In effect, 1138A.3 allows for either 24-inch or 25-inch-deep obstructions depending on whether a side approach or front approach is used. The section on electrical receptacle heights doesn’t go into such details; Section 1136A.1 for receptacle heights simply states: - “Physical barriers and obstructions shall not extend more than 25 inches from the wall beneath the receptacle.”
That means expensive special-order base cabinets would be required for every adaptable unit, i.e. every single-story unit on an accessible route, plus 10 percent of the multistory units for covered dwellings. The standard counter depth with a countertop finish exceeds 25 inches. The standard counter depth in the corner of the countertop exceeds the maximum depth even more.
Generally, kitchen plans will note or somehow refer to reach ranges and accompanying diagrams on a details page, mirroring the diagrams in Section 11A – Figures 11A-1I and 11A-1J. For whatever reason, contractors frequently fail to connect the reach-range diagrams to kitchen counter depths. Electricians typically pay heed to receptacle and switch height requirements but when it comes to ordering kitchen cabinets, requirements for reach ranges don’t seem to play a part. For this reason, inspectors who prefer to head off problems before they occur would be well advised to have a discussion about kitchen counters during roughs. In that discussion, a key talking point must be the reach-range requirement for a 25-inch-maximum countertop. As noted above, Section 1136A for receptacle heights defers to 1138A.3 for reach ranges, which requires – here is a contentious part – knee space under an obstruction up to 25 inches deep. A depth of 25 inches is allowed only for a front approach, which requires clear floor space beneath the obstruction, per 1138A.3.1(2). A maximum depth of 24 inches is required for a side approach. So the inspector should let the contractor know that without mitigating elements, kitchen countertops must be 24 inches deep maximum measured from the wall beneath receptacles. If removable base cabinets or knee space are provided underneath, kitchen countertops can be 25 inches maximum. These dimensions do not include the backsplash unless the receptacle or switch is mounted in the backsplash. Inspectors should be prepared for push-back and, of course, questions. On more than one occasion, a designer has called out a parenthetical reference in 1136A that supposedly clarifies the intended definition of an obstruction, as it states, “for example, a kitchen base cabinet.” Another “example” could be a countertop finish, however. The Housing and Community Development has completed its rulemaking process to issue a change in the next intervening code cycle, allowing for a 25 ½-inch countertop to match the requirements in the Fair Housing Act Design Manual. Commenters cautioned that the change would cause more confusion without more clarification or that 1138A should also be amended, but for now the HCD is simply amending a sentence in 1136A to provide for a maximum physical barrier or obstruction of 25 ½ inches, in contrast with 1138A, which still cites a maximum 25-inch obstruction, and only with clear floor space underneath. Interestingly, the Fair Housing Act Design Manual specifically refers to HUD’s allowance for a 25½ countertop even for a parallel approach. The CBC’s 1136A does not state that the 25 ½ depth will apply to both parallel and forward approaches. Here is a portion of the HCD’s language in a June 2020 Final Statement of Reasons for Rulemaking, in connection with the upcoming intervening code cycle: - “Currently physical obstructions are not permitted to extend beyond 25” from a wall beneath a receptacle, switch, or control, where a countertop is located. HCD’s proposal will allow countertops to extend an additional 1⁄2 inch, for a total of 25.5”. HCD’s proposal aligns with the Fair Housing Act Guidelines and is also consistent with standard industry manufacturing practices. An industry standard commercially available countertop depth often measures up to 25.5” where installed over a standard commercially available 24-inch deep base cabinet and this measurement is already accepted as compliant by many code enforcing agencies. HCD is proposing this amendment to align with current industry and manufacturing practices…”
In addition to omitting which approaches apply with a 25½-inch countertop, Chapter 11A does not address specific requirements for receptacles in corners above countertops. The California Electrical Code requires a receptacle every four feet above a countertop. At least one will have to be located in a corner. If it’s not accessible, and it wouldn’t be, a comparable outlet will have to be provided, per 1136A. This is another issue that should be discussed during roughs. Every above-counter receptacle required by the CEC must be accessible or a comparable outlet provided. It would be a difficult task to find a set of plans that shows compliant locations for accessible receptacles in corners. The Fair Housing Act Design Manual provides a diagram with text stating electrical outlets on walls over cabinets must be a minimum of 36 inches from a corner, but that is not a requirement in the CBC. If an inspector’s jurisdiction chooses to use the Fair Housing Act Design Manual as precedent and intent, as the HCD implies in its rulemaking comments, the kitchen counter depth should be permitted to be 25 ½ inches deep maximum for either a forward or parallel approach. If the more restrictive CBC is to be applied as written, 24 inches is the maximum counter depth for a parallel approach and 25 inches with clear floor space underneath for forward approach, although the intervening code cycle will allow for 25½ inches maximum without specifying an acceptable type of approach. For publicly funded residential buildings, 11B-308 applies. It is clear that 24 inches is the maximum counter depth for a parallel approach and 25 inches with clear floor space underneath for forward approach. |
