HIRSGH
GROUP, LLC
Tel: 603.233.7797
Fax: 603.231.3533
Cell: [phone]
Thonnas Hrnsoh, AIA
14 Nonth Allen Stneet
Madison, WI 53726-3924
e-mail: [email address]
19 January 2005
I believe the 2004 re-stated Design Guidelines (ADAAG) does not provide useable tub and shower valve locations, and there is a simple fix. The basic building blocks of forward and side reach ignore the true ergonomics of reach into corners. Should housing be covered by ADA (and it would be in service-oriented and publicly-owned facilities) this provision should be made to apply, too.
The basic logic goes like this:
First, using ADAAG's Appendix Figure A3(a) which shows the reach limits of a persons who uses a wheelchair I selected the upper illustration of a person who also has upper body flexibility, e.g., a person with paraplegia, who most likely would be bathing without assistance.
Second, I extracted the basic geometry of that illustration, and it is reproduced alongside; I refer to it as "the reach diagram." lt is useful as a supplement to the traditional side and forward reach diagrams in that it addresses what the reach potential is into comers; it is not the combined area of the ANSI & ADAAG side and forward reach diagrams. This suggests that Figures 607.2 & 608.2.1 do not result in reachable controls.
Third, overlaying the reach diagram onto a plan view of a bathtub or shower, it becomes clear that in order to reach a control mounted on the Centerline of the tub, the traditional mounting location, 9" must be provided beyond the foot of the fixture in order to reach the water control. In actual practice we have found that offsetting the control 9" from the approach side of the fixture then permits an accessible reach with only 5" beyond the
foot of the tub/shower.
The issue of toe space beyond the foot of the tub is not addressed in any national access design standard (Americans with Disabilities Act, ANSI 117, Fair Housing, etc.), but has been incorporated into the clear floor space requirements of Wisconsin building code for multi-family housing since 1992 (see attached excerpts) and, to my knowledge, have never been the subject of a petition for variance.
In addition,
* The beneficiaries extend beyond persons with disabilities: offsetting the controls makes it easier to reach when parents bathe children, or you simply want to adjust the water temperature before getting in. The features do not interfere with any one else's use of the fixtures
* The floor space needed (9" max. by 30" wide = 1.88 SF) is a modest cost, and depending on the layout and size desired may not require any added area per se. Most bathrooms are no longer the old 5' x7' standard which would unavoidably add area; our current norms of designs based on market demands are for larger bathrooms, often with multiple bathing facilities.
* lt is only one of two "Wisconsin-isms" retained in our recent adoption of the IBC; 6 others were dropped.
lf you have any questions on this material, you may contact me at 608-233-7797 or by e-mail [email address].
Sincerely yours,
Thomas Hirsch, AIA
WISCONSIN ADMINISTRATIVE CODE
closet shall [be a minimum of 18 inches from the obstacle. The side of the watercloset without a grab bar shall be a
minimum of 15 inches measured from the centerline of
the water closet to the finished surface of adjacent walls,
vanities or the edge of a lavatory.
Note See Appeodix for examples of clear floor space at water closets.
(c) Vanities and lavatories. When 2 or more lavatories
are provided in a bathroom, at least one lavatory shall be
made acoessible.
1. Vanities and lavatories shall be installed with the centerline of the lavatory a minimum of 15 inches, measured horizontally, from an adjoining wall or fixture.
2.The top of the fixbure rim shall be a maximum height of 34 inches above the finished floor.
3. A clear floor space at least 30 inches by 48 inches shall be provided at a lavatory for either a parallel or a front approach. If a front approach is used, full kneespace shall be provided below the lavatory at least 17 inches in depth. If kneespace is provided below the vanity, the bottom of the aprom shall be at least 27 inches above the floor.
Note: See Appendix for examples of clear floor space at lavatories.
(d) Bathtub and shower fixtures. When both bathtub and shower fixtures are provided in the bathroom, at least one fixture shall be made accessible.
1. 'Bathtubs.' a. Where the centerline of the controls is located not more than 9 inches from the apron of the bathtub, a clear floor pspace at least 30 inches by 48 inches shall extend at least 5 inches beyond the head of the bathtub as show in Figure 57.871.1.
Figure 57-871-1 Clear floor Space/Offset Controls
Figure 57.871.2 Clear Floor Space/Centered Controls
b. Where the centerline of the controls is located between 9 inches and 18 inches from the apron of the bathtub, a clear floor space at least 30 inches by 48 inches shall extend at least 9 inches beyond the head of the bathtub as shown in Figure 57.871-2.
2. 'Shower Stalls.' a. Shower stalls in a bathroom shall have an inside dimension at least 36 inches.
b. A minimum clear floor space 30 inches wide by 48 inches shall be provided outside the stall.
Note: See Appendix for an example of clear floor space.
c. If the shower stall is the only bathing facility provided in the covered dwelling unit or on the accessible level of a covered multilevel unit, the shower stall shall have reinforcing to allow for installation of a wall hung bench seat.
3. Powder Rooms. Where a powder room is the only toilet room provided on the grade-level floor of a multilevel dwelling unit, the powder room shall be designed and constructed in accordance with the applicable portions of sub. (2).
Note: See Appendix for examples of adaptable powder rooms.
(4) Single-Level Plumbing Controls. Single-lever plumbing controls or other controls which are provided by the department, may be requested by the renter for installation on plumbing fixtures used by the renter and shall be provided by the landlord at not additional cost to the renter.