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Sinks, Sinks, Sinks, and Lavs – What needs to be done?

Janis Kent, FAIA Architect, CASp ©  April, 2017; modified September, 2021

Sinks have many differing requirements depending upon how they are being used including types of approach, cabinetry below or not, and even the number required to be accessible. Following is a summary of different sink types and their uses that will hopefully shed some light, or not, on the issue and requirements for each. Please be aware that per ADAS 212.3, 5% with one minimum of sinks in accessible rooms are required to have a forward approach with knee/toe clearance below, but the exceptions under 606.2 can be used. There are some exceptions, one of which is for kitchens and kitchenettes, but you will need to use the dictionary definition for these room types since ADA has not defined them.

Kitchens within Mobility Residential Dwelling Units, and Social Service Center Mobility Sleeping Rooms

A kitchen with cooking elements, such as a range or cooktop, is required to have knee/toe clearance below the sink for front approach. Easily removable cabinetry is allowed to be placed below, if the floor and all sides are finished.

Kitchens in Common-Use Spaces, and Within Mobility Feature Student Housing at a Place of Education

A kitchen with cooking elements, such as a range or cooktop, is required to have knee/toe clearance below the sink for front approach with no cabinetry below for forward approach. In this case, all surfaces below are to be finished. In my opinion, placing doors on the sink box is a form of cabinetry, and therefor should not be provided.

Kitchens or Kitchenettes in Transient Lodging Mobility Feature Guest Rooms

If there is a cooktop or range then the sink is required to have a forward approach with no cabinetry below. If there is a cooking element which is not a cooktop or range (microwave or convection oven, etc) the sink can have a parallel approach. If there are no cooking elements at all, a forward approach might also be required depending upon interpretation. (see below –Employee Break Rooms Without Built-In Cooking Elements)

Employee and Other  Kitchenettes with Cooking Elements

In an employee or other common-use space kitchens, where there are cooking elements, but no range or cooktop, the sink is required to be accessible and a parallel approach is acceptable. This means cabinetry can be placed below the sink. There may be other types of cooking elements whether built-in or otherwise but this does not affect the sink requirements. A microwave or convection oven would be considered cooking elements.

Employee Break Rooms with No Cooking Elements

As previously stated, in an employee break room or other common-use space lounges with no cooktop or range, a parallel approach can be used if there are other types of cooking elements, whether built-in or otherwise. A coffee pot or small loose toaster oven is not considered a cooking element for these purposes. The question comes up as to whether a kitchen sink is a specific type of sink or whether it is any sink located within a kitchen or kitchenette. If there are no cooking elements, it is a grey area as to whether a front or parallel approach is required.

Related Article: Single User Toilet Rooms in California

Wet Bars

A wet bar is generally a small sink with running water and is used for mixing drinks and rinsing glasses. These are typically found in residential and in hotel guest rooms. A parallel approach is required for Access.

Medical-Care and Long-Term Care Facilities per CBC

All patient and resident sleeping room hand washing fixtures are to be accessible for front approach as well as all hand washing fixtures, lavatories, and sinks with the exception of scrub sinks. Scrub sinks are used during the septic preparation for surgery and generally activated  by knee-action, wrist or foot controls, or electronic sensors. An eye wash sink, while not specifically stated, could be considered a common-use element and is recommended to be accessible.

Mop Sinks

A mop sink is usually a floor mounted sink, although there are also free-standing varieties as well. These are typically used by janitorial staff and have no requirements for access.

Utility or Scullery Sinks per CBC

A utility or scullery sink is a large basin sink typically used for food service, workshops, and general industrial applications. They have from one to three basins and are used by employees with no requirements for access since they are employee only fixtures.

Lavatories

Lavatories are required to have knee-toe clearance below and to have one minimum accessible. This accessible fixture is not to be located in a toilet compartment in a multi-user restroom. CBC requires 10% of the lavatories in a room, with one minimum, to be accessible. Lavatories require a front approach with a 17” minimum depth knee-toe clearance below to a 27” minimum height AFF. The minimum knee clearance of 11” deep is allowed to be reduced from 9” AFF to 27” at the rate of 1” in depth for every 6” in height. CBC requires the minimum depth to be 17”, and 19″ maximum whereas ADA allows a range of 17″ to 25″. CBC also requires the front edge of the lavatory to provide 29” minimum AFF reducing down to 27” AFF at 8” back. A further requirement on lavatories per CBC – the fixture is to be centered 18” minimum from any adjacent side walls or partitions. In mobility feature residential dwelling units and within social service center mobility feature sleeping rooms, a lavatory can have cabinetry below, if it is easily removable and if the floor and all sides are finished.

Children’s Lavatories

Lavatories used by children have differing height requirements dependent upon the predominant age of the users. Ages 6-12 have a height of 31” minimum with 24” knee/toe clearance below whereas children younger than 6 years can have a parallel approach without knee/toe clearance. These height requirements are optional but if used, other fixtures in the same space should also meet the alternate age requirements.

In Summary

Be aware that there is also a requirement where sinks are located in an accessible room, then 5% of each type are to be accessible with one minimum. This would be true in school laboratories or other teaching venues as well. CBC has increased this number to be 10% for lavatories. If a sink has multi-bowls, the knee-toe space is required only under one bowl – be aware of not locating garbage disposals in the required knee/toe clearance. Height requirements are 27” minimum clear AFF except for lavatories per CBC, which require 29” at the front. There is a grey area, left for interpretation, for sink approach requirements at counters and work surfaces not located in a kitchen(ette) – whether it is meant as a kitchen-type of sink or whether it is a sink within a kitchen space. Note that kitchens and kitchenettes that have some form of built-in cooking elements, regardless of the approach to the sink, require 50% of the shelf space to be within reach range – if there is no built-in cooking elements then one of each type of storage is to be accessible and within reach range. Many scoping requirements for our sinks!

Be aware that your local City or County may have additional requirements that are more restrictive than the State or Federal requirements. Also, this article is an interpretation and opinion of the writer. It is meant as a summary – current original regulations should always be reviewed when making any decisions.

© Janis Kent, Architect, FAIA, CASp April, 2017; modified September, 2021