2013 CA PTD Twist

2010 CBC 1115B.8.3 Towel, sanitary napkins, waste receptacles, dispensers and controls. Where towel, sanitary napkins, waste receptacles, dispensers, other equipment and controls are provided, at least one of each type shall be located on an accessible route, with all operable parts, including coin slots, within 40 inches (1016 mm) from the finished floor and shall comply with Section 1117B.6, Controls and operating mechanisms.

2013 CBC 11B-603.5 Accessories.  Where towel or sanitary napkin dispensers, waste receptacles, or other accessories are provided in toilet facilities, at least one of each type shall be located on an accessible route.  All operable parts, including coin slots, shall be 40 inches (1016 mm) maximum above the finished floor.

2010 CBC 1115B.8.3 states "at least one of each type shall be located on an accessible route, with all operable parts ... within 40 inches."  2013 CBC 11B-603.5 breaks up the provision into two sentences as follows: "at least one of each type shall be located on an accessible route.  All operable parts ... shall be 40 inches."

Based on this sentence structure, it is clear that "at least one" accessory is required on an accessible route.  However, does the next sentence refer to the operable parts of "all" accessories, or "all" accessories that are on the accessible route, i.e., the one of each type?  Was there a change in intent.

Bradley the ADA Geek. Niavete is my strength. I seek to understand. I strive for perfection. And I can't type for crap so please forgive me.

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11B-603.5 has two sentences, so if one were to look at them "separately," the second sentence would impose the height requirement on all accessories -- even if they were not "on an accesible route." This is contrary to the intent of singling out the accesible accesories -- making the concept self-defeating. IMHO, both sentences should be taken together (or grammatically connected with a conjunction --> "...route, and." BTW, DSA would need to go through rulemaking, as it is subjective.

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