issues come up before.  Would it be acceptable to provide removable cabinets as long as the floor and wall finishes are continued behind it? That way the end user could keep their extra storage but could also easily make the space fully accessible in the event that they hired a disabled employee in future.

Obviously this would be a special approval but would you even consider it?


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## RJJ

lpiburn: I would not approve it. How would someone with disabilities be able to remove the cabinet?


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## RJJ

Globe The section provided is what I would have applied. And Mark the post from the Building Safety Journal creates some ability to be flexible. I remember reading this back in 07. Great posts !


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## globe trekker

If the code official and the RDP disagree on "what is actually required", ..then what? Who gets

to decide on the path to compliance. The RDP will usually (not always) offer that "they're

saving their client money", while still being compliant, and too, ..they will be liable for their design

"if" litigation is ever brought.

I am looking for some more dialogue and guidance on this as I have plans for a medical

facility in my office right now, with this very application.

Thanks for the timely topic "RJJ".

.


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## steveray

I have had the discussion with several DP's.....they explain in writing with detail and a seal how they are satisfying the code, and I am good....As long as it remains gray...


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## RJJ

Yes it seems a little gray and I am trying to work through it. If they provide a sink it must be accessible. Most doctors are not going to have an exam room that does not provide a place to wash hands.

The article form the safety journal is a great article, but it is not code!

The 5% I also do not think applies.


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## globe trekker

I agree "RJJ"!

.


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## Francis Vineyard

A similar request made to our office:

" provided a cabinet door with the toe kick attached to the door - so that when the doors are opened the required ADA roll-under forward approach at the sink is provided with the cabinet door handles are within reach ranges in accessibility code and can be opened easily by someone needing that extra space to get under the sink"





Francis


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## RJJ

In PA we get audited and even a reasonable decision on the part of the code official is not permitted. You have to totally relay on L&I and I am reluctant to call them. They will give you advice, but will not put it in writing. Unless they write you up for missing something.


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## JPohling

I do a significant amount of medical offices.  We typically will provide 5% fully accessible exam room sinks.  It is a grey area.  We have never had any issues at all.


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## globe trekker

In researching the requirement for Accessibility compliance of the sinks in the Exam Rooms,

is the 5 % number a federal allowance (DOJ = 2010 ADA SAD), or does that number come

from the IBC or A117.1? Please cite the applicable section for reference. Thank You!

Essentially, if there is an Exemption from Accessible requirements in the IBC or A117.1,

..will the requirement still be there under the 2010 ADA SAD?

.


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## Rick18071

I always considered the cabinets, counter, and sink a work area. Patients usuly use the rest room sink wich should be accessible.


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## mark handler

Not less than 5 percent in each accessible room or space...


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## JPohling

That would equate to each sink in each exam room.


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## mark handler

That would equate to each sink in each accessible exam room.


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## globe trekker

What if plans for "new" construction do not label the "one Accessible Exam Room"?
Then, does each Exam Room have to have a Forward Approach (compliant) sink,
according to Section 606.2 in the 2010 ADA SAD?

If the 2010 ADA SAD is THE last word in Accessibility; other than California, ..by
the Letter of that standard, wouldn't each sink in each Exam Room have to be
Forward Approach compliant?

Isn't this what some of us continuously debate / argue over, ..the actual written
standard vs. our interpretations / opinions of a standard?

Just trying to process of all this, so I can relay / discuss it with others.    Thanks!


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## RJJ

Mark I am on the same page. As Globe stated just trying to process all this even my own ?. Today I am going to focus just on the code sections and respond with a position and why! I will post for debate. Should prove interesting.


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## JPohling

I see your logic.  thats pretty much what we do.  5% of the exam rooms have accessible sinks so 5% are accessible rooms.  It really does not work very well the way the rooms are used by the docs.  There is no telling when a wheelchair user is going to roll in for an appointment and they do not set them aside, so its just random luck that they are available.  Typically we run 3 exams per doc to allow them to work continuously, so really only one of the docs actually has the "accessible" room available.  We are seeing a move back to wall hung sinks in exams and many exams now do not have sinks at all.   All the docs think that the accessible sinks are completely unfounded and they would prefer we treat them as employee work areas.


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## mark handler

JPohling said:
			
		

> I see your logic.  thats pretty much what we do.  5% of the exam rooms have accessible sinks so 5% are accessible rooms.  It really does not work very well the way the rooms are used by the docs.  There is no telling when a wheelchair user is going to roll in for an appointment and they do not set them aside, so its just random luck that they are available.  Typically we run 3 exams per doc to allow them to work continuously, so really only one of the docs actually has the "accessible" room available.  We are seeing a move back to wall hung sinks in exams and many exams now do not have sinks at all.   All the docs think that the accessible sinks are completely unfounded and they would prefer we treat them as employee work areas.


That's why most doctors offices are fully accessible


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## JPohling

Actually I would say that most exam room sink areas within doctors offices are not accessible.


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## mark handler

JPohling said:
			
		

> Actually I would say that most exam room sink areas within doctors offices are not accessible.


I guess we go to different doctors


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## globe trekker

Aaaaaawwwll-righty then!

In "cracking my books", ..I am desiring to obtain some guidance and clarity.
*QUESTION # 1:* If the DOJ / Federal ADA Standards apply regardless of
the state, ..jurisidiction, ..or who's in office, ..or who someone knows, ..or
who someone can pay off, etc., and a jurisdiction adopts the ICC codes
and by reference, ..the ICC A117.1, can 3 sets of standards be legally
enforced, ..is there legal precedence to apply 3 sets of standards?   *NOTE:*
There is at least one standard (maybe more) in the A117.1 that is not in
the 2010 ADA SAD, ..*"vertical grab bars"*. See Section 604.5.1, 2003
Edition of the A117.1.

*QUESTION # 2:* If the Federal standards will apply regardless, then
should / will the A117.1 or IBC standards apply at all?    Here, trying to
apply all 3 standards ain't going well!

*My commentary:*
I am researching thru 3 sets of Accessible standards and
trying to successfully navigate / interpret / administer all
3 sets in to some type of coherent, understandable, politically
acceptable, contractor & developer friendly compilation on
all projects. I find it to be challenging and exciting, but also
frustrating at times. I regularly get the "deer in the headlights"
looks from RDP's, contractors, developers, colleagues,
political decision makers and others.     In reading the
discussions on this forum, it seems apparent that a lot of
you get "the looks" too!

If I seem to be overly redundant, incoherent, obtuse, or
just "out in out" stupid, I'll just go ahead now ask for your
indulgence and patience.   I DO have lot's of questions,
which is why I enjoy coming to this Forum to learn, ask
questions; even stupid, redundant ones, and to have
discussions. I am sure that all of us will never agree
completely on anything, but let us at the very least, be
civil and courteous to one another.   This Forum far
surpasses any other Forum on the internet, bar none!
Let's try to improve on this GREAT resource, what do
you say?


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## mark handler

Always the most restrictive for the designer

Always the codes the AHJ/inspectors are authorized/empowered to enforce and not judgment calls


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## Alias

JPohling said:
			
		

> Actually I would say that most exam room sink areas within doctors offices are not accessible.


Where I was previously employed, no exam room sinks were accessible in any of the four local clinics.

One clinic had a Doctor who used crutches due to polio, she was a good doc.  Bathrooms, doors, parking, etc. were all CA ADA compliant at the clinic.  Why not exam room sinks, who knows?

Sue


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## RJJ

Globe: I can only agree with your statements above. I find myself at times struggling to find the correct answer and at times have to review various commentary or articles to find the right path. Thus my OP on sinks in exam rooms.

If we step back and not include new construction / a new building things become complicated. In a totally new setting everything must comply. However, the remaining parts on existing buildings start to be come complicated.

To me often the application of rules become a guessing game. The OP was a simple question from the applicant, but still a complicated question. Here goes my response. If six exam rooms are proposed and will have counters and sinks then all counters and sinks must comply. The sinks must have forward approach. That would include approach space not in conflict with exam tables, chairs etc found in the exam room. How many exam room comply now? They may have the sink and counter ok until they furnish the place.


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## Rick18071

All the doctors exam rooms I ever been in they don't want the patents touching anything on the counter. For employees only. An employee work area.

However if the patents are supposed to use it is required to be accessible. Same with the sink.

PA only adopted IBC & ANSI. So that's all we are required to inspect by.


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## JPohling

Has there ever been any consensus on this?  Height of exam room counter with sink?  all at +34"?  5% of the total exam rooms at +34"?  Any allowed at +36"?


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## JPohling

JPohling said:


> Has there ever been any consensus on this?  Height of exam room counter with sink?  all at +34"?  5% of the total exam rooms at +34"?  Any allowed at +36"?


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## JPohling

Has there ever been any consensus on this? Height of exam room counter with sink? all at +34"? 5% of the total exam rooms at +34"? Any allowed at +36"?


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## conarb

JPohling, good question, but another question is whatever happened to our old friend RJJ?


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## north star

*@ ~ @ ~ @*

JPohling,

I do not know of any "official" concensus, but Contractors
look for \ operate [ typically ] on the path of least resistance.
To me that would mean, to order all of the Exam Room
cabinetry to be at 34", and to not have some at 34" and some
at 36".......That way, all countertops would be compliant.
But what the heck do I know...


conarb,

The rumors & Speculation Grapevine has it that
***RJJ*** no longer wanted to play in this sand-box,
with these sand-box rules.

I can neither confirm nor deny that rumor !.....This
is only my opinion !

*@ ~ @ ~ @*


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## steveray

JPohling said:


> Has there ever been any consensus on this? Height of exam room counter with sink? all at +34"? 5% of the total exam rooms at +34"? Any allowed at +36"?


IF it is an "employee work area" it is exempt....Does it make sense to get it "right" when it is in new construction? Yes....But if they don't want to they can just remodel or get sued later when there is a complaint...No way for me to force it.


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## conarb

North Star said:
			
		

> conarb,
> 
> The rumors & Speculation Grapevine has it that
> **RJJ** no longer wanted to play in this sand-box,
> with these sand-box rules.
> 
> I can neither confirm nor deny that rumor !.....This
> is only my opinion !



Thanks, he was a good ally in the fight against sprinklers, he provided real insight when he attended the Minneapolis hearings. Forums have tended towards echo chambers, many like-minded people have gravitated to Facebook that welcomes echo chambers.


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