Plug Mold for Kitchen Counter Small Appliance receptacles and Fair Housing Req.

[octavius1st]

I am being asked to weigh in on whether it is OK to install only plugmold to the underside of the upper kitchen cabinets (36"+18"), and none in the backsplash, for standard (non-island and peninsula) dwelling unit kitchen counter spaces. I've seen it done many times, but there is a code reviewer that is telling me that the underside of the upper cabinets is too high to comply with the reach requirements of the Fair Housing Act. Has anyone determined how this can clearly comply in a multi-unit building?

The client wants only the plugmold and no wall outlets at the counters, but the implications of the code reviewer seem to force some wall outlets into every counter space in the kitchen.

Please help.

 

[infinity]

I know nothing about the fair housing requirements but the NEC allows up to 20" above the counter top.

Welcome to the Forum.

 

[tom baker]

There was a code proposal many cycles ago from an interior designer in Montanat who wanted to mount plugmold on the bottom lip of a cabinet, which would put it more than 18" above the counter. the proposal was accepted.
Not sure about the fair housing act, but OK by NEC.
FYI I tried to install the new plug mold with built in GFCI, it must be end fed as 12 AWG wires can't be fed from the middle and get past the big AFCI module. I ended up using a DF GFCI/AFCI CB.

 

[Adamjamma]

If installed there, a wheel chair user cannot reach it, but, it is only in such kitchens that one cannot use it, from what I was taught about design... wheel chair users need lowered counters, pull down shelves on upper cabinets, area under certain counter places clear for knees, wider clearance in the doors and walkways, stoves are put in a lower countertop as well, and dishwashers and other such appliances are raised to make it easier as well, normally, so design is wholly different...
that said, you often see certain design things suggested under the ADA act that make it easier in some ways for all to use outlets etc.. one of which is outlets above 2 feet and switches and counter outlets below 4 feet 6 inches.

i still have a book somewhere on ADA design points and the comparison to the European rules.

 

[romex jockey]

I learn something every day here.....

I learn something every day here.....

Of interest may be Annex J in the nec......

This informative annex is not a part of the requirements of this NFPA
document, but is included for informational purposes only.
The provisions cited in Informative Annex J are intended to
assist the users of the Code in properly considering the various
electrical design constraints of other building systems and are
part of the 2010 ADA Standards for Accessible Design. They are
the same provisions as those found in ANSI/ICC A117.1-2009,
Accessible and Usable Buildings and Facilities.

Interesting disclaimer , yet ends up being addressed by state entities here , a fire marshal for example....

Now i know where the 80" sconce height standard comes from ....

~S~

 

[charlie b]

I can tell you that this very day an electrician will be installing just such a set of receptacles on the underside of the cabinets of our almost-completed kitchen remodel. There are no receptacles in the backsplash. The distance between the countertop and the underside of the upper cabinets is 19.5 inches. I don't know the brand name of the raceway. It is triangular in shape, so that the receptacles face downwards at an angle.

 

[octavius1st]

If installed there, a wheel chair user cannot reach it, but, it is only in such kitchens that one cannot use it, from what I was taught about design... wheel chair users need lowered counters, pull down shelves on upper cabinets, area under certain counter places clear for knees, wider clearance in the doors and walkways, stoves are put in a lower countertop as well, and dishwashers and other such appliances are raised to make it easier as well, normally, so design is wholly different...
that said, you often see certain design things suggested under the ADA act that make it easier in some ways for all to use outlets etc.. one of which is outlets above 2 feet and switches and counter outlets below 4 feet 6 inches.

i still have a book somewhere on ADA design points and the comparison to the European rules.

Agreed. So that's what we might call an Accessible and Type A Accessible Unit (ICC & ANSI A117.1 nomenclature). They do have different design practices. The rub here is that all the rest of the dwelling units in the building are Type B Accessible, which wouldn't have these features, BUT the fair housing reach requirements appear to still apply, which put the plugmold above the 46-48" height they cite. I'm really looking for a citable exception, if anyone know of one...

 

[octavius1st]

Of interest may be Annex J in the nec......



Interesting disclaimer , yet ends up being addressed by state entities here , a fire marshal for example....

Now i know where the 80" sconce height standard comes from ....

~S~

Annex J doesn't exist in the NEC 2008, which is the active code for a few more days in my main AHJ and this building. In 2017 NEC it appears to be very near a reissue of ANSI A117.1.

Does anyone know of a reach diagram for ADA that shows something that is overhead and not wall mounted? The plug mold would be up to about 9" away from the wall. I don't know if there is a distinction that could apply to this.

 

[growler]

Does anyone know of a reach diagram for ADA that shows something that is overhead and not wall mounted? The plug mold would be up to about 9" away from the wall. I don't know if there is a distinction that could apply to this.

The Department of Justice has a toll free ADA help line. Perhaps it would be better just to call them and ask.

800-514-1301 ( voice )
800-514-0383 ( TTY )

 

[norcal]

Do ADA requirements apply to single family homes? I can see it applying to multi-family though.

 

[david]

https://www.huduser.gov/portal/publications/PDF/FAIRHOUSING/fairfull.pdf


I think when a site has four or more dwelling units the fair housing act applies

"The design and construction requirements
of the Fair Housing Act apply to all new multifamily housing consisting of four or more dwelling
units. Such buildings must meet specific design
requirements so public and common use spaces
and facilities are accessible to people with disabilities. "

 

[Adamjamma]

https://www.huduser.gov/portal/publications/PDF/FAIRHOUSING/fairfull.pdf


I think when a site has four or more dwelling units the fair housing act applies

"The design and construction requirements
of the Fair Housing Act apply to all new multifamily housing consisting of four or more dwelling
units. Such buildings must meet specific design
requirements so public and common use spaces
and facilities are accessible to people with disabilities. "

and when you contact them with this, they will tell you that while the doors and public walkways must be wheelchair accessible, only the wheel chair ready apartments must be designed for wheelchairs totally... the rest of the apartments can be designed under normal access guidelines so the mounting on the underside of the upper cabinets will be OK... Because an apartment is not normally considered public or common use space, only the hallways and walkways...

 

[octavius1st]

The Fair Housing Act Design Manual (FHADM) clearly calls for "all premises within" to have light switches and outlet within access. See Chapter 5 starting on page 151. ANSI A117.1-2009 and later have exemptions for outlet and switches above countertops, 1004.9 ex10, but I can't find how these later versions of ANSI are part of a safe harbor option, only earlier versions (2003 & 2000)

ANSI A117.1 - 2009


ANSI A117.1 - 2003




Safe Harbor listings:

https://www.fairhousingfirst.org/faq/view_all.html​

 

[david]

I would think you would apply the Type B Units requirements



http://www.mzarchitects.com/wp-content/uploads/2015/03/ansi.a117.1.2009.pdf

1004 Type B Units

1004.9 Operable Parts. Lighting controls, electrical switches and receptacle outlets, environmental controls, electrical panelboards, and user controls for security or intercom systems shall comply with Sections 309.2 and 309.3.

EXCEPTIONS: 1. Receptacle outlets serving a dedicated use. I 2. Where two or more receptacle outlets are provided in a kitchen above a length of counter top that is uninterrupted by a sink or appliance, one receptacle outlet shall not be required to comply with Section 309.

10. Within kitchens and bathrooms, lighting controls, electrical switches and receptacle outlets are permitted to be located over cabinets with counter tops 36 inches (915 mm) maximum in height and 25 1/2 inches (650 mm) maximum in depth.

309.2 Clear Floor Space. A clear floor space complying with Section 305 shall be provided.

309.3 Height. Operable parts shall be placed within one or more of the reach ranges specified in Section 308.

309.4 Operation. Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5.0 pounds (22.2 N) maximum. 14 EXCEPTION: Gas pump nozzles shall not be required to provide operable parts that have an activating force of 5.0 pounds (22.2 N) maximum.

308 Reach Ranges

308.1 General. Reach ranges shall comply with Section 308. 308.2 Forward Reach. 308.2.1 Unobstructed. Where a forward reach is unobstructed, the high forward reach shall be 48 inches (1220 mm) maximum and the low forward reach shall be 15 inches (380 mm) minimum above the floor.

308.2.2 Obstructed High Reach. Where a high forward reach is over an obstruction, the clear floor space complying with Section 305 shall extend beneath the element for a distance not less than the required reach depth over the obstruction.

The high forward reach shall be 48 inches (1220 m) maximum above the floor where the reach depth is 20 inches (510mm) maximum.

Where the reach depth exceeds 20 inches (510 mm), the high forward reach shall be 44 inches (1120 mm) maximum above the floor, and the reach depth shall be 25 inches (635 mm) maximum.

308.3 Side Reach

308.3.1 Unobstructed. Where a clear floor space complying with Section 305 allows a parallel approach to an element and the edge of the clear floor space is 10 inches (255 mm) maximum from the element, the high side reach shall be 48 inches I (1220 mm) maximum and the low side reach shall be 15 inches (380 mm) minimum above the floor.

EXCEPTION: Existing elements that are not I altered shall be permitted at 54 inches (1370 mm) maximum above the floor.

308.3.2 Obstructed High Reach. Where a clear floor space complying with Section 305 allows a parallel approach to an element and the high side reach I is over an obstruction, the height of the obstruction shall be 34 inches (865 mm) maximum above the floor and the depth of the obstruction shall be 24 inches (610 mm) maximum.

The high side reach shall be 48 inches (1220 mm) maximum above the floor for a reach depth of 10 inches (255 mm) maximum.

Where the reach depth exceeds 10 inches (255 mm), the high side reach shall be 46 inches (1170 mm) maximum above the floor for a reach depth of 24 inches (610 mm) maximum. EXCEPTION: At washing machines and clothes dryers, the height of the obstruction shall be permitted to be 36 inches (915 mm) maximum above the floor.

 

[david]

Section 1004 of this standard provides criteria for Type B units. These criteria are intended to be consistent with the intent of the criteria of the U.S. Department of Housing and Urban Development (HUD) Fair Housing Accessibility Guidelines. The Type B units are intended to supplement,

not replace,

Accessible units or

Type A units as specified in this standard.

 

[octavius1st]

The units in question are definitely Type B (not Type A, or Accessible). Is there a "Safe Harbor" path that can use what is now in the A117.1 2009 or later?

 

[david]

The Fair Housing Act Design Manual (FHADM) clearly calls for "all premises within" to have light switches and outlet within access. See Chapter 5 starting on page 151. ANSI A117.1-2009 and later have exemptions for outlet and switches above countertops, 1004.9 ex10, but I can't find how these later versions of ANSI are part of a safe harbor option, only earlier versions (2003 & 2000)

ANSI A117.1 - 2009
View attachment 22407

ANSI A117.1 - 2003
View attachment 22408



Safe Harbor listings:

https://www.fairhousingfirst.org/faq/view_all.html​

What you highlighted in yellow would limit your front approach obstructed to 44 in max except for the allowance for one receptacle

Edit side approach obstructed 46 in max

 

[david]

The units in question are definitely Type B (not Type A, or Accessible). Is there a "Safe Harbor" path that can use what is now in the A117.1 2009 or later?

As far as i can tell ADA was updated but the fair housing act references the 2003 ANSI 117.1

but i'm not sure what difference that makes in your circumstance