# Grab Bar Overlap Exemption?



## DTBarch (Apr 5, 2021)

Question:

Does the grab bar below prohibitively encroach into the door's 18" maneuvering clearance?  There is a code snap (A4.24.2.5) that I found online that seems to exempt grab bar overlap for required clear floor space, but unsure of the code source.  The actual horizontal clearance between the end of the grab bar and the door swing is approx. 12 inches.  The door has a closer.  Plan reviewer has an issue with it.  Is this a discussion with "clear floor space" versus "maneuvering clearance"??


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## Yikes (Apr 5, 2021)

I don't know what A4.24.2.5 refers to.  I mainly deal with ADA Standards.  IN ADAS 404.2.4.3 you are allowed to have a door in a recess that is up to 8" deep, within the 18" strike side clearance.  Any recess or protrusion greater than 8" needs to stay 18" away form the pull/strike side.



Let's say your grab bar is 1.5" diameter, and it site 1.5" off the wall, total protrusion of 3" off of the face of the wall and door.
If you think of the protruding grab bar in your picture as the equivalent of creating a "recess" for the door strike clearance, then since 3" is less than the 8" maximum allowable recess, it is acceptable per ADAS.

That said, make sure you've provided the necessary 60" clear at the side of the toilet.  Your lavatory looks like it might be a little close (unless it is a dwelling unit bathroom).


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## DTBarch (Apr 5, 2021)

Yikes said:


> I don't know what A4.24.2.5 refers to.  I mainly deal with ADA Standards.  IN ADAS 404.2.4.3 you are allowed to have a door in a recess that is up to 8" deep, within the 18" strike side clearance.  Any recess or protrusion greater than 8" needs to stay 18" away form the pull/strike side.
> View attachment 7700
> 
> 
> ...


Thank you Yikes.  That was the argument we used on the initial response.  I'll push harder.  Yes, we've got the 60" for the wc covered.  Thanks again.


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## redeyedfly (Apr 5, 2021)

Yikes said:


> I don't know what A4.24.2.5 refers to.  I mainly deal with ADA Standards.  IN ADAS 404.2.4.3 you are allowed to have a door in a recess that is up to 8" deep, within the 18" strike side clearance.  Any recess or protrusion greater than 8" needs to stay 18" away form the pull/strike side.
> View attachment 7700
> 
> 
> ...


This is a common misinterpretation of this code section.  404.2.4.3 does not allow anything in the door maneuvering clearance.  It requires you to use a forward approach if you have a recess >8".   The pull side sketch is very misleading because nothing can be in that 18" anyway.  But you could have planned for a latch approach with a recess.  If that recess is >8" within 18" you need to redesign for a forward approach and STILL keep the 18" clear.  

To the OP: Nothing is ever allowed in a door maneuvering clearance, not even grab bars.  The code section you cited is from the 1992 ANSI (you should verify that is the current code with your local AHJ).  It is discussing clear floor space around plumbing fixtures.  Door maneuvering clearances are not the same thing as clear floor spaces.


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## Yikes (Apr 5, 2021)

redeyedfly said:


> This is a common misinterpretation of this code section.  404.2.4.3 does not allow anything in the door maneuvering clearance.  It requires you to use a forward approach if you have a recess >8".   The pull side sketch is very misleading because nothing can be in that 18" anyway.  But you could have planned for a latch approach with a recess.  If that recess is >8" within 18" you need to redesign for a forward approach and STILL keep the 18" clear.
> 
> To the OP: Nothing is ever allowed in a door maneuvering clearance, not even grab bars.  The code section you cited is from the 1992 ANSI (you should verify that is the current code with your local AHJ).  It is discussing clear floor space around plumbing fixtures.  Door maneuvering clearances are not the same thing as clear floor spaces.



See image below the current 2010 ADAS 404.2.4.3, along with the "Advisory" commentary from the Dept. of Justice.
"Maneuvering clearances for a forward approach shall be provided *when any obstruction within 18 inches* of the latch side of a door way projects more than 8 inches beyond the face of the door..."
Note the acknowledgement that obstructions can and do occur within 18 inches of the latch side of the door.

Note their phrasing in the advisory: "*A door can be recessed... because of casework and other fixed elements adjacent to the doorway*".
In other words, it's not just a wall that creates a recess condition at a door.  It's also casework or other fixed elements in front of the wall face.
In my opinion, a grab bar qualifies as "other fixed elements".

Note that if the code intent was really that "_nothing_ is _ever_ allowed in a door maneuvering clearance", then the following items commonly found there should not be allowed, because they protrude into the strike-side clearance adjacent to the face of the door:
- a hollow metal door frame
- baseboard or coved tile on the joint between the floor and wall, next to the door
- applied tile or FRP wainscot finish applied to the bathroom wall
- a light switch or doorbell on the wall next to the door
- tactile signage, required by ADAS 703.4.2 to be within 18" on the wall next to the door
- a low-level exit sign on the wall adjacent to an exit door.

Perhaps you are trying to say that when 404.2.3 allows an obstruction that is within 18" of the strike edge and is less than 8" beyond the face of the door, you would start the 60" perpendicular measurement from the face of the obstruction, rather than from face of door?  If that is so, then the O.P.s diagram still appears to comply.


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## redeyedfly (Apr 7, 2021)

Yikes said:


> See image below the current 2010 ADAS 404.2.4.3, along with the "Advisory" commentary from the Dept. of Justice.
> "Maneuvering clearances for a forward approach shall be provided *when any obstruction within 18 inches* of the latch side of a door way projects more than 8 inches beyond the face of the door..."
> Note the acknowledgement that obstructions can and do occur within 18 inches of the latch side of the door.
> 
> ...


I use ANSI A117.1 much more than ADA but the language is the same.  I have an opinion from ICC that disagrees with you.  Note that the figure still shows 18" clear on the pull side approach and the 8" obstruction outside of it.  My take is that the section is simply requiring a forward approach when you have a door in an alcove but you still need to meet the forward approach requirements.  
I do tend to be very conservative with accessibility considering the enormous risks of getting anything wrong.


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## Yikes (Apr 7, 2021)

redeyedfly said:


> I use ANSI A117.1 much more than ADA but the language is the same.  I have an opinion from ICC that disagrees with you.  Note that the figure still shows 18" clear on the pull side approach and the 8" obstruction outside of it.  My take is that the section is simply requiring a forward approach when you have a door in an alcove but you still need to meet the forward approach requirements.
> I do tend to be very conservative with accessibility considering the enormous risks of getting anything wrong.


1.  Are you at liberty to publish the opinion from the ICC?
2.  I note that the figure applies to obstructions greater than 8".  There is no figure showing obstructions less than 8".  So, I infer from the ADAS cited in my previous post that the existence of obstructions less than 8" is recognized and allowed.


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## redeyedfly (Apr 7, 2021)

Yikes said:


> 1.  Are you at liberty to publish the opinion from the ICC?
> 2.  I note that the figure applies to obstructions greater than 8".  There is no figure showing obstructions less than 8".  So, I infer from the ADAS cited in my previous post that the existence of obstructions less than 8" is recognized and allowed.


1.  I'm sure I could but it was at a former firm and I don't have it.  
2.  I have found several examples that agree on your interpretation for ADA.  After giving it a few days I am coming around to your position.  The ICC opinion is what I have used but they aren't infallible either.  It's just people like you and me who answer the questions coming in. Now I wish I still had the opinion to review (and follow up with the author with more questions).


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