# Mailboxes



## Jim B (Apr 29, 2014)

I am reviewing an apartment complex: R2 Occupancy classification

IBC 2012, Appendix E is adopted in my state

The design professional has the unit mailboxes as well as a common use outgoing USPS mailbox in a seperate structure that is open on two sides and under roof.

The structure is not occupied or habitable

IBC 2012, Appendix E105.4 states that where mailboxes are provided at an interior location at least 5% or not less than one of each type shall be accessible. There is no definition for “interior” in the IBC. Would a small shleter with two walls and a roof be interior?

Also stated in E105.4, in residential facilities where mailboxes are provided for each dwelling unit or sleeping unit, accessible mailboxes shall be provided for each unit required to be accessible. Does this statement exempt and R2 apartment building with Type A and Type B units and no Accessible units?

Thanks


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## cda (Apr 30, 2014)

It's occupied when people are in it

You have to have access to the building so should have the accessible boxes


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## ADAguy (Apr 30, 2014)

Have you reviewed FHA/HUD requirements too?


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## mark handler (Apr 30, 2014)

ADAguy said:
			
		

> Have you reviewed FHA/HUD requirements too?


 FHA/HUD requires accessible Mailboxes, does not define a number.

To be safe, provide a number equal to, or more than, the number of units.

Just like High - low DF, remember some disabled cannot bend over.


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## ADAguy (Apr 30, 2014)

Thank you for a voice of logic and reason but will it standup in court?

MG says "if it ain't prescriptively directed the defendent doesn't have to do it" (smiling)


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## mark handler (Apr 30, 2014)

ADAguy said:
			
		

> Thank you for a voice of logic and reason but will it standup in court? MG says "if it ain't prescriptively directed the defendent doesn't have to do it" (smiling)


It is an amenity and MUST be accessible. The question is Quantity.


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## ADAguy (May 1, 2014)

Isn't USPS under their own access regs?

If not specifically addressed by ADA the property owner still must provide a box for each apartment, if so, then it is a component of the site and must comply with reach ranges, no?

Boxes therefore assigned to each unit with each type of unit's box having to be accessible for its tenant. Makes sense, no?


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## mark handler (May 1, 2014)

Postal Service is subject to the Architectural Barriers Act (ABA), rather than the ADA.


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## Rick18071 (May 1, 2014)

Mailboxes need to be accessible for type A and B units:

2009 IBC 1100.2 ACCESSIBLE. A site, building, facility or portion thereof that complies with this chapter.

Type A & B units comply with chapter 11 therefore they are accessible units.


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## Pcinspector1 (May 2, 2014)

Mark thanks for the information I was unaware that the USPS had to meet a different requirement other than ADA.

pc1


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## ADAguy (May 2, 2014)

So much to remember, so little time (smiling)


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## mark handler (May 2, 2014)

Pcinspector1 said:
			
		

> Mark thanks for the information I was unaware that the USPS had to meet a different requirement other than ADA.pc1


Side note:

All the codes and standards require access. If you use ADASAD, you are fine....


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## Jean Tessmer-HI (May 8, 2021)

usps says at least one mailbox is required to be at 48" AFF.   Mail cluster boxes are considered federal property and therefor the USPS has total control over design placement and yes how many need to be in ADA compliance.    Most of the vendors of cluster boxes built to USPS specs have this information.


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## SH225 (May 9, 2021)

USPS STD 4C also has a _minimum_ height of 28” to the bottom of the lowest customer compartment to which they deliver, except parcel compartments. STD 4C allows parcel compartments to be as low as 15”.


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## Yikes (May 10, 2021)

Jean Tessmer-HI said:


> usps says at least one mailbox is required to be at 48" AFF.   Mail cluster boxes are considered federal property and therefor the USPS has total control over design placement and yes how many need to be in ADA compliance.    Most of the vendors of cluster boxes built to USPS specs have this information.


I respectfully disagree, in that I think USPS does not have "total control".  USPS has a minimum and maximum reach range for their postal workers, for (a) the mailboxes, (b) the parcel boxes, and (c) the keyhole that the postal worker uses to open the boxes.  The local postmaster also has some control over how the mailboxes get numbered to facilitate ease of mail delivery.  This is usually sequential, e.g. the mailboxes are numbered 101,102, 103, etc.

Within that reach range, you (the designer) have the additional control and responsibility to provide accessible mailboxes for the people that need them, including all designated mobility accessible units.  ADA for tenant mailboxes is especially important if you are dealing with public housing.
It gets tricky when your mailbox #s exactly match your dwelling unit numbers, and your ADA dwelling units are also dispersed throughout your facility, and the postmaster wants all delivery to be sequential.  You might end up with a mailbox that meets USPS delivery requirements, but is out of reach range for your mobility-impaired tenant.

The safest thing to do (but also the one which takes up the most space in plan) is to provide everything within ADA reach range.  That way, if a tenant becomes wheelchair-bound and requests a "reasonable accommodation" for mail delivery, you're already set up for accessibility.  To make all of it comply with both USPS and ADA, it's as follows:

Mailbox key for tenants between 28-48" AFF.
Outgoing mail slots between 28"-48" AFF.
Parcel locker bottom at min. 15" AFF.
Postal worker "arrow" key access between 36"-48" AFF.
This is what manufacturers typically describe as a "10 door high" unit:




The next best thing, if you must have mailboxes higher than 48" AFF, is to give your tenants a different mailbox name (mailing address) than their unit number.  Example: US mail addressed to unit #A, while that mailbox #A may actually be assigned to the tenant in unit #305. 

See also https://www.florencemailboxes.com/compliancy


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## SH225 (May 11, 2021)

If you do have boxes above 48 inches, the Fair Housing maximum height is 54 inches for a side reach and 48 inches for a forward reach, based on 1986 ANSI A117.1. That applies to mailboxes serving all units in a building with an elevator and all ground-floor units in a building without an elevator.


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## Yikes (May 11, 2021)

SH225 said:


> If you do have boxes above 48 inches, the Fair Housing maximum height is 54 inches for a side reach and 48 inches for a forward reach, based on 1986 ANSI A117.1. That applies to mailboxes serving all units in a building with an elevator and all ground-floor units in a building without an elevator.


Yes, the link I provided above includes a chart describing the potential applicable clearances - - see below.  If you are doing private housing, your mailboxes probably won't need to comply with ADA (except maybe if you have a mailbox for a leasing / management office).   So you just pick the most restrictive measurements from among all the regulations that might apply to your project.


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## Jean Tessmer-HI (Jun 9, 2021)

Hello yikes,
Thank you for your feedback.  My understanding of the federal accessibility laws is that the FHA/DOJ are not the enforcement agency for Federal properties or features.  The enforcement agency for USPS is the US Access Board done by way of Legislation.  Peg Blechman at the Access Board is in charge of the USPS and we have had this conversation since 2004.  The best thing to do for new and existing projects is put all the tenants living in FHA covered dwelling units and ADA covered dwelling units (includes vacation rentals see the joint statement DOJ/HUD) on the lower boxes.  Reserving a few extra low boxes in commercial facilities might work where you don't know who will need an accessible box.  These scenarios would need to be worked out directly with the USPS.  It is more difficult to shift the boxes around after the fact.  Make sure they do not exceed 54" (ADA requires a percentage to be at 48") to the top of the highest set of accessible cluster boxes and no lower than 15" to the bottom of the lowest cluster box interior surface.  Making all the boxes low can cause reverse discrimination for people with back problems or overweight to have to bend down.  The hi-lo drinking fountains are an example of how the access board resolved having a low and high range.  FHA does not have technical scoping in the 1991 guidelines for the number of accessible mail cluster boxes.  HUD has written a position memo to USPS but that is just a position memo not law.  USPS has their own accessibility manual called the RE-4 and USPS specifies exactly how cluster boxes shall be built.   USPS says at least one shall be at 48".  Make sure the drop slot for out going mail as mentioned above is at 47 inches aff.


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## Yikes (Jun 9, 2021)

Jean, I do a lot of projects in elevator buildings, which means 100% of the units are FHA covered dwellings, and therefore 100% of the mailboxes should be within the 15-48" reach range.  In the diagram shown in post #15, at least 20% of the mailboxes are at the 48" AFF height.


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## Jean Tessmer-HI (Jun 11, 2021)

Yikes,  
I appreciate the value of your knowledge and experience.  I was told there would end up being whole floors in a high rise dedicated to the very low reach range mailboxes if they all had to be accessible.  My understanding is that the 100% scoping is not stated anywhere in the actual legislated statute the 1991 Fair Housing Act Guidelines.  There have been memorandums between USPS and HUD but no actual congressional requirements for 100%.  USPS contended the heights were set for their carriers to safely access based on ergonomics.


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## Yikes (Jun 15, 2021)

Jean, as stated above, the issue is not that 100% of the mailboxes need to be accessible per FHA.  They don't.
The issue is the intersection of the postmaster wanting mailboxes to be sequentially numbered (for ease of delivering the mail), and the numbers match the dwelling unit #, plus the issue of ADA requiring dispersal of accessible units throughout the development, plus the (post-construction, non-code) issue of never knowing when a tenant in an FHA covered unit will request a "reasonable accommodation".  You may end up in a situation where an out-of-reach-mailbox gets assigned sequentially by USPS to an ADA mobility unit.

For a very large project, if you can't put all the mailboxes within reach range, the best space-saving workaround for this issue is either to: (1) give your tenants a different mailbox name (mailing address) than their unit number, and /or (2) provide just a few extra unassigned mailboxes within reach range.
Think of it as a kind of private PO Box #. 
Example: US mail addressed to unit #A, while that mailbox #A may actually be assigned to the tenant in unit #305.
That way, any tenant who is (or becomes) unable to reach a higher mailbox can be assigned one of the accessible mailbox #s instead.
But you may need to plan this with your local postmaster before implementation.


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## Jean Tessmer-HI (Jun 29, 2021)

Yikes! Brilliant Solution!  Thank you very much.
As far as dispersal per ADA the USPS Post Master says only one cluster box in the deepest location in a subdivision to their specs (plus we add the access route, USPS pad to accommodate maneuvering plus reach ranges, and ADA parking).


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## redeyedfly (Jul 8, 2021)

Yikes said:


> Jean, as stated above, the issue is not that 100% of the mailboxes need to be accessible per FHA.  They don't.


They do.  
HUD administers the FHA.  HUD decided that ALL mailboxes for covered units must be within reach range.  They still hold this as policy.  
I personally disagree with their opinion and believe it is actually LESS accessible because it assumes all people with mobility issues are in wheelchairs and ignores those who are unable to bend down to reach the low mailboxes.  But HUD does enforce this interpretation of the Federal Rules.  



			http://www.fairhousingnc.org/wp-content/uploads/2016/01/USPS-Infanger-5-20-08.pdf


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## Yikes (Jul 8, 2021)

Thank you for that correction.  What I meant to say is that "not all of the mailboxes need to be between 15"-48" per FHA."
FHA allows side approach clearances between 9-56".


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## redeyedfly (Jul 8, 2021)

Yikes said:


> Thank you for that correction.  What I meant to say is that "not all of the mailboxes need to be between 15"-48" per FHA."
> FHA allows side approach clearances between 9-56".


Depends which safe harbor you're using.  Most jurisdictions I am familiar with are using ANSI A117.1-2009 as the local accessibility code which has 48" max reach.


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## Yikes (Jul 8, 2021)

I'm in California.  Our state jurisdiction does not directly incorporate ANSI A117.1.

We use CBC 11A for private housing which is based on FHA, but is more stringent in several aspects.
FHA side reach range is 9"-56",  but Calif. 11A (fig 11A-1J) side reach range is 15"-48" like ADA.

For public housing, we use CBC 11B which is based on ADA.


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