# Sales and service counter height



## jar546 (Sep 1, 2013)

Today I went to an indoor shooting range that did not have an accessible entrance.  The counter was very high but had this sign:







Is this acceptable in place of a compliant counter?

21 years in its current location

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## mark handler (Sep 1, 2013)

A fold down counter for check/ credit card writing would help mitigate the high counter....

Side note

The kick down door stop is a violation of the 10" smooth clear door bottom

And

the carpet/mat is a violation, unless permanently attached to the floor


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## RJJ (Sep 1, 2013)

No the sign is nice but it is and would not be compliant in any situation.

Agree with Mark on the other issues.


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## fireguy (Sep 1, 2013)

What is that in the lower Right hand corner?


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## mark handler (Sep 2, 2013)

The word Handicap is no longer used, federally and in most states

The disabled do not want to ask for assistance, they want the same service available to the non disabled


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## RJJ (Sep 2, 2013)

must be something on Jeff's photo The sign is on the left or center.


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## Codegeek (Sep 3, 2013)

If the business has been there for 21 years and has done nothing that would require a building permit, when what would require them to provide compliance for accessibility?


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## jar546 (Sep 3, 2013)

The counter itself is not 21 years old............


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## Codegeek (Sep 3, 2013)

jar546 said:
			
		

> The counter itself is not 21 years old............


Then I'm with the others, needs to be accessible and posting the sign is not providing the same equivalent.


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## mark handler (Sep 3, 2013)

Codegeek said:
			
		

> If the business has been there for 21 years and has done nothing that would require a building permit, when what would require them to provide compliance for accessibility?


The building department would not have anything to require modifications, if nothing else is being done

But many times the business owners request information, sometimes after a complaint is filed


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## Pcinspector1 (Sep 3, 2013)

The counter could have fallen under Sec. 105.2 (13) "Work exempt from permit" and may have never crossed the inspectors desk?

pc1


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## steveray (Sep 3, 2013)

Pcinspector1 said:
			
		

> The counter could have fallen under Sec. 105.2 (13) "Work exempt from permit" and may have never crossed the inspectors desk? pc1


Correct.....but ADA would still govern....and....105.2 Work exempt from permit.

Exemptions from permit requirements of this code shall not be deemed to grant authorization for any work to be done in any manner in violation of the provisions of this code or any other laws or ordinances of this jurisdiction.

Mark....What is the violation for the mat?


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## mark handler (Sep 3, 2013)

steveray said:
			
		

> What is the violation for the mat?


*UNLESS THE MAT IS FIRMLY ATTACHED, IT IS A TRIP HAZARD*

Carpet or carpet tile shall be securely attached and shall have a firm cushion, pad, or backing or no cushion or pad. Carpet or carpet tile shall have a level loop, textured loop, level cut pile, or level cut/uncut pile texture. Pile height shall be 1/2 inch (13 mm) maximum. Exposed edges of carpet shall be fastened to floor surfaces and shall have trim on the entire length of the exposed edge. Carpet edge trim shall comply with 303.

Advisory: Carpets and permanently affixed mats can significantly increase the amount of force (roll resistance) needed to propel a wheelchair over a surface. The firmer the carpeting and backing, the lower the roll resistance. A pile thickness up to 1/2 inch (13 mm) (measured to the backing, cushion, or pad) is allowed, although a lower pile provides easier wheelchair maneuvering. If a backing, cushion or pad is used, it must be firm. Preferably, carpet pad should not be used because the soft padding increases roll resistance.


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## Pcinspector1 (Sep 3, 2013)

36.304 Removable Barriers? or 302.2 Carpet?

pc1


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## mark handler (Sep 3, 2013)

Pcinspector1 said:
			
		

> 36.304 Removable Barriers? or 302.2 Carpet? pc1


Does not matter it is a hazard.


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## Architect1281 (Sep 3, 2013)

The sign says to me "this sign is our interpretation of compliance" and the owner is going to say we don't get any clients here that need it so the sign is ok....It also says to my good friend Bobby D who fell out of his tree stand and crawled to the road a day and a half later with a broken back to then get rescued. He still hunt's shoots and with an ATV gets to his tree stand and uses a hoist, is still sucessful and has a sense of humor yet - cause when I asked him wht his email was cantfly@ provider responded that if he could have flown he would not be in a chair for the rest of his life. and by the way don't ask if you can assist him cause he will bite you. COMPLIANCE IS THE ALTERNATIVE.


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## mark handler (Sep 3, 2013)

A lawsuit is "THE ALTERNATIVE"


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## mjesse (Sep 3, 2013)

mark handler said:
			
		

> the carpet/mat is a violation, unless permanently attached to the floor


Really?

I see those everywhere around here (not implying that makes it legal)

Especially in the winter months, the snow and salt being tracked in to hard surface areas is a major slip hazard. Stores/malls/offices have multiple mats at the entries which are changed out several times a week by specialty mat companies here.


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## mark handler (Sep 3, 2013)

Really, A major slip hazard.

Must be securely attached to floor


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## Codegeek (Sep 3, 2013)

mjesse said:
			
		

> Really?I see those everywhere around here (not implying that makes it legal)
> 
> Especially in the winter months, the snow and salt being tracked in to hard surface areas is a major slip hazard. Stores/malls/offices have multiple mats at the entries which are changed out several times a week by specialty mat companies here.


According to both ADA and A117.1 in Section 302.2, carpet is to be securely attached.


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## mjesse (Sep 3, 2013)

mark handler said:
			
		

> Really, A major slip hazard.Must be securely attached to floor



View attachment 837


Hmm. I think I found a basis for some profitable lawsuits. These are quite literally everywhere in Chicagoland.http://www.cintas.com/FacilityServices/MatServices.aspx
View attachment 837


/monthly_2013_09/Mat-Services-Page.jpg.06a7df1a689d7250c1dda5cc4d21c1f1.jpg


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## mjesse (Sep 3, 2013)

Found this via Google

http://www.justice.gov/crt/foia/readingroom/frequent_requests/ada_tal/tal182.txt

So, maybe?

_If floor mats are not actually built-in as a part of a building or facility, they will not be subject to the provisions of the Guidelines ..._

_Even though the requirements of the Guidelines would not apply to the mats themselves, the Guidelines can provide_

_helpful guidance in ensuring that mats do not constitute __barriers.__- _ W. Lee Rawls,   Assistant Attorney General


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## mark handler (Sep 3, 2013)

mjesse said:
			
		

> Found this via Googlehttp://www.justice.gov/crt/foia/readingroom/frequent_requests/ada_tal/tal182.txt
> 
> So, maybe? _If floor mats are not actually built-in as a part of a building or facility, they will not be subject to the provisions of the Guidelines ..._
> 
> ...


A lot of Things have change since August 13, 1992.


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## mark handler (Sep 3, 2013)

Also notice the wiggle in the letter "If movable floor mats impede access for people with disabilities......"

Not covered under the original ADAAAG * BUT*


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## mjesse (Sep 3, 2013)

mark handler said:
			
		

> Also notice the wiggle in the letter "If movable floor mats impede access for people with disabilities......"Not covered under the original ADAAAG * BUT*


I've been searching with no clear _current_ answer on the mats. Sounds like it comes back around to someone's judgement again. Uh oh.


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## steveray (Sep 3, 2013)

I know we would have a lot more slip and falls than ADA complaints in this part of the world with mats (in winter).....damned if you do and damned if you don't....If the designers would just design appropriately.....


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## mjesse (Sep 3, 2013)

I've got this from 2003;

Department of Justice Bulletin #4

(excerpt)

Products or finishes applied to surfaces after installation are not covered by ADAAG. but may fall under the Department of Justice (DOJ) regulation governing the maintenance of accessible features. Moisture and debris contamination adversely affect the surface slip resistance of most installed finishes. While floor treatments are available that will increase the coefficient of friction of a walking surface, some products or furnishings, such as furniture wax overspray or loose throw rugs, may reduce slip resistance significantly. Others-- for example, *walkoff mats placed on lobby floors during rainy weather--do much to reduce the chance of slipping on a wet floor. Such mats are not considered carpets within the meaning of ADAAG 4.5.3.*


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## ADAguy (Sep 13, 2013)

Owners of business's have an ongoing requirement per the ADA to identify and correct existing barriers (no grandfathering) subject to expenditure of minimal cost. The owners cost would be minimal at best in the above photo.


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