The problem with Kitchens in the 2010 ADA Standards

This information is out of date. Refer to RAS Bulletin 2012-01 for more info.

First let’s look at what the Standards say to do:

212.2 Kitchens and Kitchenettes. Kitchens and kitchenettes shall comply with 804.

804.5 Storage. At least 50 percent of shelf space in storage facilities shall comply with 811.

811.3 Height. Storage elements shall comply with at least one of the reach ranges specified in 308.

308.3.1 Unobstructed. Where a clear floor or ground space allows a parallel approach to an element and the side reach is unobstructed, the high side reach shall be 48 inches (1220 mm) maximum and the low side reach shall be 15 inches (380 mm) minimum above the finish floor or ground.

Ok, simple enough. 50% of the shelves shall be with 15″ and 48″. And I have been told by the Access-Board that we should measure linear feet of shelves. No problem.

Let’s take a look at a typical breakroom kitchenette with counter-top, sink, dishwasher and storage.

Well, that doesn’t seem to work. I don’t have enough shelf space to make up for the upper cabinets and I’m only counting 2 shelves in the upper cabinets. Let’s try to add a pantry to make this work.

Dangit! 4-1/2′ short. Guess I’ll have to lose even more counter space to get this done.

Now this is just ridiculous. I guess the only way to comply is to have very little vertical clearance at each shelf or eliminate the upper cabinets. Or we could just pretend there is only one shelf in the upper cabinets.

Any ideas?


11 Responses to The problem with Kitchens in the 2010 ADA Standards

  1. Let’s pretend that if we have the same amount of lower cabinets as upper cabinets we are good. Would that fly? I can’t even reach the uppper upper cabinets anyway…so I wouldn’t even count them as storage for anyone under 5′-0″!

    • jeromymurphy says:


      I think one solution is to apply this rule only to the general usage shelves and to not apply it to upper cabinets used for bulk storage.

      The same cabinets in a workroom are exempt.

  2. Julie Gereda says:

    I guess the only way to fully comply may be to eliminate some of the top cabinets – ?

    • jeromymurphy says:

      I spoke with someone at the DOJ ADA hotline regarding this issue. She agreed that upper cabinets used for bulk storage or locked cabinets could be excluded from the count. The 50% should apply to the shelves provided for common use. Adding pull out shelves and lazy-susans in base cabinets can multiply the available shelf space and creatively get you over the 50%.

  3. SB says:

    Two solutions. 1. You have to wrap your base cabinets to the adjacent wall to achieve this requirement IF you have an integrated sink and/or dishwasher. 2. Use a wall mounted sink verses integrated to meet the requirement. Both are added costs for materials and programing space.

    • jeromymurphy says:

      That would work until your client wants to use the wall space over those additional base cabinets for more upper cabinets.

  4. SB says:

    Or better yet, how do they define “storage facility”? If you are designing a school or office building, neither one of these would be classified as a storage facility in the local building code, therefore 804.5 would not apply given the specific classification language.

    • jeromymurphy says:

      But this is specific to kitchens, not storage in general. A kitchenette in a school or office building are subject to the same rules.

  5. Brendan says:

    Hi Jeromy,

    We are struggling with this issue for Type A kitchens in an apartment building. Have there been any developments since you wrote this article? Any guidance beyond just eliminating upper cabinets to make the numbers work out? Any thoughts on why drawers don’t seem to count (or do they?)?

    • jeromymurphy says:

      This would not apply to a Type A unit in typical market rate housing. Per ANSI A117.1 2003 only a clear floor space is required at the storage and there is no mention of height.

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