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Countertop Requirements for Accessible Kitchens Under ADA

Janis Kent, FAIA, Architect, CASp © April, 2021

Counters come in many varieties from transaction to service to work surfaces just to name a few. We will look closer at kitchen countertops located in dwelling units, employee lounges, and common-use spaces. Although the requirements do overlap with other types of counters, there are a few more items that do impact kitchens. 

To start with, a kitchen is defined as an area where food is prepared and cooked as opposed to an area with just a sink, refrigerator, small loose microwave, and/or loose coffee machines, etc. And a kitchenette is a smaller version of a kitchen. Kitchen countertops do have maximum height requirements, but this does not mean that the full counter length has to be at the height. 

Counters located at work surfaces can be at variable heights from 29″ to 36″, and sinks in residential dwelling units can also be adjustable to that height range. Otherwise, if fixed, the counter surface in these two areas are required to be 34″ maximum above the floor – this includes the rim for self-rimming sinks, which actually puts the counter height lower. And note, not all kitchens are required to include work surfaces, although in dwelling units it is a requirement as well as in some common-use types of kitchens.

Reach Range Over Countertops

There is no specific stipulation for countertop heights in kitchen areas other than the work surface and sink, but there are other items that can control and impact the height. One should be aware of reach range over the countertop. For side reach, you can not reach over a surface higher than 34″. So if there are wall cabinets above, and the shelves are part of the 50% equation for reach range, then the countertop in that area is limited to 34″ maximum. The same goes for reach to any switches and outlets located on the back wall.

But if the countertop has knee/toe clearance below, and is in addition to the one required work surface, then for forward approach, it can be at the 36″ standard countertop height or higher. One can reach over a surface higher than 34″and reach 25″ back for forward approach. You can also reach up to 48″ to the wall cabinet above, presuming they are located within 20″ of the edge of the counter overhang. But this is presuming no base cabinet storage below.

Outlets and Switches

Under ADA, if a length of counter between an appliance or fixture has two or more outlets, then one outlet is exempt from reach range requirements. (CBC does not have this exemption) What this means is that the counter area directly in front of outlets and switches will need to be 34″ maximum for side reach, but the counter height can be higher in between or where there is an outlet that is exempt. If outlets are placed every 48” then a portion of that length not directly in front could actually be higher. I can not provide direction on how wide the lowered portion is required to be at outlets and switches – so there is a judgement call on how the space is used. And this presumes the cabinets are a parallel or side approach.

Appliances

With all of this said, appliances are now manufactured for 34” height counters. It is interesting to note that there are no height requirements for range or cooktop surfaces, although their controls need to be located within reach range and not across a heating element. While the height of ranges and cooktops are not controlled, be aware that if a tall pot were placed on top, not only would the items in the pot not be visible, but also can be dangerous for someone who is short or who is seated. If a counter has a cooktop, this could also be helpful if located on an adjustable height or lowered counter. 

Now the reason I am bringing this up, is that an aspect of good kitchen design principals suggests we have counters at a variety of heights. This is not only due to whether someone is tall or short, or standing or seated, but also the task at hand. So if one were chopping vegetables on a thick cutting board or mixing something in a tall bowl, it might be helpful for it to be placed on a lower counter such as at 30″ to 32″, or a bit above table height. If one were rolling out dough, perhaps 32″ to 34″ is appropriate. Other surfaces used for cooking and staging might be helpful to be at 34″ to 36″ or even higher. But remember, the accessible portion is to be at 34″ maximum for a side approach and at sinks and required work surfaces.

In Summary

So give some thought to countertop heights, and design the heights depending on the task at hand. Even though, aside from reach range, only the two areas, sinks and work surfaces, are actually required to be at 34″ maximum, it is also appropriate to provide more counters at that height or even lower as well. And do not forget, that a countertop microwave needs to be located on a counter that is 34″ maximum above the floor unless actually placed at the front edge of the counter aligning with the edge of the overhang, or you can have it placed in a drawer below, which is the safest, in my opinion.

Thanks to A. Colla for the topic request

Nothing in this article constitutes legal or design advice for a particular project or circumstance. Be aware that your local City or County may have additional requirements that are different or more restrictive than the State or Federal requirements. Also, this article is an interpretation and opinion of the writer which may vary for a particular project or due to other circumstances. It is meant as a general summary – current original regulations should always be reviewed when making any decisions and specific advice by a qualified professional should be secured for a particular project or circumstance.

© Janis Kent, FAIA, Architect, CASp 2021