What is ADA Compliance?
The Americans with Disabilities Act (ADA) is a landmark civil rights law that was enacted in July 1990. The ADA is comprehensive legislation that, in part, prohibits discrimination based on disability in the workplace, in commercial facilities, and in many state and local government services. The ADA integrates accessibility and usability into the design of both public and private buildings. The ADA Guidelines address those elements in the built environment that must be accessible to, and usable by, individuals with disabilities. The ADA standards are formulated by the U.S . Access Board. Even though the ADA regulations do not require compliance with the ADA standards, unless expressly applicable under state or local law, the courts may reference the ADA standards in determining if a facility has been constructed or altered in compliance with building codes in accordance with the ADA. The ADA compliance standards were incorporated in some fire and building codes and have been used as the basis for litigation surrounding buildings not in compliance with the ADA. Such standards are specific to the particular building code adopted by the jurisdiction.
An Overview of ADA Sink Requirements
When designing an ADA-compliant space, the sink is one of the key components that must meet certain standards. Accessibility to and approachability of a sink are critical in assuring ease of use for individuals with disabilities. The current regulations require the following:
Knee and Toe Clearance
Knee and toe clearance is required under vanities and lavatories to provide clear floor space for approach. The 2004 ADAAG and ABAAS standards specify a minimum knee clearance height of 27 inches. The exception for a toilet is discussed below.
Clear Floor Space
The 2004 ADAAG and ABAAS standards require all sinks to have clear floor space of at least 30 x 48 inches in front for wheelchair Approachability and Turnability. A side approach is permitted only if:
The lavatory has a rim or counter height no higher than 34 inches; and
One of the following is provided:
knee clearance, 29 inches high minimum, 27 inches high allowable, 13 inches deep minimum, 23 inches maximum; or
knee and toe clearance (i.e., no pedestal, cabinet, etc. under the sink).
Fixed or Built-In Lavatories
All plumbing elements must fit within the sink cabinet. In a barrier-free environment, no piping may be exposed under the lavatory, such as metal, plastic, etc. That would block or interfere with front or side approachability. A removable protective covering may be affixed to exposed piping, provided it is not permanently attached, so that it does not impede required clearances.
Minimum Required Sink Clearance
The required clear floor space for knee and toe clearance varies depending upon the sink:
Prep Sink: 48" W x 30" D 30" H; 12" knee clearance; 9" toe clearance
Single Bowl Sink: 30" W x 30" D 30" H; 12" knee clearance; 9" toe clearance
Double Bowl Sink: 48" W x 30" D 30" H; 12" knee clearance; 9" toe clearance
Dishwasher / Shower Sink: 36" W x 36" D; 12" knee clearance; 9" toe clearance
Roomy Single Bowl Sink: 36" W x 30" D 30" H; 12" knee clearance; 9" toe clearance
Common area sink: 48" W x 30" D; 36" H; 12" knee clearance; 9" toe clearance
The clear floor space should allow a forward approach to a fixture from a wheel chair and allow a parallel approach for the toilet and sinks. Counter tops must be between 28" and 34" high with clearances under and around the sink. The clearance under the sink must be a minimum of 11" high and 8" deep. For front approach, the sink should be at 28" to 34" high, and the clearance under and around the sink must be a minimum of 27" high and 11" deep.
Best Practices for Installing ADA Compliant Sinks
An important aspect of ensuring that an ADA-compliant sink is easily accessible to users is proper installation. It is vital that plumbing professionals follow best practices to ensure that all ADA-compliance requirements are met. It is also recommended that any individuals who are involved in the planning and installation of these sinks consult with experts in the field, including plumbers, architects, and ADA specialists. For sinks, this includes verifying clearances and other accessibility requirements. When installing a standard-lift or extended-lift sink with a 5-inch deep tub, make sure to leave a minimum knee clearance of 8 inches above the plumbing connections. The knee clearance is measured from the wall. If you need a counter surface that is less than 34 inches high, you will need to install a 3-legged support system for the sink to achieve the lower height. If you have permanent supports holding the sink, the knee clearance must still be at least 8 inches above them. If you cannot obtain the correct knee or toe clearance under the sink with the standard-lift sink, an extended-lift sink may be better suited for the intended space. Keep in mind that the deck must be a minimum of 21 inches from the center of the toilet to the inside edge of the counter. The top of the counter must be a minimum of 34 inches above the top of the toilet seat. Ensure that the center of the standard-lift or extended-lift sink is a minimum of 36 inches away from the toilet. If the clearance is less than 36 inches, the sink must be equipped with a foot-operated or hands-free mixing faucet. In addition, the sink must not be more than 20 inches deep. Height adjustments must be made before the sink is attached to the countertop so that the proper screw length is used when attaching the sink to the countertop. If the end of the sink’s screw when raised is a minimum of 44.5 inches, the screws must be furnished with a factory-installed cover attached with a tamper-resistant screw. This ensures that no unauthorized adjustments can be made to the sink once the installation is complete. If the screw is less than 44.5 inches from the bottom of the sink, then the mounting system can be adjusted after the sink is installed. To ensure that the proper screws are used for the installation, refer to the manufacturer’s instructions for the sink model. If you are using a standard-lift sink or an extended-lift sink in the fabricator shop, do not pour the countertop around each sink until the sink is installed. This will allow the plumbing professional to adjust the height of the sink. If you have a removable top deck for a dual or triple sink model, you can pour both top decks after the sinks are installed.
What to Avoid: Common ADA Sink Mistakes
One of the biggest errors made is misunderstanding what the ADA sink clearance requirements are and thinking they apply to a $50 faucet when they apply to the entire sink. As we’ve previously established, the range of what an ADA sink clearance can be is huge. It’s not finite or absolute and it must take into account a great many other factors beyond a $50 faucet. For example, how much space do you have? Is there a divider wall between the sink and next to it? How high is the counter? In fact, how far away is the sink from reach and pull range of a disabled person?
The bottom line is that you must evaluate and consider everything about the placement of the sink before you contemplate where the faucet and spout will be placed . The faucet must be reachable at all times and compliant in all ways to the ADA universal guidelines. The faucet needs to be able to be operated with only one hand in a natural, fluid motion that cuts down on the need to exert too much strength and pressure. The faucet must also offer controls that are easy to use or adjust to the user’s needs. Hot and cold controls should be distinct and located in the proper area and configuration. If any part of the faucet will have to be gripped or twisted more strongly by a person with physical disabilities, they should be equipped with lever type faucets so they can be operated easily with one hand.
Case Studies of Successful ADA Sink Installations
The real-world application of the ADA is where the requirements make the biggest difference. As technology has increased and the concept of universal design has matured, more and more manufacturers have developed ADA compliant products. A couple examples of successful ADA sink installations include: Shawnee Mountain Ski Area, located in the Pocono Mountains in Pennsylvania, redesigned many of their facilities for wheelchair accessibility. Not only did they provide ADA compliant restrooms, but they also provided fully accessible lavatory sinks. Many new resorts have followed suit, providing ADA compliant lavatory sinks and restrooms in both public and private facilities. Another example is from a private owner who completely remodeled his 1970s basement. He included a laundry room including a sink with a four inch high rim, compliant faucet handles and piping under the sink that allowed for easy clearance of a wheelchair underneath the sink. This was no small feat. He hired an architect, who researched the ADA requirements. Then, the architect drew plans with bids on the construction. Before hiring a contractor, the homeowner reviewed the bids and talked to his architect about the ADA sink requirements. The architect expressed concerns that the lower sink rim was an unnecessary expense, and that a standard height with a compliant faucet would suffice. The homeowner was convinced that the low sink rim was necessary for him, and not just an expense. The lower sink did cost more, and took more work, but the results are significant. The sink is comfortably low, but the pressure needed to use the spray nozzle is satisfactory for easy rinsing of dishes, and other tasks. An additional pressure reducer is installed in the wall to regulate the water pressure required to use the sink. Otherwise, the water pressure would be too strong and would cause splashing and would make it hard to use the spray nozzle. These are successful ADA installations. Both would have been relatively easy to include. ADA compliance costs less to install than to remodel later.
The Future of ADA Sink Design
Looking to the Future of Sink Compliance and the ADA Law
The ADA has gone through many iterations since its introduction in 1990. In much the same way, sink standards could change. The ADA and new technology (i.e., touch-free faucets) are always evolving and adapting. As technology marches on and we learn more about accessibility issues and how we can solve them, standards may change to keep up. Just as it may not be possible for a person on wheelchair to reach to the back of the sink, it may not be possible for a blind person to use a faucet that is not touchless. Furthermore, with every revolution in technology, there will be opportunities for improvement.
For example, an innovation of note is a paper towel dispenser that automatically dispenses paper towels into a waiting user’s hand when he or she reaches under it. The placement of such an automated device is regulated by the ADA174-175 as well as by state law. This piece of technology would be highly useful even to a user of a manual or powered wheelchair who is not necessarily low vision or blind. Where the person in a wheelchair may otherwise need assistance to place paper towels to dry his or her hands, the device would eliminate that burden and enhance independence. It is easy to envision that once the technology becomes universal and affordable, the location which would be in conflict with the clearance requirements of the ADA would likely change .
Though in its formative stage, perhaps the leading edge in compliance technology is embodied in a smart toothbrush holder designed by University of Guelph researchers to help blind children brush their teeth. Researchers used ultrasonic distance sensors to design the toothbrush holder to guide the blind children with audio feedback, and this feedback would be dependent on the actual position of the toothbrush. At this time, this prototype is not commercially available, but if it were to become widely available, one could easily envision how this could apply to sinks. For example, one could apply the same concept to guiding the blind with audio feedback to guide them to apply soap and to rinse using a specific pattern until all soap is removed. One could envision applying the same concept first without moving water, and then once the blind user understands the process, the user can then utilize it in practice. Perhaps this is the future of sink design.
There is also a certifying body in the United States called UL that provides product certification, and perhaps UL will begin providing certification for audio and other technological accessibility devices. By way of comparison, Wireless Power Consortium174 (WPC) certifies wireless power transmitters and receivers. As our nation’s population of elderly and disabled continue to grow and as our technology develops, a continuing refining of the ADA requirements will be necessary.