When it comes to the bathtub seats there seems to be confusion on what type of models actually meet the accessibility requirements and when they have to be provided. With questions often being raised if certain models are considered “removable”. Let’s first look at whether or not your project would require a seat to be provided.
The accessible ADA guestrooms that have a bathtub provided as the accessible bathing fixture, are required to provide either a permanent or removable tub seat at first occupancy. The 2010 ADA Standards and the ANSI A117.1 code provide no exceptions to this requirement for R-1 occupancies.
If the project in question is multifamily residential, whether you need to provide a tub seat or not, depends on if the project is privately or publicly funded as well as what version of the ANSI code is applicable in that jurisdiction.
In Type B units, there is no requirement for a tub seat regardless of the code or the funding source.
In Type A units on privately funded projects you will not have to provide removable or permanent bathtub seats if ANSI 2009 is applicable. ANSI A117.1- 2009, Section 1003.11.2.5.1 has an exception to providing the removable tub seat. But be aware that the ANSI A117.1-2017 code removed that exception to providing a tub seat. Under ANSI 2017 a removable or permanent seat will need to be provided / offered to tenants at Type A units.
If the project is a Section 504 publicly funded, the 2010 ADA Standards or UFAS will be in effect as the technical requirements for Section 504 compliance. Neither of these codes provide exceptions to providing a seat, meaning that you will have to provide a removable or permanent seat at tubs in the 5% of accessible mobility units.
If a bathtub is provided on the property for either employee or public use, a removable or permanent tub seat is required at first occupancy. The codes contain no exceptions to this requirement.
Keep in mind this does not apply to bathtubs when they are not functioning as bathing fixtures. This would typically occur when tubs are provided as an amenity feature within a space like a spa or athletic club.
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Fold down tub seats (like the one shown in the photo below) are commonly installed in standard sized tubs since they provide ease of use, they provide a seat and when not in use they can be folded out of the way. However be aware that these types of seats, even when the manufacturer specifications say they are ADA compliant, would not be acceptable since they are not removable. That's due to fold-down seats having to be permanently attached to the fixture wall in order to function.
The other problem with this type of folding seat is that they do not comply with the accessible reach range requirements. When the tub seat is folded up the seat is located outside of an accessible reach range, in order to pull down the seat a person would have to reach across the tub. This would effectively limit the tub to being no more than 24” in depth (measured from the front leading edge of the tub to the back wall of the tub), in order to have an accessible obstructed side reach range.
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What type of removable tub seat would be acceptable? Any model that can be fully removed from the tub when not in use, without the need for tools or special skills and that complies with the requirements found in Section 610.2 of the ICC ANSI-A117.1 or 2010 ADA Standards.
Please keep in mind that the information presented here is a general look at removable tub seats and is not comprehensive for all situations and projects. If there’s any questions about bathing fixtures or any other accessibility items, feel free to contact us.
(Title image courtesy of US Access Board, Guide to the ADA Accessibility Standards)
