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Toilet Room Mirror Mounted Too High From The Bottom Of The Reflecting Surface

Posted in: Truckstop Business, Americans with Disabilities Act, Operations


Top 20 ADA Compliance Issues Seen in Truckstops and Travel Plazas is back! Join guest post contributor Brad GaskinsThe McIntosh Group every month for a new installment in his monthly column.

/// Guest post by contributor Brad GaskinsThe McIntosh Group

The Department of Justice considers accessibility of toilet rooms to be third priority in ADA compliance, and a common issue we see in this area relates to the toilet room mirrors.

For something so simple, toilet room mirrors in convenience stores are often mounted too high to comply with the ADA standard. The good news is it’s an easy fix.

According to the Americans with Disabilities Act, the rule is:

“Mirrors located above lavatories or countertops shall be installed with the bottom edge of the reflecting surface 40 inches (1015 mm) maximum above the finish floor or ground. Mirrors not located above lavatories or countertops shall be installed with the bottom edge of the reflecting surface 35 inches (890 mm) maximum above the finish floor or ground.”

Generally, for the past many years, the standard for architects and contractors has been “substantial compliance” to building codes, which for this item basically means that a contractor comes in, looks at the mirror, and decides whether it looks like a person in a wheelchair would be able to see themselves.

Because we now must adhere to the ADA, a civil rights law, “substantial compliance” just won’t cut it. The specific rule is that the toilet room mirror must be mounted 40 inches from the floor. According to, the average eye level of a person in a wheelchair is 43-51 inches. Using the 40-inch standard, the average person in a wheelchair would clearly be able to see his or her own face in the mirror.

We often see other “fixes” to this problem, such as a tilted mirror intended to give better viewing range to persons in wheelchairs. While these tilted mirrors are helpful, they do not exempt you from meeting the 40-inch rule.

We also see this problem in places that use thick frames around the mirror for design purposes, where the thickness of the frame takes the mirror above the 40-inch mark. If this framed mirrors are a look you’re interested in, you must make sure your frames do not put you out of compliance.

If you’re unsure whether your store meets this requirement, use a tape measurer to see whether the distance from the floor to the bottom of the reflective surface of the mirror exceeds 40 inches, and relocate your mirror if necessary.

As far as barrier removal goes, this is a simple one. 


/// Read more Top 20 ADA Compliance Issues Seen in Truckstops and Travel Plazas posts here

Photo Credit: 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.

{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.

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About the Author

Brad Gaskins, AIA, CASp

Brad Gaskins, AIA, CASp

Brad has more than 25 years experience in the practice of architecture and a comprehensive understanding of professional practice nationwide. Brad brings a unique and valuable perspective to The McIntosh Group’s practice and clients, with a specific expertise in the Americans with Disabilities Act (ADA) and national building codes.  Brad has gained recognition as an expert witness for clients with ADA compliance complaints. He represents NACS, The Association for Convenience and Fuel Retailing, as a full voting member on the International Code Council (ICC), American National Standards Institute (ANSI) A117.1, Consensus Committee on Accessible and Usable Buildings and Facilities. His objective is to share, with the committee for their deliberations, the potential impact of the standards on the convenience store and truckstop industry. Brad has an undergraduate degree in engineering and a master’s degree in architecture from the University of Oklahoma. He is currently serving as president of AIA Oklahoma. 

Got questions about ADA guidelines? Let Brad help, he’s the ADA Geek.


The “Ask Brad” website educates visitors on the Americans with Disabilities Act (ADA). The site offers the knowledge of an architect, Brad, who has a specific expertise in ADA compliance. Visitors to the site are encouraged to submit questions regarding the ADA. Brad will answer the questions and post them to the site for all to take advantage. In addition to the Q&A section, the site offers timely information through instructional videos, white papers, articles and resource links.


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