Type A Kitchens: 34” Countertop Height Applies to the Entire Kitchen

We hear it quite often where someone mentions that the countertops will be seamed to allow both the sink and work surface countertop to be lowered upon tenant request. That raises a red flag from us. To be clear there is no issue with lowering the countertops later upon tenant request, there is an exception written into the code under ANSI 2009, Section 1003.12.3.2 (work surface) & Section 1003.12.4.2 (sink). The red flag is thinking that only the work surface and sink need to be designed to have lowered countertops.

This issue typically comes up because if you only read through the section of code for Type A Kitchens, Section 1003.12 and don’t apply the rest of Section 1003, you will be missing other relevant code sections that apply to kitchens.

The code for Type A unit kitchen work surfaces and sinks (ANSI 2009, Section 1003.12.3.2 & 1003.12.4.2) has code language that specifically calls out the height requirement for these items. The code diagrams in this section also don’t help to clarify things, because they depict a lowered countertop at the sink and work surface but raised countertops adjacent to them. In effect, creating confusion and leading people to think only the work surface and sink need the 34” height, which would then be an issue.

For this you will need to look at Section 1003.9, Operable Parts. This section of the code states that controls for tenant use, including lighting controls/switches, appliance controls, and outlets, need to comply with Section 309. If we look at Section 309, we find language stating that operable parts shall be within an accessible reach range as specified by Section 308.

It is here in Section 308.3.2 we find the relevant language for countertops in Type A kitchens. When you have a clear floor space positioned for a parallel approach at a countertop, the reach range to any outlets, switches, or controls positioned above or on top of the kitchen counter is defined as an “obstructed side reach range”. The code requires a 24” maximum depth over a counter to the outlet or switch, with a counter height measuring 34” maximum AFF. With any outlets or switches positioned at 46” maximum AFF, measured to the centerline of the highest switch or outlet in the receptacle.

If you're not providing 34” high countertops at first occupancy or installing ones that can be lowered later upon tenant request, you will have an accessibility issue on your hands that's far from being easy or cheap to fix later.

Just as a friendly reminder this write-up was focused on Type A unit kitchens but the requirement discussed will also apply to kitchen and kitchenette spaces open to the general public, those serving employees (break rooms), as well as those provided in tenant amenity areas.

The 24” reach range depth at Type A kitchen countertops is another common issue that comes up. If you have questions regarding this item, please take a look at our previous write-up, Type A Kitchen Counters: 24” Reach Range Depth. We explain the requirement and explore different design/construction options for addressing the issue.

Concerned about your project or want to discuss another topic? We have experience nationwide handling all sorts of accessibility issues on a wide range of project types, so feel free to contact us.