# Accessible Service Counter



## rooster (Jun 15, 2012)

We're having a bit of a disagreement at the office...

Let's say at a bank you have 4 teller stations.  One of those stations must be 36"h for an accessible service counter (much to the owner's dismay).  The openings for the stand-up counters are all 24" wide.  Does the accessible counter have to be a 36" wide opening, or does it only have to be the width of the stand up counters?  Keep in mind that the entire accessible counter will be 36"H.

_*ANSI 904.3 Parallel Approach.*__  A portion of the counter surface 36 inches minimum in length and 36 inches maximum in height above the floor shall be provided.  Where the counter surface is less than 36 inches in length, the entire counter surface shall be 36 inches 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._


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## Big Mac (Jun 15, 2012)

36" is required per code.  Persons in a wheelchair require a larger amnuvering space.


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## Big Mac (Jun 15, 2012)

36" is required per code. Persons in a wheelchair require a larger manuvering space.   (Typo in the previous posting)


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## rooster (Jun 15, 2012)

Big Mac said:
			
		

> 36" is required per code. Persons in a wheelchair require a larger manuvering space.   (Typo in the previous posting)


But what if I want a 24" long counter?  It seems that ANSI 904.3 is allowing me to have a counter length less than 36"...despite the fact it says 36" min.


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## Big Mac (Jun 15, 2012)

As I read 904.3 it states 36" minimum for a parallel approach, 30" for a forward approach.  I don't see any reference to 24" at all.  I am looking at the 2003 Standard which is the current standard referenced in the 2009 IBC.  Are you looking at a different year, or perhaps a state amendment?

Also remeber, if you use 30" for a forward approach, you will need to provide knee and toe space.


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## rooster (Jun 15, 2012)

Big Mac said:
			
		

> As I read 904.3 it states 36" minimum for a parallel approach, 30" for a forward approach.  I don't see any reference to 24" at all.  I am looking at the 2003 Standard which is the current standard referenced in the 2009 IBC.  Are you looking at a different year, or perhaps a state amendment?Also remeber, if you use 30" for a forward approach, you will need to provide knee and toe space.


I'm referring to this from ANSI 904.3:

_Where the counter surface is less than 36 inches in length, the entire counter surface shall be 36 inches 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. _


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## rooster (Jun 15, 2012)

So what if I just decided I want a 24" service counter?  Seems like


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## rooster (Jun 15, 2012)

delete "seems like"


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## Big Mac (Jun 15, 2012)

I see now where you are comming from.  I would think the intent is for perhaps existing situations, although it doesn't say that.  It has always been my approach that if when dealing with new construction, the intent is to fulfill the entire letter of the code if at all possible.  I seldom buy the argument, well I just don't want to. The need to see extenuating circumstances to allow somethign less.

Remember, the whole premise of the code is equal access.  That does not necessarily mean equal manuvering clearances and equal dimensions for counter top applications.  The clear truth is that disabled persons in wheelchairs need more space to function.

Even if the ANSI Standard would accept something less than a 36" length, the building owner & business owner still need to be concerned about what is allowed or required by the ADA Standards and enforced by the Department of Justice.


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## rooster (Jun 15, 2012)

Thanks for the reply Big Mac.  This is basically what we have assumed all a long and that if there is going to be a service counter, it's going to be 36" long.  This is obviously the safest way to go.

But then I started reading the ANSI 904.3 a little closer and it seems odd that they put that last section in there with nothing in regards to a 36" long counter not being feasible.  To me it seems to read that I can put a 24" wide counter in just because I want to as long as the whole service counter is 36"h max.


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## rooster (Jun 15, 2012)

And actually, in this case it's a bank, so it's not necessarily "just because they want 24"."  They just don't like that big of an opening from the lobby to the teller area...an opening that is wide, low, and usually un-manned.


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## Big Mac (Jun 15, 2012)

If it were me, I would suggest to the bank that they are trying to hard to avoid what the code has intended.  Please suggest that they have their lawyers review ADA requirements.  Sounds to me like they are leaving themselves wide open for a disability lawsuit.


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## rooster (Jun 15, 2012)

Big Mac said:
			
		

> If it were me, I would suggest to the bank that they are trying to hard to avoid what the code has intended.  Please suggest that they have their lawyers review ADA requirements.  Sounds to me like they are leaving themselves wide open for a disability lawsuit.


ADA says the exact same thing regarding service counters.  And I'm not sure why it's skirting requirements if it is by code.  ANSI and ADA could have simply said 36"min length .  But instead they throw in this bit about a counter less than 36" in length.  I don't think it's unreasonable to look into it.


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## mark handler (Jun 15, 2012)

ANSI is not code, it is a standard, that some Jurisdictions have codified

ADASAD is not code, it is a standard, By the Feds to assist the Design Professionals, courts and other interested parties, to understand and comply with the ADA.

The ADA is a Civil Rights Law.

If you do not follow the ADASAD, a standard, You risk a lawsuit.

The "guidelines" serve as a basis for ADA "standards" enforced by the Department of Justice

Since there is no such thing as Grandfathering in the ADA, the ADASAD Allows for exceptions for existing buildings to assist buisness owners to comply one such "exceptions" is for service counters.



> *904.4 Sales and Service Counters**EXCEPTION: In alterations,,,,the counter shall be permitted to have a portion which is 24 inches (610 mm) long minimum complying with 904.4.1 provided that the required clear floor or ground space is centered on the accessible length of the counter.*


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## Big Mac (Jun 15, 2012)

It is my impression (perhaps erroneously) that when a state or juridiction adopts a building code, it becomes law.  If that is correct and said juridicationhas adopted the I-Codes it appears that the ICC standard is also law.

Buildings and facilities SHALL be designed and constructed in accordance with this code and ICC A117.1.  2009 IBC, Section 1102.

Waht am I missing?


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## mark handler (Jun 15, 2012)

Big Mac said:
			
		

> It is my impression (perhaps erroneously) that when a state or juridiction adopts a building code, it becomes law.  If that is correct and said juridicationhas adopted the I-Codes it appears that the ICC standard is also law.Buildings and facilities SHALL be designed and constructed in accordance with this code and ICC A117.1.  2009 IBC, Section 1102.
> 
> Waht am I missing?


As Stated "...some Jurisdictions have codified..." the ICC/ANSI-117.

The ADA is a Federal Law.

A designer and the owner are required to design to the most restrictive.

A BO needs to enforce the Code of that juridication.


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## georgia plans exam (Jun 15, 2012)

It seems to me that, if the stand up counters are 24" and the entire 24" length of the accessible counter is 24", you are providing "equal access".

JMHO

GPE


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## mark handler (Jun 15, 2012)

georgia plans exam said:
			
		

> It seems to me that, if the stand up counters are 24" and the entire 24" length of the accessible counter is 24", you are providing "equal access".JMHO
> 
> GPE


24" long, not high *in alterations only,* New construction needs to be 36" long


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## georgia plans exam (Jun 15, 2012)

Oops. I meant 36" high.

GPE


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## rooster (Jun 15, 2012)

*904.4 Sales and Service Counters*

* EXCEPTION: In alterations,,,,the counter shall be permitted to have a portion which is 24 inches (610 mm) long minimum complying with 904.4.1 provided that the required clear floor or ground space is centered on the accessible length of the counter.*

This is interesting that it says alterations here.  I looked at ADA and in the text it said nothing of 'alteration', but then I took another look at the figure which does say 'alteration.'  Although in the text it does say "when the counter provided..."

SO...it seems that ADA is intending that this less than 36" is for existing conditions.  ANSI is just confusing.


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## rogerpa (Jun 15, 2012)

> It is my impression (perhaps erroneously) that when a state or  juridiction adopts a building code, it becomes law.  If that is correct  and said juridicationhas adopted the I-Codes it appears that the ICC  standard is also law.


"The standards are part of the code *to the extent of the reference* to the standard."

The IBC, 2003 I think, provided a "safe haven" from the ADA. I don't know if this is still the case.

2009 IBC

* 1109.1 General.* Accessible building features and facilities shall be provided in accordance with Sections 1109.2 through 1109.14.

*1109.11.3 Point of sale and service counters*. Where counters

are provided for sales or distribution of goods or services, at least one of each type provided shall be accessible.

Where such counters are dispersed throughout the building or facility, accessible counters shall also be dispersed.

No mention of ANSI A117.

Could this be considered a check writing surface?

ANSI A117

*904.4.3 Check Writing Surfaces*. Where provided, check writing surfaces shall comply with Section 902.3.

*902.3 Height*. The tops of dining surfaces and work

surfaces shall be 28 inches (710 mm) minimum and

34 inches (865 mm) maximum in height above the

floor.

Or

*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.

The more I read the more convoluted it gets.


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## mark handler (Jun 16, 2012)

rooster said:
			
		

> i looked at ada and in the text it said nothing of 'alteration', but then i took another look at the figure which does say 'alteration.'  although in the text it does say "when the counter provided..."


What ADA are you looking at?

Are you looking at the 2010 ADASAD or the 2004 ADAAG? Or the actual text of the ADA in the Federal Register?

Are you plan checking this or designing this counter?


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## mark handler (Jun 16, 2012)

Is this a "moot" Question?

Is the bank new?

Or is This an alteration?

What State is the bank in?


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## Paul Sweet (Jun 16, 2012)

The counter may be required to be 36" long, but there is no minimum length for the pass-thru.


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## incognito (Jun 18, 2012)

I believe if it is a counter in which they will be writing checks maximum height is 34". At least that is how I interpret the 2010 regs.


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## rooster (Jun 18, 2012)

mark handler said:
			
		

> What ADA are you looking at?Are you looking at the 2010 ADASAD or the 2004 ADAAG? Or the actual text of the ADA in the Federal Register?
> 
> Are you plan checking this or designing this counter?


This was the ADA I was looking at: http://www.access-board.gov/ada-aba/ada-standards-doj.cfm#built-in

And of course I was looking at ANSI 2003 also.

I am looking at the counter from the eyes of the designer, and I'm looking at it in the case of New Construction.

I typically design every accessible service counter 3'wide, but recently I saw a boiler plate kind of response from a plan checker that says, *"This portion [accessible service counter] shall be at least as wide as the ambulatory teller windows, without being required to be greater than 36" in width."*

Now I know this is the plan checker's interpretation, but it got me thinking and looking harder at ANSI 904, which was the plan checker's reference.  Also, this plan checker is VERY thorough in regards to accessiblility, so I thought it was at least something to look into.

I want to make clear that I'm not trying to skirt any requirements by asking this question, I'm merely trying to get a grip on the intent...an intent that I have perhaps misunderstood.


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## Big Mac (Jun 18, 2012)

Mark - I am a bit confused by your statement that "some jurisdictions" have codified it.  I must admit I am also a bit confused by those that apparently feel that if every specific section of the ICC A117.1 Section is referenced by the building code, that it doesn't apply.

Section 1101.2 of the 2009 International Building Code (as well as the international codes before it) states "Buildings and facilities SHALL be designed and constructed in accordance with this code and ICC A117.1."  That language doesn't suggest to me that there is an option whether you enforce the ANSI Standard or not, assuming that you have adopted the IBC, unless of course you specifically remove it in the adoption process.

Therre is no language included there that would indicate portions of the ICC Standard could be ignored.  Are you trying to say that there are jurisdictions out there that are not enforcing the IBC?


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## mark handler (Jun 18, 2012)

big mac said:
			
		

> mark - i am a bit confused by your statement that "some jurisdictions" have codified it.  I must admit i am also a bit confused by those that apparently feel that if every specific section of the icc a117.1 section is referenced by the building code, that it doesn't apply.Section 1101.2 of the 2009 international building code (as well as the international codes before it) states "buildings and facilities shall be designed and constructed in accordance with this code and icc a117.1."  that language doesn't suggest to me that there is an option whether you enforce the ansi standard or not, assuming that you have adopted the ibc, unless of course you specifically remove it in the adoption process.
> 
> Therre is no language included there that would indicate portions of the icc standard could be ignored.  Are you trying to say that there are jurisdictions out there that are not enforcing the ibc?


some states do not use the ansi 117 at all, some have adoped thir own standards some have adopted the adasad

ansi is not the all inclusive standard


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## mark handler (Jun 18, 2012)

rooster said:
			
		

> This was the ADA I was looking at: http://www.access-board.gov/ada-aba/ada-standards-doj.cfm#built-inAnd of course I was looking at ANSI 2003 also.
> 
> I am looking at the counter from the eyes of the designer, and I'm looking at it in the case of New Construction.
> 
> ...


Relook at what you directed us to :

904.4 Sales and Service Counters.  Sales counters and service counters shall comply with 904.4.1 or 904.4.2.  The accessible portion of the counter top shall extend the same depth as the sales or service counter top.

EXCEPTION:  In alterations, when the provision of a counter complying with 904.4 would result in a reduction of the number of existing counters at work stations or a reduction of the number of existing mail boxes, the counter shall be permitted to have a portion which is 24 inches (610 mm) long minimum complying with 904.4.1 provided that the required clear floor or ground space is centered on the accessible length of the counter.


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## rooster (Jun 18, 2012)

mark handler said:
			
		

> Relook at what you directed us to :904.4 Sales and Service Counters.  Sales counters and service counters shall comply with 904.4.1 or 904.4.2.  The accessible portion of the counter top shall extend the same depth as the sales or service counter top.
> 
> EXCEPTION:  In alterations, when the provision of a counter complying with 904.4 would result in a reduction of the number of existing counters at work stations or a reduction of the number of existing mail boxes, the counter shall be permitted to have a portion which is 24 inches (610 mm) long minimum complying with 904.4.1 provided that the required clear floor or ground space is centered on the accessible length of the counter.


This would be a project in PA, by the way.  And to answer another question you had, this is moot I suppose because the counter has already been designed 36"w.  More than anything I was looking for clarification on something I might have misinterpretted.

I must admit I looked past the section you quoted and was actually looking at this:

*904.4.1 Parallel Approach.  A portion of the counter surface that is 36 inches (915 mm) long minimum and 36 inches (915 mm) high maximum above the finish floor shall be provided.  A clear floor or ground space complying with 305 shall be positioned for a parallel approach adjacent to the 36 inch (915 mm) minimum length of counter. *

*EXCEPTION:  Where the provided counter surface is less than 36 inches (915 mm) long, the entire counter surface shall be 36 inches (915 mm) high maximum above the finish floor.*

What I find goofy about this whole thing is that what you quoted basically says that if it doesn't comply with 904.4.1 or 904.4.2 then you may have a 24" accessible counter.  BUT I can have a 24"w counter that complies with 904.4.1 according to the exception of 904.4.1 (where it says nothing about alterations).

I'm not trying to grasp at straws.  It really doesn't matter to me one way or the other.  It just seems odd that 904.4.1 includes that exception at all, just like I think it's odd that ANSI 2003 904.3.1 includes the same language, when all they had to say was *36" MIN*


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## rooster (Jun 18, 2012)

mark handler said:
			
		

> Relook at what you directed us to :904.4 Sales and Service Counters.  Sales counters and service counters shall comply with 904.4.1 or 904.4.2.  The accessible portion of the counter top shall extend the same depth as the sales or service counter top.
> 
> EXCEPTION:  In alterations, when the provision of a counter complying with 904.4 would result in a reduction of the number of existing counters at work stations or a reduction of the number of existing mail boxes, the counter shall be permitted to have a portion which is 24 inches (610 mm) long minimum complying with 904.4.1 provided that the required clear floor or ground space is centered on the accessible length of the counter.


This would be a project in PA, by the way.  And to answer another question you had, this is moot I suppose because the counter has already been designed 36"w.  More than anything I was looking for clarification on something I might have misinterpretted.

I must admit I looked past the section you quoted and was actually looking at this:

*904.4.1 Parallel Approach.  A portion of the counter surface that is 36 inches (915 mm) long minimum and 36 inches (915 mm) high maximum above the finish floor shall be provided.  A clear floor or ground space complying with 305 shall be positioned for a parallel approach adjacent to the 36 inch (915 mm) minimum length of counter. *

*EXCEPTION:  Where the provided counter surface is less than 36 inches (915 mm) long, the entire counter surface shall be 36 inches (915 mm) high maximum above the finish floor.*

What I find goofy about this whole thing is that what you quoted basically says that if it doesn't comply with 904.4.1 or 904.4.2 then you may have a 24" accessible counter.  BUT I can have a 24"w counter that complies with 904.4.1 according to the exception of 904.4.1 (where it says nothing about alterations).

I'm not trying to grasp at straws.  It really doesn't matter to me one way or the other.  It just seems odd that 904.4.1 includes that exception at all, just like I think it's odd that ANSI 2003 904.3.1 includes the same language, when all they had to say was *36" MIN*


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## mark handler (Jun 18, 2012)

Acording to the ADASAD

Is this an alteration of an exising Building?

If yes, the minimum counter width is twenty-four inches.

If no, it is new construction the counter is thirty six inches

That's it. Stop thinking, that's not working for you. Stop thinking.


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## Jim B (Jun 19, 2012)

In talking about this exact situation with the ICC and their accessibility specialist, it was stated by the ICC that the accessible portion does not need to be 36” in width if the ambulatory counters are not 36” in width.

In other words, if the ambulatory windows are 24” in width, then the accessible portion can be 24” in width as well, but a parallel approach would be needed since no knee and toe clearance can be provided

I believe this meets the requirement if ANSI A117.1- 2003, 904.3.1. I am located in Pennsylvania and have used this same interpretation


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## rooster (Jun 19, 2012)

Jim B said:
			
		

> In talking about this exact situation with the ICC and their accessibility specialist, it was stated by the ICC that the accessible portion does not need to be 36” in width if the ambulatory counters are not 36” in width.In other words, if the ambulatory windows are 24” in width, then the accessible portion can be 24” in width as well, but a parallel approach would be needed since no knee and toe clearance can be provided
> 
> I believe this meets the requirement if ANSI A117.1- 2003, 904.3.1. I am located in Pennsylvania and have used this same interpretation


Thanks for the reply Jim B.  This is the interpretation I've been coming to.  More and more it seems to make sense that the windows could be similar in width and as much as I look for the sacrifice in accessibility, I don't see it.  It seems like the crucial elements would be the clear floor space and the height of the counter.  It's meant for transaction.

Sorry for beating the proverbial dead horse, Mark.  I can be like that some time.


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