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11B-226.1 General.

Where dining surfaces are provided for the consumption of food or drink, at least 5 percent of the seating spaces and standing spaces at the dining surfaces shall comply with Section 11B-902. In addition, where work surfaces are provided for use by other than employees, at least 5 percent shall comply with Section 11B-902.


1.      Sales counters and service counters shall not be required to comply with Section 11B-902. See Section 11B-227.

2.      Check writing surfaces provided at check-out aisles not required to comply with Section 11B-904.3 shall not be required to comply with Section 11B-902

[2010 ADAS] Advisory 226.1 General.  In facilities covered by the ADA, this requirement does not apply to work surfaces used only by employees. However, the ADA and, where applicable, Section 504 of the Rehabilitation Act of 1973, as amended, provide that employees are entitled to "reasonable accommodations." With respect to work surfaces, this means that employers may need to procure or adjust work stations such as desks, laboratory and work benches, fume hoods, reception counters, teller windows, study carrels, commercial kitchen counters, and conference tables to accommodate the individual needs of employees with disabilities on an "as needed" basis. Consider work surfaces that are flexible and permit installation at variable heights and clearances.

11B-226.2 Dispersion.

Dining surfaces required to comply with Section 11B-902 shall be dispersed throughout the space or facility containing dining surfaces for each type of seating in a functional area. Work surfaces required to comply with Section 11B-902 shall be dispersed throughout the space or facility containing work surfaces. 

[2010 ADAS] 226.2 Dispersion.  Dining surfaces and work surfaces required to comply with 902 shall be dispersed throughout the space or facility containing dining surfaces and work surfaces.

11B-226.3 Dining surfaces exceeding 34 inches in height.

Where food or drink is served for consumption at a counter exceeding 34 inches (864 mm) in height, a portion of the main counter 60 inches (1525 mm) minimum in length shall be provided in compliance with Section 11B-902.3 _|Height|_

11B-226.4 Baby changing tables.

Baby changing tables shall comply with Sections 11B-309 and 11B-902. Baby changing tables when deployed shall not obstruct the required width of an accessible route except as allowed by Section 11B-307.2. Baby changing tables shall not be located in toilet compartments complying with Section 11B-604.8 within a multiple accommodation toilet facility.

ETA Editor's Note

The ADA requirements included at Section 11B-226 are provided for information only. The 2013 CBC scoping requirements are more inclusive.

Baby changing tables were not specifically addressed by the original 2013 CBC.  If located in a toilet room required to be accessible, they were indirectly addressed by the requirement to make at least one of each accessory accessible.  This has been generally understood to include the technical requirements for accessible routes, clear floor space, reach ranges, knee and toe space, worksurface heights, operable parts and protruding objects.

Although a 2010 ADAS Advisory strongly cautions otherwise, there was no prohibition in the original 2013 CBC or 2010 ADAS against installing baby changing tables in accessible water closet compartments, provided that all of the technical requirements were met.  There was also no specification that baby changing tables could not intrude into the accessible routes when deployed.  Therefore, existing baby changing tables that are installed in accessible water closet compartments, or that protrude more than 4" into accessible routes when deployed, are not presently subject to path of travel barrier removal obligations if, and only if, they meet all other technical requirements for accessibility.  If they must be modified, for example, to comply with the maximum work surface height of 34 inches, their noncompliant location (i.e., inside an accessible water closet compartment, or obstructing an accessible route when deployed) would also require correction.

When evaluating whether to take advantage of this Safe Harbor, Pocket Guide users are urged to consider:

  1. If alterations are performed in an area served by the subject toilet room in the future, permitted under a subsequent edition of CBC, the baby changing table in a noncompliant location will have to be relocated at that time;

  2. When a baby changing table in an accessible toilet compartment is being used, that compartment becomes unavailable for its intended use;

  3. Parents dealing with a young child's needs are not always mindful of the needs of others, and poorly located baby changing tables that are left in the deployed position can limit door movement, blocking access for anyone who cannot negotiate tight spaces, a circumstance prohibited under CBC 11B-108, Maintenance of accessible features;  and,

  4. Baby changing tables left in the deployed position in a circulation path can be a hazard to persons with vision impairment, also prohibited under CBC 11B-108.


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