T.

4-23-93
Control No. X93032203939
MAY 10 1993
The Honorable Jim Kolbe
Member, U.S. House of Representatives
1661 North Swan Road, Suite 112
Tucson, Arizona 85712

Dear Congressman Kolbe:

This letter responds to your inquiry on behalf of your

constituent, Stewart R. Palmer, concerning the regulatory
requirements of the Americans with Disabilities Act (ADA) for
urinals and for drinking fountains.

The ADA authorizes the Department of Justice to provide

technical assistance to individuals and entities with rights or
obligations under the Act. This letter provides informal
guidance to assist your constituent in understanding the ADA
accessibility standards. However, this technical assistance does
not constitute a legal interpretation of the statute and it is
not binding on the Department.

The technical provisions for accessible urinals in section

4.19 of the Department's standards for accessible design do not
specify a dimension for the required "elongated rim." Many
commonly available urinals, including the one shown on the
catalog sheet that Mr. Palmer enclosed with his inquiry, are
acceptable if installed in compliance with all the applicable
technical provisions.

Drinking fountains that allow a front approach by a person

using a wheelchair must have a knee space at least 27 inches high
(see section 4.15.5 of the standards). Section 4.4.1 says that
an object mounted with the leading edge at or below 27 inches
above the floor may protrude any amount. Therefore, if the
bottom edge of the drinking fountain is 27 inches above the
floor, both these height requirements are satisfied.

cc: Records, Chrono, Wodatch, Harland, McDowney, FOIA, MAF

n:\udd\mercado\congltrs\kolbe.ewh

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If there are state or local accessibility requirements that

are more stringent than those required by the ADA, these must
also be addressed.

Your constituents may contact the Public Access Section when

they have questions or need information. The Department
maintains a telephone information line to provide technical
assistance regarding the rights and obligations of individuals,
businesses, agencies, and others covered or protected by the ADA.
This technical assistance is available by calling (202) 514-0301
(voice) or (202) 514-0383 (TDD) between 1:00 p.m. and 5:00 p.m.,
Monday through Friday.
I hope the information we have provided is helpful to you
and your constituent.

Sincerely,

James P. Turner
Acting Assistant Attorney General
Civil Rights Division

Stewart R. Palmer Consulting Engineers, Inc.

January 26, 1993

The Honorable Jim Kolbe
U.S. Congressman
1661 North Swan
Tucson, Arizona 85712

Dear Mr. Kolbe:

I am trying to get an official interpretation of the "American for

Disability Act." Will you please help.

My paragraph numbers refer to the Federal Register/Vol. 56 No.

144/Friday, July 26, 1991/Rules and Regulations (copies of the pages
a-re attached).

4.18.2 Height, Urinals shall be stall-type or wall hung with an

elongated rim.... What is meant by elongated rim? The normal wall
hung urinal has about a 12" rim. See attached catalog sheet.

4.15 Drinking Fountains. This paragraph details the clearances

required for wheelchair access. Paragraph 4.4 Protruding objects:
has requirement for items to project into the walking area.
This is to assist the visually handicapped. . In accordance with
Figure 8(2) it appears a drinking fountain can only project 4" into
the walking area unless the bottom is 27" or lower. Drinking
fountain bottoms may comply with the 27" but the rim projects
further into the space. (See attached catalog sheet.)

My questions are:
1. Does the normal urinal meet the ADA requirement?
2. Do the normal drinking fountains meet the requirements
or must they be recessed so only 4" project into the
walking area?

Sincerely,

Stewart R. Palmer