Overlooked Accessibility Requirements for Refillable Soap Dispensers

More and more hotels are switching over from the single use bathroom soap and shampoo bottles to the larger refillable bottles mounted to the wall of the bathing fixture. Love them or hate them, they are a common thing to see installed in most hotels these days. Yet they can create issues meeting the accessibility ADA requirements, requirements which tend to get overlooked. Just because there is no code language specifically referencing soap dispensers at bathing fixtures, does not mean they are exempt from the overlapping accessibility requirements.

In R-1 developments, like hotels and motels, refillable soap dispensers are an accessibility concern in the amenity areas (common-use restrooms, fitness centers, saunas, pools), employee areas (restrooms, break rooms) and in the guest rooms with mobility features (the accessible guest rooms) per 2010 ADA Standards, Section 224.2

Dispensers installed within the guest rooms that are not required to provide accessible mobility features would be exempt from the requirements discussed below.

The clear space between the horizontal grab bar and any projecting objects above the grab bar shall be 12” minimum. The clear space between the horizontal grab bar and any projecting objects below the grab bar shall be 1 1/2” minimum. (2010 ADA Standards, Section 609.3)

Soap dispensers, storage trays, soap dishes, and anything else mounted to the walls of a shower or tub will need to account for this spacing requirement. Keep in mind that the grab bar spacing requirements apply to all horizontal grab bars at the bathing fixtures as well as the toilets, but it would not be common to see these soap dispensers installed at the toilet fixture. But be aware that other items can typically interfere with the grab bar spacing at the toilet, like toilet paper and toilet seat cover dispensers.

Soap dispensers need to be provided with the operable parts, including the pump, lever, buttons, sensors within an accessible reach range of 15” min to 48” max above the finish floor for an unobstructed reach range. While this sounds simple, you need to take into account the grab bar spacing requirements we discussed above.

It's typical to see soap dispensers mounted above the grab bar, but this can create compliance issues. When the dispenser is mounted to the wall above the grab bar, it needs to measure 12” min above the grab bar to the bottom leading edge which might then push the operable parts above the 48” max reach range. This issue most commonly affects traditional bottle style dispensers where the pump is located at the top, as the image below shows.

There is an option to consider and that would be dispensers with the operable parts located at the bottom, with the controls at the bottom of the dispenser it may be possible to meet the grab bar spacing and still have controls within an accessible reach range.

To avoid the grab bar spacing requirements it's common to see the soap dispensers get installed on the seat wall of the shower fixture. No grab bars on that wall, so there's no accessibility issues to be concerned with right? Unfortunately no, the space above the seat in the shower is required to remain clear and can not be overlapped by grab bars mounted to any of the fixture walls. Any obstructions above the seat prevent a person from being able to fully utilize the seat, nobody wants to sit down and have a protrusion sticking into their neck or back. This means that soap dispensers and soap dishes are also not permitted to be installed over the seat, whether it be the seat wall or the adjacent wall. (2010 ADA Standards, Section 608.3)

Is your hotel located in the state of Illinois? On August 9, 2024, Illinois passed the Small Single-Use Plastic Bottle Act (SB2960) into law, requiring hotels with 50 or more rooms to eliminate the use of single-use plastic bottles containing personal care products in individual rooms and public bathrooms beginning July 1, 2025. Hotels with less than 50 rooms shall comply by January 1, 2026.

Feel free to reach out if you have any concerns or questions about your project. We have experience with new and existing hotels across the country, and would be more than happy to help provide clarification on any confusing code topics.