A few questions from a client regarding sinks in break rooms.

August 7, 2012

From: Brad Pitt, Architect (honorary)

Sent: Monday, August 06, 2012 5:37 PM

To: Jeromy Murphy [jmurphy@acico.com]

Subject: Accessibility Question-Knee Space under Sinks

We are trying to get proper interpretation on the attached bulletin.

In summary:

  • A Break Room with a sink but without “Cooking Facilities” is not required to have Knee Space
  • Any room with at least one fixed or built-in cooking facility including microwave ovens is considered a kitchen and therefore the sink needs knee space
  • A portable countertop Microwave Oven is not considered a Cooking Facility since it is not fixed or built-in
  • Sinks in Break Rooms with no other cooking facility except a portable countertop microwave oven does not require knee space

Are these statements correct?

Your best buddy,

Brad

————————————————————————-

From: Jeromy Murphy [jmurphy@acico.com]

Sent: Monday, August 06, 2012 5:37 PM

To: Brad Pitt, Architect (honorary)

Subject: re: Accessibility Question-Knee Space under Sinks

Brad,

So good to hear from you. See my answers in red below. Note that these are NOT my interpretations, they are directly from TDLR.

      • A Break Room with a sink but without “Cooking Facilities” is not required to have Knee Space. False. 606.2(Exception 1) only applies to sinks located in “Kitchens” or “Wet Bars”. Because a break room is neither a kitchen nor a wet bar, the knee clearance is required (ridiculous, I know).
      • Any room with at least one fixed or built-in cooking facility including microwave ovens is considered a kitchen and therefore the sink needs knee space. True, but…If there is only a microwave, you can apply 606.2(Exception 1) and not provide the knee clearance. If it’s a non-fixed microwave, you can still call it a kitchen, but then you must meet the 50% storage and other kitchen requirements.
      • A portable countertop Microwave Oven is not considered a Cooking Facility since it is not fixed or built-in. Truish. These Standards only address fixed or built-in elements. If dedicated circuits or shelves are provided for a microwave, it could still be considered a kitchen.
      • Sinks in Break Rooms with no other cooking facility except a portable countertop microwave oven does not require knee space. False. As described, this is not a kitchen nor a wetbar, therefore 606.2(Exception 1) cannot be applied.

See you this Thanksgiving,

Jeromy

For reference:

606.2 Clear Floor Space. A clear floor space complying with 305, positioned for a forward approach, and knee and toe clearance complying with 306 shall be provided.

EXCEPTIONS: 
1. A parallel approach complying with 305 shall be permitted to a kitchen sink in a space where a cook top or conventional range is not provided and to wet bars.