# Tilted \ angled mirrors questions



## lpiburn

Hello all,

I have done some checking through the IBC, ANSI, and ADA and I cannot find any reference to the use of angled or tilt mirrors for compliance with accessibility in restrooms.  I have seen these "ADA mirrors" various times, and have even used them in some of my projects at the direction of other design professionals.

Here are several questions I came up with:

1. Is an angled mirror simply a failed attempt to meet the code?

2. Is it a product that was intended for some other purpose but re-labeled "ADA" once accessibility codes started being enforced?

3. Does it go above-and-beyond as long as it is also mounted appropriately?

4. When replacing a non-compliant flat mirror could it be considered an acceptable alternative to install a tilt mirror instead of lowering it?

I am interested to hear opinions on the matter, especially considering the posts in this forum about businesses being sued for 5-figures due to "minor" infractions such as mirror height.

-LP


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## Paul Sweet

As best as I can remember, accessibility standards always had the bottom of the mirror no higher than 40", and tilt mirrors were just a patch for replacing existing mirrors that couldn't be lowered to 40".


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## mark handler

Are the angled to tilt Mirrors mounted with the bottom edge of the reflecting surface
no higher than 40 in. above the finish floor ?  If yes, they comply.   If no, they do
not comply.


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## kilitact

I agree that as an alternate, these mirrors meet the intent of the accessibility standards


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## swerve

I am still seeing the tilted mirrors being installed by contractors, when asked why they are spending the extra money I'm told its what the company wants. I just let them know the code only requires the mirror to be 40" max from the floor.

Im going to have to dig out my old ansi a117.1 and see if it was in that code year ( the green one )


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## mark handler

swerve said:
			
		

> I am still seeing the tilted mirrors being installed by contractors, when asked why they are spending the extra money I'm told its what the company wants. I just let them know the code only requires the mirror to be 40" max from the floor.Im going to have to dig out my old ansi a117.1 and see if it was in that code year ( the green one )


Never in the code or standards


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## mtlogcabin

Under the building code/ANSI a tilted mirror mounted 44" AFF to the bottom of the mirror could be approved under "alternate materials and methods" because it would meet the intent of the code and allow a person in a wheelchair to use the mirror and actually see more of themselves under this application

Under ADA no exceptions yet I wonder what civil right is violated with an angle mounted mirror where the bottom is more than 40" AFF.

It would probably be a good change to have some kind of guidance on mounting heights and angle of degrees for a tilted mirror but it will probably be another 15 years before ADA is looked at again.


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## hannah leschinsky

mtlogcabin said:


> Under the building code/ANSI a tilted mirror mounted 44" AFF to the bottom of the mirror could be approved under "alternate materials and methods" because it would meet the intent of the code and allow a person in a wheelchair to use the mirror and actually see more of themselves under this application
> 
> Under ADA no exceptions yet I wonder what civil right is violated with an angle mounted mirror where the bottom is more than 40" AFF.
> 
> It would probably be a good change to have some kind of guidance on mounting heights and angle of degrees for a tilted mirror but it will probably be another 15 years before ADA is looked at again.



Hi Mtlogcabin!   I'm trying to find the code you're referencing for mounting a tilted mirror at 44" AFF.  do you have a site, reference, or a tip on how to find this info?  Thanks so much!!!!


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## tmurray

There is no code, which would be why it would be considered under the alternate materials and methods. You are meeting the intent of the code, but not actually following the code.


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## mtlogcabin

Today most building officials are not willing to make decisions based on the "intent" of the code. They are more interested in "CYA" then stepping out from the specific language of the code or standard and approving something else that will work. Non life safety issues should be easy decisions but most are not willing to go down that path.  A tilted mirror will cause a little distortion but does it result in a civil right violation if it is the only mirror in the room or every mirror in the room is tilted? No one is denied the use of a mirror that is not equal and available to some one else in the same room.   

ICC/ANSI A117.1 2009 edition

Chapter 1. Application and Administration

101 Purpose

The technical criteria in Chapters 3 through 9, Sections 1002, 1003 and 1006 and Chapter 11 of this standard make sites, facilities, buildings and elements accessible to and usable by people with such physical disabilities as the inability to walk, difficulty walking, reliance on walking aids, blindness and visual impairment, deafness and hearing impairment, incoordination, reaching and manipulation disabilities, lack of stamina, difficulty interpreting and reacting to sensory information, and extremes of physical size. The intent of these sections is to allow a person with a physical disability to independently get to, enter, and use a site, facility, building, or element.

Section 1004 of this standard provides criteria for Type B units. These criteria are intended to be consistent with the intent of the criteria of the U.S. Department of Housing and Urban Development (HUD) Fair Housing Accessibility Guidelines. The Type B units are intended to supplement, not replace, Accessible units or Type A units as specified in this standard.

Section 1005 of this standard provides criteria for minimal accessibility features for one and two family dwelling units and townhouses which are not covered by the U.S. Department of Housing and Urban Development (HUD) Fair Housing Accessibility Guidelines.

This standard is intended for adoption by government agencies and by organizations setting model codes to achieve uniformity in the technical design criteria in building codes and other regulations.

103 Compliance Alternatives

Nothing in this standard is intended to prevent the use of designs, products, or technologies as alternatives to those prescribed by this standard, provided they result in equivalent or greater accessibility and such equivalency is approved by the administrative authority adopting this standard


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## Francis Vineyard

The 2009 A117.1 provides a new exception that does not require the mirror to be located over the lavatory.

"As an exception to the accessible mirror being located over a lavatory or counter, a wall mirror would be an alternative due to the creation of a new exception. This new exception was created from both new and existing text. The added language makes sure the accessible mirror is in the bathing/grooming area. Though not specifically stated, it should be
assumed that the intent is that the mirror is located in the general room area and should not be located within a toilet compartment or other isolated location. The use of the exception is acceptable in public bathrooms but not within accessible dwelling or sleeping units.

The text in Section 1002 dealing with the mirrors in accessible units coordinates with the exception in Section 603.3 and would exclude the option of using a wall mirror instead of a mirror over the accessible lavatory. Notice that these sections do not require the installation of a mirror but that they simply regulate the mirror when it is installed above the
accessible lavatory. The intent is that within an accessible unit the required accessible toilet and bathing facility would have an accessible mirror if the mirror is mounted over a lavatory as is typical for dwelling units. Where there are multiple lavatories installed the standard would only regulate the mirror over the one required lavatory."

*603.3 Mirrors*. Where mirrors are located above lavatories, a mirror shall be located over the accessible lavatory and shall be mounted with the bottom edge of the reflecting surface 40 inches maximum above the floor. Where mirrors are located above counters that do not contain lavatories, the mirror shall be mounted with the bottom edge of the reflecting surface 40 inches maximum above the floor.

*EXCEPTION:* Other than within Accessible dwelling or sleeping units, mirrors are not required over the lavatories or counters if a mirror is located within the same toilet or bathing room and mounted with the bottom edge of the reflecting surface 35 inches maximum above the floor.


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## ADAguy

Interesting topic, consider that 40" is the approximate eye level height for those in
WC's and it will also accommodate those who are height challenged.

Consider also that if the mirror is tilted down towards you, it may allow for those
who are follically impaired to see the thinning hair on top of their head, which most
don't want to see (smiling).


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