Are built-in shoe shine stands required to be accessible?

May 27, 2009
This post references the Texas Accessibility Standards, but on this issue the ADAAG is the same.

“Is it built-in?” If no, then there are no requirements since TAS does not apply to furniture.

Assuming that it is built-in and therefore subject to TAS, we could look to section 4.32 for fixed or built-in seating and tables. The first section of the chapter reads:

4.32.1 General.(1) Fixed or built-in seating or tables required to be accessible by 4.1 shall comply with 4.32.

Let’s take a look at 4.1 to see if shoe-shine stands are mentioned……flip, flip, flip….flip….

4.1.3(18) If fixed or built-in seating or tables (including, but not limited to, study carrels and student laboratory stations), are provided in an accessible public or common use area, at least five percent (5%), but not less than one, of the fixed or built-in seating areas or tables shall comply with 4.32. An accessible route shall lead to and through such fixed or built-in seating areas, or tables.

Ok, back to 4.32. …..flip (good thing I kept my finger on the page)…. Here are the remaining sections of 4.32:

4.32.2 Seating. If seating spaces for people in wheelchairs are provided at fixed tables or counters, clear floor space complying with 4.2.4 shall be provided. Such clear floor space shall not overlap knee space by more than 19 in (485 mm) (see Fig. 45).

4.32.3 Knee Clearances. If seating for people in wheelchairs is provided at tables or counters, knee spaces at least 27 in (685 mm) high, 30 in (760 mm) wide, and 19 in (485 mm) deep shall be provided (see Fig. 45).

4.32.4* Height of Tables or Counters. The tops of accessible tables and counters shall be from 28 in to 34 in (710 mm to 865 mm) above the finish floor or ground.

None of these sections impose a requirement on the shoe-shine stand since there are no tables or counters provided. Therefore, the only thing necessary to comply would be to have an accessible route to the stand.