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Storage – An Overview

Janis Kent, Architect, FAIA, CASp © January, 2016

For some reason, storage requirements appear to be confusing for most people – either accessible storage is forgotten completely or adequate accessible storage is not provided. And there also are some ambiguous portions in the ADA which really do need to be better defined. Like most other things in Access, the requirements for storage depends on its use. In order for storage to be considered accessible, it needs to be within reach range, whether side or forward reach, and from a level clear floor space that is along an accessible route. If it has any operable parts then they are required to have 5 lbs maximum operating force and are operable without tight grasping, pinching, or twisting of the wrist. The issue though, is the scoping – how much do we need? Below is a summary of different types of storage and their respective requirements.

General storage

General storage is required to have one minimum of each type of storage, located in each accessible storage area, to be accessible. Different types of storage can be shelving (open and closed shelving), drawers, clothes hang rods, hooks, towel rods, cabinets, etc. You can have additional storage that is not within reach range as long as one of each type in each area is accessible. Some examples are;

• A linen closet with a shelf in a mobility feature dwelling unit within public housing
• A clothes closet in a mobility feature guest room in transient lodging both for the hang rod and shelf
• An iron and ironing board wall storage device in transient lodging mobility feature guest rooms
• An employee lounge or break room counter with a sink but no cooking elements
• A guest room in a hotel with a wet bar, refrigerator, and counter but no cooking elements – coffee machines are generally not considered cooking elements per the Access Board

One of each type is somewhat loose. If you had a clothes closet split with a hangrod and shelf at the typical height and an additional lower one of each within reach range, that is all you need – the full closet is not required to have everything within reach range. If a linen closet shelf has full extension hardware, it would make it more usable, but is not required.

Kitchen storage

The term kitchen or kitchenette has not been defined by the ADA Standards. Both Webster’s dictionary and Wikipedia define it as a room or area where food is prepared and cooked. A kitchenette is defined as a small kitchen. If there are no cooking elements, then it is not really considered a kitchen. By this definition, if the kitchen or kitchenette does have cooking elements, then 50% of the shelving space is required to be accessible. DOJ does not address drawer space or other types of storage in kitchens – just shelving. The US Access Board has a broad interpretation equating drawers as being synonymous with shelving, although this has not yet been stated by DOJ as being equivalent. Kitchen storage is challenging since typical wall cabinets are not within reach range. A non-viable solution I have been seeing is removing all wall cabinet shelving to help with meeting the 50% criteria. This, though, is not really acceptable since the storage would not be equivalent to a non-mobility kitchen. Some alternatives for making kitchens accessible with 50% of the shelving within reach range are;

• Provide pull-out shelves in the base cabinets with full extensions
• Provide half height pantries with pull-out shelves if they are base cabinet depth
• Provide islands with half height cabinets at each end with pull-out shelves along the length
• Make the base cabinets deeper than typical and bring the wall cabinets down to the counter surface – if you have the bottom 2 shelves of the wall cabinets on full pull-out extensions they would be within reach range

So by this definition an employee lounge or a kitchenette in a hotel guest room having a sink, refrigerator, and a large countertop microwave would require 50% accessible. If we are talking about commercial kitchens, it is my opinion that the stored food and cooking equipment would be considered general storage with one of each type required to be within reach range, unless it is a training kitchen. For calculations, the Access Board suggests measuring the linear dimension of the front edge of the shelves. This would equate the storage in the wall cabinets as being the same as the base cabinet since you can not reach into the base cabinets. As an option, I suggest using full extension hardware on the base cabinet shelves and measuring the surface area instead of the linear frontage.

Other interesting storage points

There are some other different types of storage as well as miscellaneous items concerning storage requirements;

• In terms of alterations, supply storage rooms or locker rooms are not considered primary function areas – if being altered, it does not trigger path of travel requirements
• When prioritizing which features to address for alterations, storage is considered within the last priority group in terms of spending for disproportionality
• Public dwelling units can have cabinetry storage below the kitchen sink as long as it is easily removable
• Employee lunch rooms can not have cabinetry below the sink since knee/toe clearance below is required – self-pocketing doors are acceptable as long as they do not block the sink clear floor space
• Wet bar sinks can have storage below since side approach is allowed
• Self-service shelving, such as in retail, is required to be on an accessible route, but there is no requirement for being within reach range
• Condiment stands/counters require 50% of the items with one minimum of each type to be within reach range
• Self-service storage facilities have a specified percentage of individual units accessible and on an accessible route, dispersed by unit classes, but not required to be dispersed by area
• Lockers require 5% of the total with one minimum of each type to be accessible
• Wheelchair storage at amusement rides is required for each transfer seat and placed adjacent to the unload area out of the accessible route or means of egress

In summary, understanding the storage requirements for your project from the get-go helps with overall planning. Try and visualize how the arm bends – you can not reach down into a deep cabinet and back – elbow just does not work that way unless you squat down and reach straight back, which is why I suggest the solution of full-extensions to access the full depth of a base cabinet. There are some other types of mechanized storage solutions that can bring shelving or a hangrod down to be within reach range. These may be an alternative for equivalent facilitation to consider for alterations with limited space. And as a note, when calculating reach range you are calculating height and depth based on the front edge of the shelf or hardware and not the full depth of the storage itself.

Be aware that your local City or County may have additional requirements that are more restrictive and providing greater access 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 2016