# Dinking Fountain vs Water Cooler



## Mule (Apr 21, 2010)

Do you guys allow a water cooler in place of a drinking fountain?

I don't know how a water cooler would work as far as accessabilty for wheelchair or standing.

2006 IBC B occupancy. The way I read it is that one is required but you have to provide one high one low.


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## FredK (Apr 21, 2010)

No.  No.  No.


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## globe trekker (Apr 21, 2010)

*.*

*Mule, Yes, we allow the water coolers or even,  ...bottled water [ in the individual bottles ] in place of*

*the water fountains.       Requiring water fountains on "change of occupancies" or even small tenant*

*spaces is not politically digestable here.          I DO know what the code requires, but sometimes that*

*is just not a financially attractive option for the small business owner.        Essentially,  we are trying*

*to meet the ' intent ' of the code  vs.  ' the letter ' of the code.        It's part of that  "learning to pick*

*my battles" thingy.*

*.*


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## brudgers (Apr 21, 2010)

globe trekker said:
			
		

> *.**Mule, Yes, we allow the water coolers or even,  ...bottled water [ in the individual bottles ] in place of*
> 
> *the water fountains.       Requiring water fountains on "change of occupancies" or even small tenant*
> 
> ...


Who cares if it violates civil rights?


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## Yikes (Apr 21, 2010)

Our California Plumbing Code, based on the 2006 Uniform Plumbing Code, requires drinking fountains in certain locations per Table 4-1.  Per footnote 12 on that same table: "where food is consumed indoors, *water stations may be substituted for drinking fountains*."  It goes on to describe that larger office buildings may need drinking fountains for employee use, but in the context of the table 4-1, there may still be interpretive room on this issue and a water station might still meet the requirement in lieu of a drinking fountain.

So in theory, if your applicant says they intend to consume food indoors (for example, and employee break room), then a water station may be a viable alternative, at least here in California.

This leads to the next question: what is a "water station"?  We believe it is a facility where a container can be filled with water for drinking purposes.  On the old code chat bulletin board, various people offered that this could be a domestic water sink with paper cups nearby, or bottled water, etc.

The high/low concept for drinking fountains has to do with bending over to get your mouth near the stream of water.  At a water station, you don't bring your mouth to the water - - you bring the water to your mouth (via a container), so bending over, hi/low provisions are not an issue.

I personally don't think that supplying drinking water in every facility is a civil rights issue.  I think it is up to the code to state when it is required.  However, when drinking water _is _supplied, then reasonable accomodation for everyone to have access to that water IS a civil rights issue.  We also believe that under the concept of equivalent facilitation in our building code, a "water station" would also need to be accessible, using forward or side reach ranges for access to controls and dispensers.

It is possible that a water cooler could be made accessible.  for example, I used a water cooler last night where the cold water valve was a push-down lever, operated by very light pressure.  This could be operated without grasping or pinching, etc.  A container could be placed on the drain grate under the spigot, so the user would not have to hold the cup while the water is coming out.

This same water cooler had a hot-water option that had a child-proof safety latch that would NOT be considered accessible.


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## Gene Boecker (Apr 21, 2010)

Ooooooo!

Yikes, you're my new hero!


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## Yikes (Apr 21, 2010)

Gene, thanks but be forewarned - - I'm not a building official, so it's just an architect's opinion.  Having said that, I've had several favorable rulings from various local building officials around here (So Cal) on this very issue.

One one project, a church had a kid's Sunday School building, where they always served water to the kids with a mobile serving cart in each room that had a water dispenser with spigot, paper cups, and some cookies.  This met the requirement of footnote 12 "where food is consumed indoors...".  The building official required the church to write a letter for his file, stating their intent to maintain this system as a condition of code compliance / occupancy of the building.


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## brudgers (Apr 21, 2010)

A sink is a drinking fountain, black is white, up is down...and a cup doesn't require grasping.

Either that or my nine year old is correct and it's opposite day.


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## Pcinspector1 (Apr 22, 2010)

Mule,

Weird code, after you do a plan review and theres no fountain, they then get a choice of a fountain or water cooler?

Two years later when your in the building and your parched, the coolers gone! I heard the 2009 code sez you got to provide a chicken salad sandwich and no-fat chips! Is this true?


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## texas transplant (Apr 22, 2010)

Mule,

410.1 Approval.

Drinking fountains shall conform to ASME A112.19.1M, ASME A112.19.2M or ASME A112.19.9M and water coolers shall conform to ARI 1010. Drinking fountains and water coolers shall conform to NSF 61, Section 9. Where water is served in restaurants, drinking fountains shall not be required. In other occupancies, where drinking fountains are required, water coolers or bottled water dispensers shall be permitted to be substituted for not more than 50 percent of the required drinking fountains.

Last line of the above section from 2006 IPC gives some leeway to bottled water dispensers.


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## brudgers (Apr 22, 2010)

texas transplant said:
			
		

> Mule,410.1 Approval.
> 
> Drinking fountains shall conform to ASME A112.19.1M, ASME A112.19.2M or ASME A112.19.9M and water coolers shall conform to ARI 1010. Drinking fountains and water coolers shall conform to NSF 61, Section 9. Where water is served in restaurants, drinking fountains shall not be required. In other occupancies, where drinking fountains are required, water coolers or bottled water dispensers shall be permitted to be substituted for not more than 50 percent of the required drinking fountains.
> 
> Last line of the above section from 2006 IPC gives some leeway to bottled water dispensers.


Right, so long as you have one drinking fountain you comply with IPC.  If that one drinking fountain is accessible you might comply with ADAAG too.

Zero drinking fountains doesn't comply with either (except for the exception in the IPC).


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## Yikes (Apr 22, 2010)

Again, a California thing - -our accessiblity code (CBC chapter 11B) is written such that IF you provide a drinking fountain, it must be hi/low.  For space planning purposes, there is practically no such thing as only "one" drinking fountain - - it's effectively "two": one high and one low.

Brudgers - actually, there are cups available that do not require grasping with fingers.  I have friends that use them - - basically, the "handle" is large enough to put your wrist through.

As a complete aside, I have another friend whose hand was amputated two years ago up to half the forearm.  He has been fitted with a prosthetic hand that has complete gripping ability for the individual fingers - -it senses minor movements in his remaining forearm muscles and each finger responds accordingly.  If you saw that thing operate, you'd swear he was "The 6 million dollar man" in real life (actually, it was about $50k).  Amazing technology!


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## Mule (Apr 23, 2010)

Thanks for all the responses. This is actually going to be an animal clinic.

In the 2006 IBC

1109.5 Drinking fountains. Where drinking fountains are

provided on an exterior site, on a floor or within a secured area,

the drinking fountains shall be provided in accordance with

Sections 1109.5.1 and 1109.5.2.

The key word "Where"

Then you go to Chapter 29 Plumbing Fixtures and Table 2902.1 Minimum Required Plumbing Fixtures refers you to 410.1 of the IPC, the section Texas Transplant refers to, requires a minimum of 1 per 100 for a Business classification.

So now we have "one" required if the occupancy load is less than 100 per 410.1 of the IPC.

Okay so back to 1109.5. "Where"...Okay so we do have "one" drinking fountain required.

1109.5 goes on to say.

shall be provided in accordance with

Sections 1109.5.1 and 1109.5.2.

1109.5.1 Minimum number. No fewer than two drinking

fountains shall be provided. One drinking fountain shall

comply with the requirements for people who use a wheelchair

and one drinking fountain shall comply with the

requirements for standing persons.

Exception: A single drinking fountain that complies

with the requirements for people who use a wheelchair

and standing persons shall be permitted to be substituted

for two separate drinking fountains.

So 1109.5.1 specifies a minimum of "two" however the exception to 1109.5.1 allows you to go back to a single drinking fountain that complies with the requirements may be permitted.

1109.5.2 does not come into play here because the applicant is only going to provide the minimum required.

So now we are jumping back to the plumbing code Section 410 that TT posted last sentence.

In other occupancies, where drinking fountains are

required, water coolers or bottled water dispensers shall be permitted

to be substituted for not more than 50 percent of the

required drinking fountains.

Since only "one" drinking fountain is required, a water cooler or bottled water dispenser is allowed because I am not allowing the water cooler to substitute for more than 50% of the required amount.

If three drinking fountains were required then one could be a water cooler and the other two would have to be drinking fountains.

So it appears in this situation that a water cooler meets code as long as the water cooler meets 1109.5.1 Exception.

Any comments??? Do you guys agree??


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## Yikes (Apr 23, 2010)

What about the dog's drinking fountain?

http://www.k9guzzler.com/


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## vegas paul (Apr 23, 2010)

Yikes - that web site indicates that the dog fountain is ADA compliant... I presume that means for the operational buttons/shut-off valve.  But what about disabled dogs?  Don't you need TWO dog fountains???  Some dogs can't bend down that far, and I believe in equal access for all dogs...      I need to adjust the dosage....


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## FredK (Apr 23, 2010)

Yikes said:
			
		

> What about the dog's drinking fountain?http://www.k9guzzler.com/


Guess you haven't seen the plans for the new dog drinking fountain in the new dog park over here.   Seem to recall it could fall under the swiming pool regs before it was done.  Our regs say anything with water over 18 inches in depth gets regulated and this way exceeded that.  Due to current budget I figure it may get changed before they decide to do it.


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## Yikes (Apr 23, 2010)

vegas paul said:
			
		

> Yikes - that web site indicates that the dog fountain is ADA compliant... I presume that means for the operational buttons/shut-off valve.  But what about disabled dogs?  Don't you need TWO dog fountains???  Some dogs can't bend down that far, and I believe in equal access for all dogs...      I need to adjust the dosage....


ADA = All Doggies Allowed!


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## Yikes (Apr 23, 2010)

Or perhaps within the vet's office, the regular and ADA-height toilets function for the pets like hi/low doggie drinking fountains.


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## brudgers (Apr 24, 2010)

Yikes said:
			
		

> Brudgers - actually, there are cups available that do not require grasping with fingers.  I have friends that use them - - basically, the "handle" is large enough to put your wrist through.


Are they stamped with "DOJ Approved?"

And which section of ADAAG allows them?


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## brudgers (Apr 24, 2010)

Mule said:
			
		

> Thanks for all the responses. This is actually going to be an animal clinic.In the 2006 IBC
> 
> 1109.5 Drinking fountains. Where drinking fountains are
> 
> ...


How did "a water cooler" become "a drinking fountain?"

Transubstantiation?


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## Mule (Apr 26, 2010)

1109.5.2 does not come into play here because the applicant is only going to provide the minimum required.

So now we are jumping back to the plumbing code Section 410 that TT posted last sentence.

In other occupancies, where drinking fountains are

required, *water coolers or bottled water dispensers shall be permitted*to be substituted for not more than 50 percent of the

required drinking fountains.


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## Yikes (Apr 26, 2010)

brudgers said:
			
		

> Are they stamped with "DOJ Approved?"And which section of ADAAG allows them?


1. As a matter of fact, it has the exact same kind of "DOJ Approved" stamp as you would expect to find on a drinking fountain.

2.  ADAAG 4.1.3 (10).  "*Where* only one drinking fountain is provided on a floor..."

If the code does not require a drinking fountain on a floor, and you have not provided a drinking fountain, then you are in compliance with 4.1.3 (10).

If the applicable codes do not actually require a particular facility to exist, then no facilitation for anybody is a form of equal facilitation for everybody.

Let's continue this sidetrack discussion (if necessary) in the accessibility forum.


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## Mech (Apr 26, 2010)

Mule,

If you find a way to permit a single water cooler to substitute the high / low water fountain, I'd be interested.  I have a building with a design occupant load of about 150 people, but an actual occupant load of only 5 (five) people and I am required to have the high / low water fountains.  Seems a little ridiculous to me.

Semantics time:

Does the IBC or the IPC define drinking fountains or water coolers?  I don't remember them doing so.  Wikipedia lists water coolers as being both the traditional drinking fountain (bottle-less water cooler) and the 5 gallon bottled water dispensers (bottle water cooler).  Elkay's site indicates to me that a water cooler is a drinking fountain with a refrigeration unit attached.

Anything from the code commentary?


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## brudgers (Apr 26, 2010)

Yikes said:
			
		

> 1. As a matter of fact, it has the exact same kind of "DOJ Approved" stamp as you would expect to find on a drinking fountain.2.  ADAAG 4.1.3 (10).  "*Where* only one drinking fountain is provided on a floor..."
> 
> If the code does not require a drinking fountain on a floor, and you have not provided a drinking fountain, then you are in compliance with 4.1.3 (10).
> 
> ...


1.  There's are diagrams in ADAAG (as well as text) showing the requirements for drinking fountains.  That's the best DOJ approval one can have.

2.  Do you also apply the "if it's not required by code then it doesn't need to be accessible" logic elsewhere?  BTW, I've never seen a code mandated second story.


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## brudgers (Apr 26, 2010)

Mech said:
			
		

> Mule,If you find a way to permit a single water cooler to substitute the high / low water fountain, I'd be interested.  I have a building with a design occupant load of about 150 people, but an actual occupant load of only 5 (five) people and I am required to have the high / low water fountains.  Seems a little ridiculous to me.
> 
> Semantics time:
> 
> ...


Good luck with the Wikipedia defense.

ADAAG (and A117.1) have diagrams of drinking fountains.

So "drinking fountain" is not only defined in the building code, but in Civil Right law as well.


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## Mech (Apr 27, 2010)

Brudgers: I was trying to point out that "water cooler" did not seem to have a definitive description.


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## Uncle Bob (Apr 27, 2010)

Good luck with enforcement.  If they are really that thirsty; they can get a drink from the lavatory/urinal, in the bathroom.

Uncle Bob


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## Plans Approver (Apr 27, 2010)

The DOJ does not approve any products as "ADA Approved".

_"The Department of Justice does not certify or endorse any individual or organization as ADA consultants, and does not approve or endorse any products or designs as being in compliance with the ADA. Any individual or business claiming to have such a certification or endorsement may be violating various state and federal laws prohibiting fraud and misrepresentation."_

Read the whole letter here. http://www.justice.gov/crt/foia/tal397.txt

Has there been an update?  I don't know of one.


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## mtlogcabin (Apr 27, 2010)

Mt state ammendment drinking fountains are NOT required in B, M, Nightclubs, Restaurants, Assited Living, Hotels, Motels and Lodges.

footnote r On an individual case by case basis the BO may approve an alternative source of potable drinking water, such as, a bottled water cooler, in lieu of a drinking fountain.

If they choose to put one in it is high/lo style. There is no reason in this jurisdiction to subsitute a bottled water cooler in lieu of a drinking fountain. There are facilities around this state that are open to the public and do not have potable water piped into the buildings. Restrooms are supplied by untreated springs , creeks or cisterns and this is a UPC state so hot water is not required for hand washing as was brought up in another post

Sometimes my job is easiers than others  :wink:


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## Yikes (Apr 28, 2010)

brudgers said:
			
		

> 1.  There's are diagrams in ADAAG (as well as text) showing the requirements for drinking fountains.  That's the best DOJ approval one can have.


Awesome, I agree that's the way to go _when you are required or choose to provide a drinking fountain_.  Let me know where ADAAG describes the minimum number of drinking fountains for a given use or occupancy, without such qualifiers as "when provided" or "where provided" that send me back to my locally adopted codes.



			
				brudgers said:
			
		

> 2.  Do you also apply the "if it's not required by code then it doesn't need to be accessible" logic elsewhere?


No, I don't apply that statement anywhere.  What I *do** apply is restated from above: **If the applicable codes do not actually require a particular facility to exist, then **no facilitation for anybody** is a form of equal facilitation for everybody.**  If it's not required, and I choose not to provide, then there's nothing to be out of compliance.*





			
				brudgers said:
			
		

> *BTW, I've never seen a code mandated second story.*


*My point exactly! If I designed an accessible one-story building, no one could criticize me for omitting an elevator to provide accessibilty to the (non-existent) second story, even though ADAAG thoroughly defines and covers the requirements for an elevator, and requirements for accessibility to an upper floor... if such a floor ever existed.*

*At my office we do not have an ATM machine - - our HR department is the "money station", handing out paychecks every couple of weeks at their desk.  If we decided to replace HR with an onsite ATM, well-then I suppose our new ATM would have to meet ADAAG requirements, wouldn't it?  OR if ADAAG mandated that all companies have at least one onsite ATM, then I'd have to comply... but they don't...  and I won't be losing any sleep over it.*


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## brudgers (Apr 28, 2010)

Unless you're in use group R, you're required to have a drinking fountain  by most "locally adopted codes."

(and sometimes even then)

Install a water cooler in lieu of it, and you're not meet ADAAG.

(not meeting the code either)


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## Yikes (Apr 28, 2010)

brudgers said:
			
		

> Unless you're in use group R, you're required to have a drinking fountain  by most "locally adopted codes."


See my original response in post #5 which addresses the issue of locally adopted code.


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## brudgers (Apr 28, 2010)

Yikes said:
			
		

> See my original response in post #5 which addresses the issue of locally adopted code.


That's the one with the mythical "water station."

I don't buy it any more as a substitution for a drinking fountain, today, than I did then.


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## Yikes (Apr 28, 2010)

brudgers said:
			
		

> That's the one with the mythical "water station."I don't buy it any more as a substitution for a drinking fountain, today, than I did then.


Hey, no problem; that's why I practice architecture in California, using California codes.

"When in Rome..."

Peace out.


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## brudgers (Apr 28, 2010)

and ADAAG?


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## Yikes (Apr 29, 2010)

brudgers said:
			
		

> and ADAAG?


Repeating from post #30: "Let me know where ADAAG describes the minimum number of drinking fountains for a given use or occupancy, without such qualifiers as "when provided" or "where provided" that send me back to my locally adopted codes."

My state's code has provisions that in certain circumstances allow 100% water stations, 0% drinking fountains.

We're now talking in circles, so I have nothing further to add.


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## 88twin (Apr 29, 2010)

im cornfused, if one is required and i substitute one for one aren't I substituting 100% not 50%


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## brudgers (Apr 29, 2010)

Yikes said:
			
		

> Repeating from post #30: "Let me know where ADAAG describes the minimum number of drinking fountains for a given use or occupancy, without such qualifiers as "when provided" or "where provided" that send me back to my locally adopted codes."  My state's code has provisions that in certain circumstances allow 100% water stations, 0% drinking fountains.
> 
> We're now talking in circles, so I have nothing further to add.


California's accessibility code is not DOJ certified.


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## Yikes (May 9, 2010)

Here's the response from the ADA technical assistance center regarding my inquiry as to water stations:

*

Thank you for contacting the Pacific ADA Center. The Pacific ADA Center provides technical assistance, training, education and written materials regarding the Americans with Disabilities Act (ADA).

The ADA is a civil rights law that ensures that individuals with disabilities get afforded the same rights as everyone else in the areas of employment, state and local government facilities and programs, public accommodations and telecommunications.

The list of questions and answers listed below are in response to your questions regarding a water station and the ADAAG.

Q-1.  If a local code allows a facility to provide water stations in lieu drinking fountains, does ADAAG still require drinking fountains in addition to said water stations?

A-1. ADAAG does not require a drinking fountain to be installed, only that it meet the accessible guidelines if one is installed.

Q-2.  Does ADAAG address the definition of "water station"?

A-2.  ADAAG makes no reference to the definition of "water station."

Q-3.  a. What features would a "water station" require in order to be considered compliant with ADAAG?

            b. Would it simply be the same features as for an accessible sink or lavatory?

            c. What about a traditional "water cooler" - does this qualify as an ADAAG-compliant water station?

A-3.  a., b. ADAAG does not provide any guidelines in reference to a water station other than following the guidelines for dispensing devices under section 4.2 as stated under Special Occupancies (In general it should be accessible to and useable by persons with disabilities.)  RESTAURANTS AND CAFETERIAS, 5.6 Tableware and Condiment Areas.

Self-service shelves and dispensing devices for tableware, dishware, condiments, food and beverages shall be installed to comply with 4.2.

(4.2 Space Allowance and Reach Ranges, 4.27 Controls and Operating

Mechanisms)

And following guidelines for Drinking Fountains and Water Coolers, see link below.

            c. Water coolers must comply with Section 4.15 Drinking Fountains and Water Coolers. See link:

http://www.adata.org/adaportal/Facility_Access/ADAAG/Tech_Rqmts/ADAAG_4-

15.html

Q-4.  At a water station, are cups required to be provided by the facility?  If so, do the cups need and special design features?  ...and does the act of holding the cup constitute a "grasp" problem?

A-4. The ADAAG makes no reference to a water station or the requirements of cups.

Q-5. What is the ADAAG definition of "grasp"?

A-5. The ADAAG refers to accessing controls and operations mechanisms

as: 4.27.4 Operation. Controls and operating mechanisms shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls shall be no greater than 5 lbf (22.2 N).

Please call a Technical Assistance Specialist at 1-800-949-4232 between the hours of 8:00 AM and 5:00 PM, Pacific Time for ADA and accessible IT assistance and technical information, or if you would like to order any written materials. You can also visit our web site at www.adapacific.org

The information presented in this email is intended solely as informal guidance, and is neither a determination of legal rights or responsibilities under the ADA, nor is it binding on any agency with enforcement responsibilities under the ADA.

Robert Farr, ADA Specialist

DBTAC: Pacific ADA Center

1-800-949-4232 Toll Free (V/TTY)

1-510- 285-5600 (V/TTY)

email: adatech@adapacific.org

www.adapacific.org


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