# sales counter with forword approach.



## Rick18071 (Mar 9, 2015)

I'm looking at a reception window. In front of the window there is a accessible 36" high shelf/counter that is lower than the bottom of the window for the public. The employee side of the window also has a higher counter than the accessible shelf. If the shelf has the required space (17" deep for knee and toe space) under it for a forward approach then the window opening and the empolyee side counter doesn't need to be the same height the full depth as it would for a parallel approach?

Why is that?

904.3.1 Parallel Approach.

A portion of the counter surface 36 inches (915 mm) minimum in length and 36 inches (915 mm) maximum in height above the floor shall be provided. Where the counter surface is less than 36 inches (915 mm) in length, the entire counter surface shall be 36 inches (915 mm) maximum in height above the floor. A clear floor space complying with Section 305, positioned for a parallel approach adjacent to the accessible counter, shall be provided.

from the commentery:

Typically, service counters are designed and used from both sides at the same time. An employee will address the counter from one side while the other side is used for customers. Sales and service counters are designed using a vast assortment of materials, and the sizes and shapes are limited only by the imagination of architects and designers. Because sales and service counters can take on many shapes and be constructed to a wide variety of sizes it is important to establish guidelines that will ensure a portion of the counter will contain an area that is accessible for someone using a wheelchair. The 36 inch (915 mm) height will allow for a standard counter height. The width of the accessible counter must be at least 36 inches minimum. For interaction between the customer/employee, the 36-inch (915 mm) height must be the full depth of the counter. A shelf under a higher window is not adequate.

904.3.2 Forward Approach.

A portion of the counter surface 30 inches (760 mm) minimum in length and 36 inches (915 mm) maximum in height above the floor shall be provided. A clear floor space complying with Section 305, positioned for a forward approach to the accessible counter, shall be provided. Knee and toe clearance complying with Section 306 shall be provided under the accessible counter.

from the commentary:

Sometimes a service counter can be the location where someone may need to fill out forms or access information. In these cases, the service window should have a forward approach with knee and toe clearances similar to a work surface.


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## jdfruit (Mar 9, 2015)

If the employee side of the reception window is within high forward reach, then items necessary to transact the business can be passed from employee to customer. If the items are expected to be larger, like merchandise in boxes, then the employee side should be at the same level as the customer side.

Reception is not typically the same as sales, please clarify the window function.


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## Rick18071 (Mar 10, 2015)

sales counter with forword approach.

That's all its called on the plans. It will be in a medical clinic for employees in a large campus of a drug company.


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## jdfruit (Mar 10, 2015)

Medical reception typically is passing paperwork through the window for checkin/checkout and paying for services (sometimes). Take a look at how the pay transactions are handled; check, credit card reader, etc. & make sure the equipment is within reach range to the customer counter. Paperwork is usually filled out remote from the reception window and on a clipboard. If no clipboard, make sure there is an accessible table in the area.

Appears your situation the employee side being higher is not an issue. Your OP indicates 36" counter height on customer side, if writing is necessary at the counter 28" - 34" is the height range.


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## Rick18071 (Mar 10, 2015)

I only enforce 2012 IBC chapter 11 and 2009 ANSI. Not ADA or anything else.

The code doesn't say anything about packages. I don't think there will be paying for services here because it is a medical service area for empoyees. So actually empoyees will be using both sides of the counters. To keep it simple I'll call the empolyee that came in for service the patient.

This section was always confusing to me.  The counter on the employee side of the widow is higher (36")  than the counter on the patient side of the window (30"). The sliding window opening bottom is the same height as the employee counter (36"). The commentary says "For interaction between the customer/employee, the 36-inch (915 mm) height must be the full depth of the counter. A shelf under a higher window is not adequate." The commentory seems to be more conserned about interaction than packages.  Also ANSI 904.3 says "The accessible portion of the countertop shall extend the same depth as the sale and service countertop".

1. Is the patient side counter considered the service countertop and the employee side counter considered as a separate counter top so it's ok the way they want to build it.

2. Are both counters considered as the same countertop and need to be the same height?

3. If they are considered different counters would it matter if the employee side was higher than 36"?

4. Could the bottom of the window be higher than 36" too?

5. Is the window bottom ok at 36" if both counters are at 30"?

6. Do any of these answers change if it  a forward or a parallel approach?


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## Francis Vineyard (Mar 10, 2015)

Does the following help answer your question?

Reviewingthe 2010 ADA Standards and the ICC/ANSI A117.1 we find language that could be construed to mean the counter must be continuous, from the front public/customer side to the back employee side of the counter. To find more on this we look to the Department of Justice Guidance on the 2010 ADA Standards forAccessible Design3 as follows: 



_Section904.4 of the 2010 Standards also clarifies that the accessible portion of the counter must extend the same depth as the sales or service counter top. Where the counter is a single-height counter, this requirement applies across the entire depth of the counter top. Where the counter is a split-height counter, this requirement applies only to the customer side of the counter top. The employee-side of the counter top may be higher or lower than the customer-side of the counter top. _



From this there is clearly a distinction made as to the employee side of the counter and the public/customer side of the counter. The USDOJ explicitly states that the requirement only applies to the public/customer side of the counter and that a split counter height is allowed.

http://www.tmgada.com/wp-content/uploads/ART_ADA_teller-2011_0506.pdf


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## Rick18071 (Mar 10, 2015)

Thanks Francis. This seems to say the opposite of what the commentory says:

"For interaction between the customer/employee, the 36-inch (915 mm) height must be the full depth of the counter. A shelf under a higher window is not adequate."

I would think this would also mean on the employee side. They could have a 5' high counter on the employee side and there would could not be any interaction with someone on a wheel chair.

I'm more confused.


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## Rick18071 (Mar 10, 2015)

Just got this answer from PA L&I accessiblity board. They have the last say in this state.:

1. Is the public side counter considered the service countertop and the employee side counter considered as a separate counter top so it's ok the way they want to build it. No.

2. Are both counters considered as the same countertop and need to be the same height? Yes.

3. If they are considered different counters would it matter if the employee side was higher than 36"? N/A

4. Could the bottom of the window be higher than 36" too?  Only if there is an opening below if physically passing material back and forth.

5. Is the window bottom ok at 36" if both counters are at 30"? Yes.

6. Do any of these answers change if it  a forward or a parallel approach? No.


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## Francis Vineyard (Mar 10, 2015)

Rick aside from difference in interpretations I believe ICC is leaning towards a more restrictive language by adding window to 904.1 2009 A117.1

Good call.


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## Code (Apr 16, 2015)

My ADA reps. interp



			
				Rick18071 said:
			
		

> Just got this answer from PA L&I accessiblity board. They have the last say in this state.:1. Is the public side counter considered the service countertop and the employee side counter considered as a separate counter top so it's ok the way they want to build it. No.
> 
> 2. Are both counters considered as the same countertop and need to be the same height? Yes.
> 
> ...


I had a bank put their sales/service counter at 42" throughout, despite calling it out during plan review.  After calling our Great Plains ADA center Region VII (being buisness friendly), I was told that a forward approach would work with varying heights surfaces if they met the requirements for a workstation.  So 34" AFF max, with knee and toe clearance for a front approach.


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## ADAguy (Apr 16, 2015)

Rick, is your customer aware that he has a responsibility to build to ADA minimums in spaite of your code approval?

Why don't code officials and AG's accept responsibility for implimenting Federal civil rights law?


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## steveray (Apr 16, 2015)

"Why don't code officials and AG's accept responsibility for implimenting Federal civil rights law?"

Because I have enough to do already.....


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