# California and Hi/Lo drinking fountain exception?



## JPohling (Feb 14, 2018)

There is an exception in the 2016 CBC for providing a hi/low drinking fountain.  11B-211.2 Exception states: Where a single drinking fountain complies with sections 11B-602.1 through 11B-602.9, it shall be permitted to be substituted for two separate drinking fountains.

So either they are covering their bases with this exception for if and when a device like this comes out..........or there is already one that I am not able to find?  Short of having one that is height adjustable by the user to allow the correct spout height for the chair user (36" maximum) and then the 38" minimum height for the standing person I cannot fathom how this is achieved?  Anyone see anything like this?

  CPC 415.2 Drinking fountain alternatives.  has a sentence that states.  "Bottle filling stations shall be permitted to be substituted for drinking fountains up to 50% of the requirements for drinking fountains"  

We typically try and do a single drinking fountain at accessible height equipped with a bottle filler and are constantly shot down.  

What do you guys think?


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## JPohling (Feb 15, 2018)

No thoughts?  Handler?  ADA guy?


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## rgrace (Feb 15, 2018)




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## rgrace (Feb 15, 2018)

This one also provides the puppy dog with their own fountain


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## JPohling (Feb 15, 2018)

hi/low is easy.  trying to avoid that with a bottle filler


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## Rick18071 (Feb 15, 2018)

JPohling said:


> CPC 415.2 Drinking fountain alternatives. has a sentence that states. "Bottle filling stations shall be permitted to be substituted for drinking fountains up to 50% of the requirements for drinking fountains"
> 
> We typically try and do a single drinking fountain at accessible height equipped with a bottle filler and are constantly shot down.



If only one high/ low is required and then having a bottle filler instead you would be substituting the drinking fountain 100%.


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## rgrace (Feb 15, 2018)

Probably not going to happen. Gotta start with the minimum, one hi, one low, then you can move on to the substitutions. Not sure what the CBC says, but the IBC (1109.5) says you gotta start with one hi and one low (no fewer than two drinking fountains shall be provided, or a single hi/low fountain).


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## JPohling (Feb 15, 2018)

Drinking fountain of any variety is not required,  occupant load less than 30.  We could install only a bottle filler and that would be fine.  Owner would like to provide a drinking fountain option as well and that is where we are at.  looks like no other option so do away with the fountain


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## ADAguy (Feb 15, 2018)

Bottle fillers are not accessible, require fingers to hold bottle. Check for reach range compliance when used in conjunction with a hi-lo.


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## JPohling (Feb 15, 2018)

no requirements on the bottle fillers only reach range


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## Yikes (Feb 19, 2018)

Once you decide to do a drinking fountain under ADA, you better have one high and one low (whether or not they are in a single device).  To make either a person in a wheelchair or a person who can't bend over be compelled to carry a water bottle is NOT equivalent facilitation IMO.

An exception of sorts: in California, where drinking fountains located within common use areas of private multifamily housing (CBC1139A), there is no mention of both a high and a low requirement.

If you don't have room for both high and low, try to find a way around requiring any drinking fountains.  An example is a food service facility, where the plumbing code may grant an exception and you provide drinking cups.


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## Rick18071 (Feb 20, 2018)

Looking for a requirement for that high and low drinking fountains need to be near each other? I am looking at a very large S1 building were they are putting the high and low abut 800' apart.


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## ADAguy (Feb 20, 2018)

No way Rick, not equal.
As to bottle fillers, how would they meet controls requirements if bottle must be held to fill?


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## mark handler (Feb 20, 2018)

Texas accessibility standards (tas)
People with disabilities shall not be required to travel more than 250 feet from anywhere on a floor or level to reach an accessible drinking fountain if there are units provided within that distance.

Never seen it anywhere else


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## Rick18071 (Feb 20, 2018)

ADA guy, Why would not a high and a low drinking fountain in the same building 800' apart be equal? They are equally apart from each other. What IBC section do you refer to that they need to be next to each other? Beside these two there are also 8 high and 8 low drinking fountains that are next to each other through out this million sq ft one story building. The two drinking fountains that I am talking about are the only ones separated (by 800').


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## ADAguy (Feb 20, 2018)

Ah, clarification as to what is "big", thank you. Initially you did not mention that there were multiple DF's throughout the space, makes a difference.
What is the use of space, office, educational, warehouse, stadium? Seems odd if providing DF's not to make each Hi-lo but you may have your reasons. Are they all equal distance from each other?


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## Yikes (Feb 21, 2018)

rick18071, I've asked that question before, and I get different answers from different CASps, which leads me to think it's one of those subjective things, and you have to assess risk.  I know this is a code forum, but if the goal is also to not get sued under ADA, then picture a scenario: 
 - A shakedown activist in a wheelchair is in the middle of the building, and asks someone, "where is the drinking fountain?"
 - They answer: "400 feet to your right".
 - He wheels over there, finds only the high fountain, and a sign that says, "For the low fountain, go 800 feet to your left".

What is the likelihood he's going to call his lawyer?


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## ADAguy (Feb 21, 2018)

"very", why must they be so far apart?


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## Yikes (Feb 22, 2018)

ADAguy, I'm going to guess the answer to "why must they be so far apart?", because I've been there before:
It's an existing building, with existing drinking fountain alcoves that are just big enough for either a high, or a low, but not both together.  enlarging the alcove will destroy something important on the other side (typically a restroom) or will have a domino effect on other accessibility clearances.


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## Rick18071 (Feb 23, 2018)

No, it's a new million sq ft  S1 building with about thousand miles of conveyors and 300 truck docks. I did not design it, I'm the inspector and notice there was only a low water fountain at one of the restrooms while the other restrooms that have both high and low. The building is not finished so I will be looking for the missing high water fountain before it's finished.


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## mark handler (Feb 23, 2018)

Rick18071 said:


> No, it's a new million sq ft  S1 building with about thousand miles of conveyors and 300 truck docks. I did not design it, I'm the inspector and notice there was only a low water fountain at one of the restrooms while the other restrooms that have both high and low. The building is not finished so I will be looking for the missing high water fountain before it's finished.


Place a sign at the non-conforming unit referring to the other locations and call it done


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## ADAguy (Feb 23, 2018)

MH, but he says it is a "new" bldg., as such the plans should have called for "all" DF's to be hi-lo, no?


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## Yikes (Feb 23, 2018)

Rick18071 said:


> No, it's a new million sq ft  S1 building with about thousand miles of conveyors and 300 truck docks. I did not design it, I'm the inspector and notice there was only a low water fountain at one of the restrooms while the other restrooms that have both high and low. The building is not finished so I will be looking for the missing high water fountain before it's finished.



In that case, it may be OK as-is.  Since 11B-212.2  only requires a minimum of 2 drinking fountains, and they have actually provided 3, then consider 11B-233.3 Exception:

11B-211.3 More than minimum number. Where more than the minimum number of drinking fountains specified in Section 11B-211.2 are provided, 50 percent of the total number of drinking fountains provided shall comply with Sections 11B-602.1 through 11B-602.6, 11B-602.8 and 11B-602.9, and 50 percent of the total number of drinking fountains provided shall comply with Sections 11B-602.7 and 11B-602.9.
*Exception: Where 50 percent of the drinking fountains yields a fraction, 50 percent shall be permitted to be rounded up or down provided that the total number of drinking fountains complying with Section 11B-211 equals 100 percent of drinking fountains.*


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## ADAguy (Feb 23, 2018)

Ok, there may be code minimums but how many employees where there be?


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## mark handler (Feb 23, 2018)

ADAguy said:


> Ok, there may be code minimums but how many employees where there be?


CA code does not dictate that
Put a sign on it and leave it....
TOO many other things to dwell on.


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## JPohling (Feb 26, 2019)

Back to this issue again as it is always coming up.  
ADA guy to answer your question above a bottle filler does not require holding to fill.  It is set on the fountain and it is filled by a sensor.

Also take a look at this document from SF and let me know your thoughts.


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## ADAguy (Feb 26, 2019)

Would like to but can't seem to open it?


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## JPohling (Feb 26, 2019)

double click then open with adobe?  works for me


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## Tim Mailloux (Feb 27, 2019)

JPohling said:


> 11B-211.2 Exception states: Where a single drinking fountain complies with sections 11B-602.1 through 11B-602.9, it shall be permitted to be substituted for two separate drinking fountains.



This single fixture complying with these requirements usually refers to a combination hi-lo fixture instead is two individual fixtures. And until you meet the minimum of (1) hi and (1) low you cannot substitute fixtures. The IPC commentary is pretty clear on this.


*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.

*Code Commentary*

_This section establishes a reasonable threshold for the required number of accessible drinking fountains. It should be noted that this section does not require the installation of drinking fountains where none are required or provided. Chapter 29 (which is duplicated from Section 403 of the IPC) contains criteria indicating the number of drinking fountains that are required based on occupancy. There are spaces that are not required to have drinking fountains. Examples are spaces with fewer than 15 occupants and spaces that serve water, like a restaurant. Current requirements for plumbing fixtures (see Table 2902 and Table 403 of the IPC) stipulate only one drinking fountain per number of occupants for many facilities or tenant spaces. Through Note e, the provisions in Section 1109.5.1 and Section 410.2 of the IPC stipulate a minimum of two drinking fountains for these facilities and spaces in order to meet the high/low criteria. Additionally, the plumbing requirements would allow for 50 percent of the drinking fountains to be substituted with bottled water coolers (see Section 410.3 of the IPC). While the provisions in Sections 1109.5.1 and 1109.5.2 and Section 410.2 of the IPC would not prohibit the substitution, the requirement for two drinking fountains would effectively negate this substitution unless there were at least three drinking fountains required for a floor. _


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## JPohling (Feb 28, 2019)

Approved with a single DF with bottle filler.  DF installed at accessible height with adjacent cup holder.  Lots of jurisdictions will allow this.


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## Tim Mailloux (Feb 28, 2019)

JPohling said:


> Approved with a single DF with bottle filler.  DF installed at accessible height with adjacent cup holder.  Lots of jurisdictions will allow this.



Which accessible height is it mounted at? ADA / ANSI specify two accessible mounting heights ranges. one height range for persons in wheel chairs and another height range for standing persons.....both are required by the accessibility code and both heights are accessible for different user groups.


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## JPohling (Feb 28, 2019)

Accessible height for rollers,  let me also clarify this is for an occupant load less than 30 determined by the CPC so a DF is not required at all.


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