36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

Comment. The proposed rule specified that the rear grab bar be 24 inches long minimum, centered on the water closet, or at least 36 inches long "where wall space permits" (604.5.2). Commenters considered this provision confusing and requested clarification on where the 24 inches would be permitted. Some comments urged removal of the 24 inches specification.

Response. The proposed rule included provisions that make clear floor space requirements at water closets more stringent by not allowing other fixtures, such as lavatories to overlap the space. Saving space by locating a lavatory closer to the water closet on the same plumbing wall could only be accomplished by recessing the lavatory so that it does not overlap the clear floor space at the water closet. A grab bar 36 inches long would limit the amount of space saved in recessing an adjacent lavatory. For clarity, the Board has revised this allowance as an exception. In the final rule, section 604.5.2 requires the rear grab bar to be 36 inches long minimum. An exception allows a 24 inch long minimum grab bar, centered on the water closet, "where wall space does not permit a length 36 inches minimum due to the location of a recessed fixture adjacent to the water closet" (604.5.2, Exception 1).