# Existing  Breakroom



## north star (Aug 17, 2016)

*% ~ % ~ %*


I am looking for "positive" input on an upcoming project.

We have an existing Break Room with 36.25" [ A.F.F. ] countertops.
Leadership wants to install a "new" sink, faucet  and an undercounter,
tankless water heater.

Sometimes, we attempt to comply with the `10 ADASAD.

What issues do ya'll foresee with this ?.........Code sections are
requested,  ...please !

Thanks !


*% ~ % ~ %*


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## mark handler (Aug 17, 2016)

Do you have turning radius?
Is the sink/faucet accessible?
Is there seating?
Don't have code sections where I am.


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## steveray (Aug 17, 2016)

Accessible upgrades not required for strictly mechanical work....3409.6 2003 IBC or 3410 something maybe in newer....Or you could tell them to do the right thing and make it right now...Or give me the address and I could get a lawsuit going...


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## Pcinspector1 (Aug 17, 2016)

NS, Sounds like it fits into maintenance, if the sink has seen it's better days and has to be replaced it would not mean the cabinets need to be replaced, IMO. Side approach to the sink should already be existing?

If replacing the faucet, an attempt to provide an ADA compliant faucet should be a priority. There times I'd like to use those big winged faucet handles with my elbows.

I do not believe you have to redesign the break room for what your describing.

pc1


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## north star (Aug 17, 2016)

*= & = & =*


Thanks all for the input !

PC,

No sink in the "existing" Break Room........They want
to add one with heated water..........Current countertop
is 36.25" A.F.F.........The current, "existing" countertop
is approx. 9 ft. long.


Mark,

They have (1x) moveable Break Room table with (6x)
moveable chairs..........I suppose someone could maneuver
around to the countertop.

My main questions have to do with the "existing" countertop
height, ...adjustability of the heated water to the "new" faucet,
and the type of faucet to install  [  *RE:* One single handle, or
two paddle type handles  ] ?


*= & = & =*


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## mark handler (Aug 17, 2016)

2010 ADASAD
Employee common use areas in covered facilities (e.g., locker rooms, break rooms, cafeterias, toilet rooms, corridors to exits, and other common use spaces) were required to be accessible under the 1991 Standards

106.5 Defined Terms. Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.

212 Kitchens, Kitchenettes, and Sinks
212.1 General. Where provided, kitchens, kitchenettes, and sinks shall comply with 212.
212.2 Kitchens and Kitchenettes. Kitchens and kitchenettes shall comply with 804.
606.2 Clear Floor Space. A clear floor space complying with 305, positioned for a forward approach, and knee and toe clearance complying with 306 shall be provided
1. A parallel approach complying with 305 shall be permitted to a kitchen sink in a space where a cook top or conventional range is not provided and to wet bars.
606.3 Height. Lavatories and sinks shall be installed with the front of the higher of the rim or counter surface 34 inches (865 mm) maximum above the finish floor or ground.

804.3 Kitchen Work Surface. In residential dwelling units required to comply with 809, at least one 30 inches wide minimum section of counter shall provide a kitchen work surface that complies with 804.3.

804.3.1 Clear Floor or Ground Space. A clear floor space complying with 305 positioned for a forward approach shall be provided. The clear floor or ground space shall be centered on the kitchen work surface and shall provide knee and toe clearance complying with 306.

EXCEPTION: Cabinetry shall be permitted under the kitchen work surface provided that all of the following conditions are met:

(a) the cabinetry can be removed without removal or replacement of the kitchen work surface;

(b) the finish floor extends under the cabinetry; and

(c) the walls behind and surrounding the cabinetry are finished.

804.3.2 Height. The kitchen work surface shall be 34 inches (865 mm) maximum above the finish floor or ground.

EXCEPTION: A counter that is adjustable to provide a kitchen work surface at variable heights, 29 inches minimum and 36 inches maximum, shall be permitted.

804.3.3 Exposed Surfaces. There shall be no sharp or abrasive surfaces under the work surface counters.

804.4 Sinks. Sinks shall comply with 606.

804.5 Storage. At least 50 percent of shelf space in storage facilities shall comply with 811.

804.6 Appliances. Where provided, kitchen appliances shall comply with 804.6.

804.6.1 Clear Floor or Ground Space. A clear floor or ground space complying with 305 shall be provided at each kitchen appliance. Clear floor or ground spaces shall be permitted to overlap.

804.6.2 Operable Parts. All appliance controls shall comply with 309.

EXCEPTIONS:

1. Appliance doors and door latching devices shall not be required to comply with 309.4.

2. Bottom-hinged appliance doors, when in the open position, shall not be required to comply with 309.3.

804.6.3 Dishwasher. Clear floor or ground space shall be positioned adjacent to the dishwasher door. The dishwasher door, in the open position, shall not obstruct the clear floor or ground space for the dishwasher or the sink.

804.6.4 Range or Cooktop. Where a forward approach is provided, the clear floor or ground space shall provide knee and toe clearance complying with 306. Where knee and toe space is provided, the underside of the range or cooktop shall be insulated or otherwise configured to prevent burns, abrasions, or electrical shock. The location of controls shall not require reaching across burners.

804.6.5 Oven. Ovens shall comply with 804.6.5.

804.6.5.1 Side-Hinged Door Ovens. Side-hinged door ovens shall have the work surface required by 804.3 positioned adjacent to the latch side of the oven door.

804.6.5.2 Bottom-Hinged Door Ovens. Bottom-hinged door ovens shall have the work surface required by 804.3 positioned adjacent to one side of the door.

804.6.5.3 Controls. Ovens shall have controls on front panels.

804.6.6 Refrigerator/Freezer. Combination refrigerators and freezers shall have at least 50 percent of the freezer space 54 inches maximum above the finish floor or ground. The clear floor or ground space shall be positioned for a parallel approach to the space dedicated to a refrigerator/freezer with the centerline of the clear floor or ground space offset 24 inches maximum from the centerline of the dedicated space.


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## steveray (Aug 18, 2016)

Adding a new sink where only one will be provided will drive accessibility at said sink IMO....Lower the counter...(Initially I thought replacement for some reason)

3409.5 Alterations. A building, facility or element that is altered shall comply with the applicable provisions in Chapter 11 and ICC A 117.1, unless technically infeasible. Where compliance with this section is technically infeasible, the alteration shall provide access to the maximum extent technically feasible.

3403.1 Existing buildings and structures. Additions or alterations to any building or structure shall conform with the requirements of the code for new construction. Additions or alterations shall not be made to an existing building or structure which will cause the existing building or structure to be in violation of any provisions of this code.


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## north star (Aug 18, 2016)

*+ & +*


Much thanks to you all for your input !
You have confirmed what I initially believed.
The Code sections [  may  ] assist in discouraging
implementing this project.......Leadership here
needs some more ammunition to "just say No,
...you cannot have this Break Room sink !"

Installing the potable water & drain lines to
this location would be reason enough to cancel
the project in itself. 


*+ & +*


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## Pcinspector1 (Aug 18, 2016)

I made the ultimate sacrifice, I gave up my cushy office with storage for the new break room so we could get to the DWV, waterlines and electrical. It did not make since to jack hammer the floor for drain lines on one of the proposed options when I could give up a little sq ft for the betterment of the staff. Later I overheard the City Clerk tell a Board of Alderman it was all her Idea.  Go figure!

"My bathroom toys when I was young, were a toaster and a radio"! 
_Rodney Dangerfield_

pc1


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## north star (Aug 18, 2016)

*~ & ~ & ~*


One of Murphy's Unchangeable Laws is,
"  ...No good deed goes unpunished !"   

Thanks to you all again !

*& ~ & ~ &*


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## north star (Feb 10, 2017)

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...continuing on with this thread, only now I have a different
scenario:

*NEW SCENARIO:*  I have an existing facility that wants to update
some elements throughout........One of the elements planned
is to replace is an existing Breakroom Sink.......Not sure of the
current countertop height, but I am relatively sure that it does
not meet the maximum height of 34" A.F.F.

*QUESTION # 1:*  If they simply want to replace the Breakroom Sink,
does the `10 A.D.A.S.A.D  *"require"* the countertops to be
lowered ?......I have not yet seen the type of Sink that will be
installed, ...don't know if it is an ADA compliant type or something
else........There IS sufficient Side Approach area at the countertops,
just wondering about the height and the replacement of the Sink.

*QUESTION # 2: * Does this fall under a "Technically Infeasible"
application ?

If possible, please provide applicable Code Sections.

Thanks !


*# ~ #*


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## Francis Vineyard (Feb 10, 2017)

"If alterations are limited only to elements in a room or space, then the standards apply only to the elements altered."  For example if knob type faucets are being replace the replacement shall have a lever type handle or auto (sensor) type.

If the countertop is being repaired or replaced then no, but if the counter is being reconstructed or replaced then it shall meet the code for new construction.

https://www.access-board.gov/attachments/article/999/alterations.pdf

Technically infeasible is when a structural load bearing element interferes.


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## north star (Feb 10, 2017)

*# ~ #*


Thanks for the reply Francis !   

My project plans to replace the Breakroom Sink
& Faucet with new.......It is not indicated on the
project plans about the new millwork in the
Breakroom, nor the type of faucet.

I am gathering info to make a response back to
the RDP.


*# ~ #*


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## ADAguy (Feb 10, 2017)

For the life of me and not knowing where you are located, I cannot comprehend your agency wanting to duck their responsibility to remove existing barriers to access.
You provide a sink the countertop height is a significant feature to its accessibility.
We are not talking major dollars to comply.


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## north star (Feb 10, 2017)

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ADAguy,

I do not believe it is a matter of "ducking a responsibility"
in this particular case, but rather no one has brought these
topics up for discussion \ addressing by the currently adopted
standards, ...to the RDP........I happened to casually review
the project plans and saw some discrepancies.......I am
composing a "Reply Letter" outlining the issues that I saw.
I am just another set of eyes on this particular project.


*# ~ # ~ #*


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## mark handler (Feb 11, 2017)

Francis Vineyard said:


> Technically infeasible is when a structural load bearing element interferes.


*You are correct, BUT some consider "Site Restraints" as an excuse not to provide equal access to all.*
“Technically Infeasible.” The term is defined as “something that has little likelihood of being accomplished because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame; or because other existing physical or site constraints prohibit modification or addition of elements, spaces, or features that are in full and strict compliance with the minimum requirements.”
https://www.access-board.gov/guidel...standards/chapter-2-alterations-and-additions


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## mark handler (Feb 11, 2017)

north star said:


> *# ~ #*
> Thanks for the reply Francis !
> My project plans to replace the Breakroom Sink & Faucet with new.......It is not indicated on the project plans about the new millwork in the
> Breakroom, nor the type of faucet.
> ...


*Anything "NEW" needs to comply, No Infeasibility.

Will the Sink allow for side/parallel access?
is the faucet accessible?
Is it within Reach ranges?*


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## north star (Feb 11, 2017)

*@ * @ * @*

Thanks for the reply Mark !........Your comments are part
of my "Response Letter"  back to the RDP.

*@ * @ * @*


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## Rick18071 (Feb 13, 2017)

The counter doesn't need to be lowered only the sink needs to be 34" max. high. So don't put the sink on the counter.


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## ADAguy (Feb 13, 2017)

Code says that counters may be no higher than 34" if they are the only surface.


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## JCraver (Feb 14, 2017)

ADAguy said:


> For the life of me and not knowing where you are located, I cannot comprehend your agency wanting to duck their responsibility to remove existing barriers to access.
> You provide a sink the countertop height is a significant feature to its accessibility.
> We are not talking major dollars to comply.




It might be major dollars though, no?  Replacing a sink like-for like is cheap - replacing the cabinets (or uninstalling cabinets/top, cutting them down, and re-installing) just to get a new sink is not so cheap.

I'm not arguing ADA or its benefits/downfalls here - just addressing the "major dollars" portion of the reply.


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## ADAguy (Feb 14, 2017)

By "Major" are you talking: (3) figures, (4) figures, (5) figures? vs annual revenues of your company?
You don't want to go there.


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## JCraver (Feb 14, 2017)

Well, we don't know how big the company is.  Could be all the difference.  A tiny florist shop in a tiny town of 4000 is a lot different than a downtown florist shop in a town of 50,000, for example.

Good discussion.  And like I said, I'm not really arguing either way.  I just think it's important to remember that "major dollars" to one is completely different than the same for another.  I know business owners in my little town who wouldn't touch that sink because they literally could not afford the rest of the requirements to make it meet code.


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## ADAguy (Feb 14, 2017)

DOJ took ability to pay into consideration when drafting the ADASAD.
I'm sure you have some idea of estimated cost/permit value? LF of counter?


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## Pcinspector1 (Feb 14, 2017)

I was not aware that the sink had to be at 34", thought that a counter space had to be at 34". Recently in a business, the counter was at 36, then sink at 34, then back up to 36 then back to 34??? 

Just curious, where does the 34" height come from. Is it because all wheel chairs are built at the same height? At the Kansas City code hearings a flyer was passed out with proposed changes, one was going from the standard 60-inch access circle and changing it to 66-inches. And there were other requested changes. 

I sat next to a hearing impaired lady and she asked why the code hearings did't have signing or help aids for the impaired? I had no answer, with the help of one of our chapter members she was guided to the podium and she spoke in favor of the proposed changes. 

I talked to a friend of mine in a WC and he said the change was due to different types of chairs being used and the length creating facility use issues, getting out of the chairs in a stall was difficult. 

Sorry for the hijack, Northstar!


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## north star (Feb 14, 2017)

*@ ~ @ ~ @*



> "*" Sorry for the hijack, Northstar! "*


No problem ***PC***.......This is all good discussion.
Keep it going.........Hopefully, others will read & learn also !


*& = &*


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## ADAguy (Feb 15, 2017)

No disrespect PC but have you "visited" the Access Board website?
If not, please do and the veil maybe lifted.

The agency holding the discussion knows better. Kansas has a very strong access presence.

The National ADA Symposium is being held in your backyard in Chicago, you should visit it, it is a real eye opener for those who "really" want to grasp access and have access to Access Board presenters and other experts, It fills up fast.

It is 34" to the lip of the sink (if a drop in) or 34" to the counter.

And yes they have noticed that as people have enlarged, so to have WC's.


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