# accessible kitchen ranges - top of range 34" AFF or ???



## syarn

84 unit HUD affordable housing apartment building; 22700 sf per floor; 3 floors with elevators; type IIB; NFPA13R;

5 of the apartments are ADA compliant.

ansi a117.1-2003 section 902.3 height

"...The tops of dining surfaces and work

surfaces shall be 28 inches (710 mm) minimum and

34 inches (865 mm) maximum in height above the

floor..."

does this apply to the kitchen range top (aka work surface)?

if it does where do you buy a freestanding drop in range at that has a range top at 34" aff?

why would GE & whirlpool market "ADA" freestanding ranges that have top of range around 36" to 37" aff?

or are you limited to doing "built-ins" for true handciapped accessibility at a range top?


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## Forest

Re: accessible kitchen ranges - top of range 34" AFF or ???

I think section 804 of the ICC/ANSI applies to Appliances chapter 9 is for built ins.


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## Coug Dad

Re: accessible kitchen ranges - top of range 34" AFF or ???

Are you the plan reviewer using the IBC / ANSI requirements of the design professional who must also follow Federal Fair Housing?


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## syarn

Re: accessible kitchen ranges - top of range 34" AFF or ???

not a plan reviewer; a r c h i t e c t

using the ANSI  requirements & Yes - complying with the federal fair housing guidelines as well.

ps-section 804.3 of ansi kicks you over to section 902....


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## Forest

Re: accessible kitchen ranges - top of range 34" AFF or ???

I do not believe that section 804.3 applies unless it is a built in range.Section 804.6 applies to kitchen appliances provided.


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## Gene Boecker

Re: accessible kitchen ranges - top of range 34" AFF or ???

HUD units require compliance with the UFAS as well as the other codes you need to use.  Speaking of which, is this under the Barrier Free Sub-code or is it outside New Jersey?

The UFAS and FHA provisions require at least one work surface that is 30 inches long to be at 34 inches in height.  It also requires the sink to be at 34 inches in height.  The range and cooktop can be at the traditional 36 inch height.

Regarding ANSI, it depends on whether these are Type A or Type B units and which code you have as the base code - IBC or heavily modified UCC.  Yes, 804.3 kicks you over to 902 - but should you be using 803 or shoudl you be in Chapter 10?  I'm betting on the latter.


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## Big Mac

Re: accessible kitchen ranges - top of range 34" AFF or ???

Work surfaces shall comply with Section 902.  !CC A117.1.  The only exception is for spaces that do not provide a cooktop OR a conventional range.  The language cooktop or conventional range is used in several locations.  Obviously a cooktop would most likely be a built in appliance.  A conventional range, not so much.


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## brudgers

Re: accessible kitchen ranges - top of range 34" AFF or ???



			
				syarn said:
			
		

> 84 unit HUD affordable housing apartment building; 22700 sf per floor; 3 floors with elevators; type IIB; NFPA13R;5 of the apartments are ADA compliant.
> 
> ansi a117.1-2003 section 902.3 height
> 
> "...The tops of dining surfaces and work
> 
> surfaces shall be 28 inches (710 mm) minimum and
> 
> 34 inches (865 mm) maximum in height above the
> 
> floor..."
> 
> does this apply to the kitchen range top (aka work surface)?
> 
> if it does where do you buy a freestanding drop in range at that has a range top at 34" aff?
> 
> why would GE & whirlpool market "ADA" freestanding ranges that have top of range around 36" to 37" aff?
> 
> or are you limited to doing "built-ins" for true handciapped accessibility at a range top?


What exactly do you mean by "ADA compliant?"

FHA does not require 34" high work surfaces...see page 7.2 in the Fair Housing Act Design Manual.

A117.1 (2003) does not require the range to be less than standard 36" height for type A units.


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## syarn

Re: accessible kitchen ranges - top of range 34" AFF or ???

UFAS

uniform federal accessibility standards

section 4.1.4 (11) (b)

Residential occupancy includes, among others, the use of a building or structure, or portion thereof, for sleeping accommodations when not classed as an institutional occupancy. Residential occupancies shall comply with the requirements of 4.1 and 4.34 except as follows:

Residential occupancies in multiple dwellings where the occupants are primarily permanent in nature, including:

(Apartment houses):

Federally assisted 5 percent of the total, or at least one unit, whichever is greater, in projects of 15 or more dwelling units, or as determined by the appropriate Federal agency following a local needs assessment conducted by local government bodies or states under applicable regulations.

[so 84 * .05 = 5 apartments have to comply with section 4.1 & 4.34 of UFAS]

4.34.6.4 WORK SURFACES. At least one 30 in (760 mm) section of counter shall provide a work surface that complies with the following requirements (see Fig. 50):

(1) The counter shall be mounted at a maximum height of 34 in (865 mm) above the floor, measured from the floor to the top of the counter surface, or shall be adjustable or replaceable as a unit to provide alternative heights of 28 in, 32 in, and 36 in (710 mm, 815 mm, and 915 mm), measured from the top of the counter surface.

chapter 7 of the guidelines page 7.3 introduction says

"...“Usable” kitchens, as specified in the Guidelines, are not necessarily “accessible” kitchens, but they do provide maneuvering space for a person who uses a wheelchair, scooter, or walker to approach and operate most appliances and fixtures..."

hmm...from rechecking this it now appears that only a 30" wide section of the counter has to be 34" aff with a forward approach minimum in the 5 "accessible" apartments....

the range however:

"...section 4.34.6.6 Ranges and cooktops shall comply with 4.34.6.2 and 4.34.6.3..."   clear floor space & controls....interesting


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## syarn

Re: accessible kitchen ranges - top of range 34" AFF or ???

yes IN NJ - barrier-free

yes NJ UCC


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## syarn

Re: accessible kitchen ranges - top of range 34" AFF or ???

chapter 10 of ansi a117.1-2003 also has a third classification of "accessible" in addition to type A & B...which kicks u back to sections 804 & 902....at least for 30" width of work surface....


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## mattbrob

The key to any stove in making it comply with ADA is not the height as much as it is the controls. Someone can not reach in the back to adjust heat ..therefore an ADA stove has ll the controls up front.The area in front of the stove is also key. That area known as clear space and the approach. Your more likely approaching from the side to maximize
reach and view.


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## mark handler

*Fair Housing- HUD allows for 36 inch high for forward approach. Does not address height in side approach installations.*



*https://www.huduser.gov/publications/pdf/fairhousing/fairfull.pdf*


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## mattbrob

Mark Handler your quotes are rude and unprofessional. Your link is fine if one chooses to abandon a conventional oven stove. With front approach you need to note the require 30 inch width at least.


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## mark handler

mattbrob said:


> Mark Handler your quotes are rude and unprofessional. Your link is fine if one chooses to abandon a conventional oven stove. With front approach you need to note the require 30 inch width at least.


And how did you determine that pronouncement?
By me copying  a picture from a government publication?
Sounds unprofessional to me.....


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## mark handler

mattbrob said:


> The key to any stove in making it comply with ADA is not the height as much as it is the controls. Someone can not reach in the back to adjust heat ..therefore an ADA stove has ll the controls up front.The area in front of the stove is also key. That area known as clear space and the approach. Your more likely approaching from the side to maximize
> reach and view.


He is not compiling with ADA. He does not want to comply with the ADA. ADA does not cover this type of dwellings.....


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## ADAguy

Be glad this is not in California where 34" would be required.
Note that ADA compliance is a subjective/performance determination as DOJ does not certify products. Read manufacturers spec sheets carefully as an ISA does not make it compliant.
If using a floor stove it must be approachable from both directions and with an oven consider how door opens.


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## Yikes

ADAguy said:


> Be glad this is not in California where 34" would be required.
> Note that ADA compliance is a subjective/performance determination as DOJ does not certify products. Read manufacturers spec sheets carefully as an ISA does not make it compliant.
> If using a floor stove it must be approachable from both directions and with an oven consider how door opens.



ADAguy - where in the California code does it say that cooktops must not exceed 34" high?  I don't see it in either 11A or 11B.


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## ADAguy

A stove top is a counter, is it not? As such it should not exceed 34", no?


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## mark handler

ADAguy said:


> A stove top is a counter, is it not? As such it should not exceed 34", no?


Not. Both 11A and 11 B address cooking surfaces.


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## ADAguy

Righto!


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## Yikes

The CBC treats a cooktop as an "appliance", not a counter or worksurface.  It is mainly concerned about controls and approach, and avoiding burns.

As such, the only time the height and depth of a cooktop surface would come into play is if you were trying to reach something behind the cooktop, in which case you treat the cooktop like an "obstruction" (11B-308.3.2), in addition to it being an "appliance" (11B-804.6).


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