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ADA Requirements for Kitchen Storage

Janis Kent, FAIA Architect, CASp © April, 2015; updated June, 2021

So what do we need to know about access for kitchen storage? Since we are talking about ADA it would pertain to kitchens that are new or altered in employee lounges/break rooms, and new or altered kitchenettes or kitchens in transient lodging whether in the guest room or in a common-use space. It would also apply to kitchens in multi-family residences that are owned, built, or operated by or on behalf of a public agency or a program of a public entity, both in the common-use space and in the mobility feature dwelling units.

It would not pertain to employee only work kitchens used for food preparation or kitchens in privately owned and funded multi-family residences. Nor would it apply to restaurant work kitchens for employees, but it might indeed apply to training kitchens.

So what exactly to do we need to know? ADA states that at least 50% of the shelf space is to be within reach range and as we know this would depend upon whether it is forward or side reach. For both the minimum height is 15″ AFF and for side reach, we can not reach across a counter higher than 34″. The maximum height depends on the approach, side or forward, and whether we are reaching across an obstruction. And just to answer the question before you even ask, I do not think you can consider counter surface or a dishwasher as shelving in the equation.

So how do we calculate shelf storage since it is not clearly defined? There are two methods. The more common method is calculating the linear inches for the front of the shelving. The other method is a surface area calculation which only has an advantage if the base cabinets and pantry, if provided, have full extension hardware. For both, you are looking at the sum of the total shelving, whether linear or area, and then the percentage that is within reach range to see if that makes up half of the shelving storage at a minimum. And, this is not an easy task.

Most shelf space is located in wall cabinets which typically start at 52″ AFF so not within reach range. If we put a full height pantry, we will probably arrive at the same proportion of accessible and non-accessible, but may have a bit more of the latter, so this does not help in the proportion of accessible to non-accessible. Base cabinets are typically comprised of drawers, but you could proved 2 pull-out shelves over one drawer with 100% extensions for reach range.  Since base cabinets are typically twice the depth of wall cabinets you would now have the equivalent storage space below as above except for one factor. We typically have wall cabinets above appliances, so you still will need additional shelf storage.

I have seen projects where upper shelves are actually removed from wall cabinets to get the inaccessible portion more limited. The problem with this is the mobility feature units would have less storage than non-mobility units and would not be considered equivalent.

So how can we solve this? And it does mean thinking outside of the box a bit. One option is to bring some of the wall cabinets down to the counter surface so in reality the counter becomes 12″ deep. You can not do this over a work surface, but it might be a consideration for some areas of the kitchen. If you have an island, you can place shelving units at the ends from the floor up to a 48″ height upper shelf. This creates an end cap to the island and can also be used at the open end of a run of base cabinets. You can do a pantry which is ¾ height with the top shelf at 48″ maximum AFF. And do consider that, if shelving is greater than 12″ deep, it is helpful if the shelves could be pull-out with full extensions and may even need to be in order to meet reach ranges.

There are also some new products out which might be useful for adapting a typical kitchen but I am not sure how well they can apply to a mobility feature kitchen. One is for wall cabinets where it is almost like an elevator lift where the whole cabinet interior with the shelves move up and down with a push of a button. There are others where the wall cabinet is almost on an accordion type of hardware where you reach and it pulls down and towards you. The latter may still have reach range issues for the pull-down hardware.

So in summary, to achieve a kitchen with at least half of its shelf space within reach range and at the same time maintaining equivalent storage space as a non-mobility unit, you will need to think out side of the box and expand the typical notion of base and wall cabinets with other options. It is a challenge but not impossible.

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, 2015