Non-Compliant Sales Counters Due to Height and Width Issues

The 2010 ADA Standards for Accessible Design section 904 covers the guidelines for sales and service counters. 904.4.1 Parallel Approach. A portion of the counter surface that is 36 inches long minimum and 36 inches high maximum above the finish floor shall be provided. A clear floor or ground surface complying with 305 shall be positioned for a parallel approach adjacent to the 36 inch minimum length of counter. 904.4.2 Forward Approach. A portion of the counter surface that is 30 inches long minimum and 36 inches high maximum shall be provided. Knee and toe space complying with 306 shall be provided under the counter. A clear floor or ground space complying with 305 shall be positioned for a forward approach to the counter. Most sales and service counters are designed for a parallel approach. Section 305 is referred to in both the parallel and forward approach. It states that the clear floor space in front of the sales and service counter should be a minimum of 30 by 48 inches.
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Welcome to the newest post in our blog series, Top 20 ADA Compliance Issues Seen in Truckstops and Travel Plazas. Join guest post by contributor Brad GaskinsThe McIntosh Group on the second Friday of every month for his monthly column.

/// Guest post by contributor Brad GaskinsThe McIntosh Group

Many people have questions about the height of their sales and service counters. This is one of the top 20 Americans with Disabilities Act (ADA) compliance issues we see in truck stops and travel plazas.

The 2010 ADA Standards for Accessible Design section 904 covers the guidelines for sales and service counters.

904.4.1 Parallel Approach. A portion of the counter surface that is 36 inches long minimum and 36 inches high maximum above the finish floor shall be provided. A clear floor or ground surface complying with 305 shall be positioned for a parallel approach adjacent to the 36 inch minimum length of counter.

904.4.2 Forward Approach. A portion of the counter surface that is 30 inches long minimum and 36 inches high maximum shall be provided. Knee and toe space complying with 306 shall be provided under the counter. A clear floor or ground space complying with 305 shall be positioned for a forward approach to the counter.

Most sales and service counters are designed for a parallel approach. Section 305 is referred to in both the parallel and forward approach. It states that the clear floor space in front of the sales and service counter should be a minimum of 30 by 48 inches.

The Standards also state, “The accessible portion of the counter top shall extend the same depth as the sales or service counter top.” This could be interpreted to mean the counter must be continuous from the front public/customer side to the back, employee side. To find more on this we look to the Department of Justice “Guidance on the 2010 ADA Standards for Accessible Design” as follows:

Section 904.4 of the 2010 Standards also clarifies that the accessible portion of the counter must extend the same depth as the sales or services counter top. Where the counter is a single-height counter, this requirement applies across the entire depth of the counter top. Where the counter is a split-height counter, this requirement applies only to the customer side of the counter top. The employee-side of the counter top may be higher or lower than the customer-side of the counter top.

From this there is clearly a distinction made as to the employee side and public/customer side of the counter. The USDOJ explicitly states that the requirement only applies to the public/customer side of the counter and that a split counter height is allowed.

Be advised if a cash register is provided at the sales and service counter, locate the accessible counter close to the cash register so the person using the wheelchair is visible to the sales or service personnel and to minimize the reach for a person with a disability.

Below is a photo and diagram that illustrates the sales and service counter requirements. 

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Photo Credit: The McIntosh Group

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Editor's note: Gaskins was a Human Library expert at The NATSO Show. The NATSO Show 2014 will be January 25-29 in Nashville, TN. Learn more about The NATSO Show 2014 here- AT

{Guest Post} Guest post provided by NATSO Allied member Brad GaskinsThe McIntosh Group. The McIntosh Group is an architecture firm focused on providing accessibility solutions for clients nationwide. Learn more about The McIntosh Group.

The opinions and advice given by guest post contributors are not necessarily those of NATSO Inc. The posts should not be considered legal advice. Qualified professionals should be sought regarding advice and questions specific to your circumstances.

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