36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)
602 Drinking Fountains
Specifications for drinking fountains in section 602 address access for people who use wheelchairs (602.2 through 602.6) and for people who do not, but who may have difficulty bending or stooping (602.7). Substantive changes to this section include:
Comment. The proposed rule, consistent with the original ADAAG, addressed both drinking fountains and water coolers. Comments advised that the guidelines should not address "water coolers," a term which is often used to refer to bottled units that are not plumbed or permanently fixed.
Response. The Board has removed the references to "water coolers" in section 602.1 for clarity and consistency with the scope of the guidelines.
Comment. For wheelchair access, the proposed rule required a forward approach at cantilevered units but allowed a parallel approach at other types of units, such as those that are floor mounted. A forward approach provides easier access than a parallel approach for people using wheelchairs. The Board sought comment on whether it should require a forward approach, which includes knee and toe clearances below the unit, at all wheelchair accessible drinking fountains (Question 24). Commenters overwhelmingly supported such a requirement as more appropriate for wheelchair access.
Response. The Board has revised the rule to require a clear floor space for a forward approach at all wheelchair accessible drinking fountains (602.2). Corresponding changes have been made to the specifications for spout location (602.5). An existing exception for units designed specifically for children’s use permits a parallel approach if certain criteria for spout height and location are met.
Comment. The proposed rule required spouts to provide a flow of water at least 4 inches high "to allow the insertion of a cup or glass." A comment noted that the rationale for this specification is not needed in the text of the requirement and might be misinterpreted as allowing cup dispensers as an alternative to accessible units.
Response. Language concerning the insertion of cups has been removed as unnecessary to the water flow specification. The minimum 4 inch height is intended to allow use of cups for persons who may need to use them. However, providing cup dispensers as an alternative to a compliant unit is not recognized by these guidelines in new construction or alterations.
Comment. Specifications for drinking fountains for standing persons address the height of the spout outlet (602.7). The proposed rule required a height of 39 to 43 inches above the floor or ground, a range that derives from the standard height of models on the market. A drinking fountain manufacturer requested that the minimum height be changed from 39 to 38 inches, consistent with referenced ergonomic data. This commenter advised that a 38 inch height will accommodate units that are intended to serve both adults and children.
Response. The minimum height for the spout outlet of units designed for use by standing persons has been lowered from 39 to 38 inches.
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