# Accessible cabinet door/drawer pulls - multifamily residential



## Taylor (Sep 11, 2019)

Are accessible cabinet door/drawer pulls required at "adaptable" units (ground floor units per CBC 1104A.1)? The contractor is wanting to use cabinet doors that have a perimeter finger pull as part of the door rather than our specified wire pulls.

Also, where in the california building code does it state the requirement for accessible cabinet pulls? I want to have a reference to give the contractor for our reasoning.


----------



## ADAguy (Sep 11, 2019)

CPC 1127A.11.4 & 1138A.4


----------



## Taylor (Sep 11, 2019)

ADAguy said:


> CPC 1127A.11.4 & 1138A.4


Thanks for the reply! I thought 1127A is only for common use facilities (like the community building) but I don't see how it applies to the dwelling units themselves...


----------



## ADAguy (Sep 11, 2019)

Applies to storage, pantry cabinets are storage last I checked.


----------



## RLGA (Sep 11, 2019)

My response would be: Provide what is on the contract documents, which is what they should have bid on.

There is nothing that requires an architect to accept a substitution submitted by the contractor. If you accept a substitution, then as the architect you assume the liability as if you had originally specified it. If you do not accept a substitution but the owner requires you to accept it, then put it in writing (to the owner) that you will accept the substitution at the owner's request over your rejection and will not assume the liability should there be issues with the substitution later on. If the owner's insistence to accept a substitution is a violation of law (ADA, building code, or some other regulation), then flat out refuse to accept it for those reasons.


----------



## Taylor (Sep 11, 2019)

RLGA said:


> My response would be: Provide what is on the contract documents, which is what they should have bid on.
> 
> There is nothing that requires an architect to accept a substitution submitted by the contractor. If you accept a substitution, then as the architect you assume the liability as if you had originally specified it. If you do not accept a substitution but the owner requires you to accept it, then put it in writing (to the owner) that you will accept the substitution at the owner's request over your rejection and will not assume the liability should there be issues with the substitution later on. If the owner's insistence to accept a substitution is a violation of law (ADA, building code, or some other regulation), then flat out refuse to accept it for those reasons.


Thanks for the advice and in this case I do agree with you. However, I would like to know for future use as well because it is not clear to me where this requirement is actually stated in the code.  Section 1127 is for common use facilities (regarding the response from ADAguy) and I just want clarity on where this requirement is stated for the dwelling units specifically.


----------



## Yikes (Sep 16, 2019)

Taylor said:


> Thanks for the advice and in this case I do agree with you. However, I would like to know for future use as well because it is not clear to me where this requirement is actually stated in the code.  Section 1127 is for common use facilities (regarding the response from ADAguy) and I just want clarity on where this requirement is stated for the dwelling units specifically.



Taylor, you are correct that 1127A is under the heading "Common Use Facilities", and since the interior of a dwelling unit is not a "common use facility", 1127A does not apply to any 11A dwelling unit kitchen cabinetry, such as base cabinets, upper cabinets, or pantries.

To be specific, there 11A is silent on the subject of adaptable dwelling unit cabinet pulls, and therefore there is no requirement.

That said, at my own office, there are so many projects that are a mixture of privately- and publicly-funded units, it's just easier to design everything to 11B.


----------



## ADAguy (Sep 16, 2019)

See The Design guide illustrations for kitchens, they all show "U" pulls. Cabinet doors and drawers must be operable, "tutch" latches for doors and drawers are available but finger edges require "fingers" "u" pulls and :Tutches do not.


----------



## RLGA (Sep 16, 2019)

*touch


----------



## RLGA (Sep 16, 2019)

I have the finger edge doors and drawers in my home. I'm fully able-bodied but I hate them. IMHO, make everyone's life easier and put some kind of wire pull on the doors and drawers.


----------



## Yikes (Sep 16, 2019)

ADAguy said:


> See The Design guide illustrations for kitchens, they all show "U" pulls. Cabinet doors and drawers must be operable, "tutch" latches for doors and drawers are available but finger edges require "fingers" "u" pulls and :Tutches do not.



ADAguy, I don't know what "The Design Guide" is that you are referring to.  Is it in the code?
Posts #1 and #6 were asking specifically about the code requirements in 11A for pulls.  Please describe specifically which code section or which illustration in chapter 11A is showing or requiring U pulls.

RGLA, I can understand that it is a personal preference for these pulls.  But please also keep in mind that if there are switches or outlets on the back wall behind a standard 25" deep countertop, the "D" or "U" pulls can become an obstruction that makes the reach to these farther than the 25" allowed by 1136A.1 and 1136A.2.


----------



## ADAguy (Sep 17, 2019)

Taylor, are you the designer or is your project a design build? 
11A contains both prescriptive and performance requirements.
Cabinet and drawer pulls fall under 1102A.1 Building Accessibility, a performance requirement.
Edge finger pulls do not qualify as an alternate method in my opinion.
Taylor, is the project a fixed fee for the contractor; privately or publicly financed? 
Yikes, the Design Guide is the HUD-FHA Guide.


----------



## Yikes (Sep 17, 2019)

ADAguy, some follow-up questions/comments based on your post #12:
1.  Are you saying  that 11A is a performance code, and not just a prescriptive code?
2.  The FHA Design Manual shows many kitchen arrangements with components that are not otherwise addressed or called out in the manual.  For example, it shows backsplashes behind the countertops, but backsplashes are not an accessibility requirement.  It shows upper cabinets, but upper cabinets are not an accessibility requirement.  Page 7.13 of the FHA Manual shows a type of base cabinet doors with no handle.


----------



## ADAguy (Sep 18, 2019)

At issue is the term "if provided". The FHA Design Manual is both illustrative (examples) and prescriptive.
It remains for the architect/designer to consider what would be a more defensable position in the event of a suit; 
"I listened to a contractors request for an alternate to the approved plans" or my plans indicating greater accessibility then his request.


----------



## mark handler (Sep 20, 2019)

ADAguy said:


> ... indicating greater accessibility then his request.


Codes are a Minimum...


----------



## Yikes (Sep 20, 2019)

mark handler said:


> Codes are a Minimum...


Agreed.
It is worth noting that the original post was asking specifically about the code minimum requirements:
_"Also, where in the california building code does it state the requirement for accessible cabinet pulls?"_​
When our responses exceed the code, but we make it sound like it is based on the code minimum, then it becomes "unclear" to the original poster, as he noted in post #3 and again in #6:
_"However, I would like to know for future use as well because it is not clear to me where this requirement is actually stated in the code. Section 1127 is for common use facilities (regarding the response from ADAguy) and I just want clarity on where this requirement is stated for the dwelling units specifically."_​


----------



## ADAguy (Sep 22, 2019)

Grey areas, see attached:

file:///C:/Users/HP_SFF/Documents/CBC/Legal/Disability-Accessibility-Liability.pdf

Document in writing with a copy to owner & contractor that doing so (using finger pull edges, though not specifically addressed in 11a, is not your direction and that doing so by the contractor may result in a later complaint by a disabled renter)


----------



## mark handler (Sep 23, 2019)

ADAguy said:


> Grey areas, see attached:
> 
> file:///C:/Users/HP_SFF/Documents/CBC/Legal/Disability-Accessibility-Liability.pdf
> 
> Document in writing with a copy to owner & contractor that doing so (using finger pull edges, though not specifically addressed in 11a, is not your direction and that doing so by the contractor may result in a later complaint by a disabled renter)


You are referencing something on your computer that we do not have access to.
We do mot have access to your C-drive

Is this the document you are referencing?
LEGAL RIGHTS OF PERSONS WITH DISABILITIES

https://oag.ca.gov/sites/all/files/agweb/pdfs/consumers/disabled_bookmarks.pdf?


NOTE: it is applicable in CA only.


----------



## ADAguy (Sep 23, 2019)

Thank you for this but what I was referring to was an AIA article on ADA liability for architects with regards to only doing code minimum. I will try and resend it.
The point I believe that both you and I continue to make is that code minimums don't always equal ADA/FHA general guidelines. The omission of reference to cabinet pulls in 11a is just such an example. Tying intent to an unstated code requirement in a court of law can be frustrating.


----------



## ADAguy (Sep 23, 2019)

www.theaiatrust.com/whitepapers/ada/     found it MH


----------



## Yikes (Sep 23, 2019)

ADAguy said:


> The point I believe that both you and I continue to make is that code minimums don't always equal ADA/FHA general guidelines. The omission of reference to cabinet pulls in 11a is just such an example. Tying intent to an unstated code requirement in a court of law can be frustrating.



There is no such thing as an unstated code requirement.  If it is unstated in a code, then it is not a code requirement.

I reviewed the AIA discussion of "gray areas" in your link above.  Thanks for providing this info.  The specific cases mentioned were dealing with clearly stated requirements in ADAS.
For example, in the Rolf Jensen case, Mandalay Bay clearly violated the stated provisions of 2004 ADAS 224.1.2, requiring 100% of hotel guest rooms to have all doors provide min. 32" clear passage.


----------



## ADAguy (Sep 23, 2019)

The point remains with regards to "access for all", if you chose to do only the minimum or as the owner directs, document it in writing.


----------

