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Protruding Objects as Defined by the ADA - Basic

Protruding objects are common discrepancies in facilities where the American with Disabilities Act (ADA) Standards apply. This article will discuss the basic requirements for protruding objects in State and local government facilities, public accommodations, and commercial facilities, as defined by the ADA.

Protruding objects on circulation paths should comply with the ADA Standards. Circulation paths include any place a person can be, interior and exterior. In other words, protruding object limitations apply everywhere there is a circulation path, NOT just on accessible routes, unless there is an exception in the Standards. There are not many exceptions.

One exception is found in the Architectural Barriers Act (ABA), where a natural element, like a tree, is not considered a protrusion if that natural element is on federal land. Another exception is when within areas of sport activity, protruding objects on circulation paths shall not be required to comply with the Standards. The last exception is when within play areas, protruding objects on circulation paths shall not be required to comply with the Standards provided that ground level accessible routes provide vertical clearance that is in compliance with the Standards.

The protrusion limits are for objects with leading edges more than 27 inches and not more than 80 inches above the finish floor or ground which cannot protrude more than 4 inches horizontally into the circulation path. The only exception is for handrails that are permitted to protrude 4½ inches maximum. The graphic below is representative of the protruding objects limits.

Protruding Objects Limits and Cane Detection Area

Protruding Objects Limits and Cane Detection Area

The logic behind the Protruding Objects limits is that when a cane is used and the element is in the cane detectable range, it gives a person with limited vision sufficient time to detect the element with the cane before there is body contact. Elements located on circulation paths, including operable elements, must comply with requirements for protruding objects. For example, awnings and their supporting structures cannot reduce the minimum required vertical clearance. Similarly, casement windows, when open, cannot encroach more than 4 inches into circulation paths above 27 inches.

A common installation used to avoid the limitations for protruding objects is to recess the element installation. The graphic below is where a drinking fountain is recessed into an alcove so that it does not project out into the circulation path more than 4 inches.

Drinking Fountain Recessed into a Wall

Drinking Fountain Recessed into a Wall

Drinking Fountain in Recessed Alcove

Drinking Fountain in Recessed Alcove

The graphic on the right shows the drinking fountain not more than 4 inches into the circulation path.

Drinking fountains can present a unique situation where they are not recessed in an alcove so they may be a protruding object that must be cane detectable at 27 inches above the finished floor. However, drinking fountains also must allow a forward approach and have space below the fountain for knee and toe clearance, which goes up to 27 inches above the finished floor. The solution is to install the drinking fountain at 27 inches exactly [absolute] above the finished floor, which would then comply with both rules.

The photo below is representative of a protruding object in a grocery store where a scale is installed more than 27 inches above the floor but the pan projects out from the post more than 4 inches.

Grocery Store Produce Scale as a Protruding Object

Grocery Store Produce Scale as a Protruding Object

The photo below is another example where a ticket dispenser is installed more than 27 inches above the floor and extends more than 4 inches from the wall mount. More than 27 inches above the floor places the dispenser above the cane detection zone.

Ticket Dispenser as a Protruding Object

Ticket Dispenser as a Protruding Object

The 80 inch rule comes into play in circumstances where the circulation path goes under an overhead projection such as a step system, plumbing installations, HVAC ductwork, signage, or a curved wall, etc. Vertical clearance must be 80 inches high minimum. Guardrails or other barriers should be provided where the vertical clearance is less than 80 inches high. The leading edge of such guardrail or barrier shall be located 27 inches maximum above the finish floor or ground. The graphic below is representative of the 80 inch rule. An exception to this limit is that door closers and door stops are permitted to be 78 inches minimum above the finish floor or ground.

Step System Protruding Object                                                        Curved Wall Protruding Object

Step System Protruding Object Curved Wall Protruding Object

The installations above are accessible because there is a fixed potted plant under the step system and a fixed guard rail installed under the curved wall that provide cane detectable warnings.

Another common installation that violates the 80 inch rule is when signs are mounted to the ceiling and allowed to hang down too low. The photo below is representative.

Retail Store Ceiling Mounted Sign as a Protruding Object

Retail Store Ceiling Mounted Sign as a Protruding Object

Graphic Illustration of Post Mounted Sign

Graphic Illustration of Post Mounted Sign

Protruding object rules apply to post mounted installations like signs even though these signs may not be fixed to the floor. The graphic on the right demonstrates the danger to a person who is site limited and walking near a sign mounted on a post, and the leading edge of the sign is up near their face.

Free-standing objects mounted on posts or pylons should overhang circulation paths 12 inches maximum when located 27 inches minimum and 80 inches maximum above the finish floor or ground. Where a sign or other obstruction is mounted between posts or pylons and the clear distance between the posts or pylons is greater than 12 inches, the lowest edge of such sign or obstruction shall be 27 inches maximum or 80 inches minimum above the finish floor or ground.

In other words, if the leading edge of the sign is not in the cane detectable area below 27 inches or at least 80 inches above the floor, the sign cannot extend out more than 12 inches from the post, and the space between 2 posts cannot exceed 12 inches. The graphic below is representative of this Standard. An exception for this rule is that the sloping portions of handrails serving stairs and ramps are not required to comply with the Standards.

Protruding Object Limits for Post Mounted Elements

Protruding Object Limits for Post Mounted Elements

Another way to look at the post rules is that post-mounted objects with leading edges 27 inches maximum or above 80 inches can protrude any amount. The graphic below is representative.

Post Mounted Sign Within Cane Detection                        Post Mounted Sign 80 Inches Above Floor

Post Mounted Sign Within Cane Detection Post Mounted Sign 80 Inches Above Floor

Finally, protruding objects should not reduce the clear width required for accessible routes. So even if a protruding object does not violate protruding object rules, it still cannot violate the rules for width of an accessible route.

For a more technical article about protruding objects, please see Protruding Objects as Defined by the ADA - Technical.

In summary, protruding object rules for ADA compliance apply to all circulation paths. These rules are complex and compliance involves detailed inspections of all installations in a facility that can be accessed by disabled individuals.

If you observe a facility that is not ADA compliant and you would like to know how to proceed, please see the link at What To Do When A Building Is Not ADA Compliant or Accessible.

ADA Inspections Nationwide, LLC, offers ADA/ABA/FHA accessibility compliance inspections for buildings and facilities, as applicable to the different laws, and expert witness services with respect to ADA/ABA/FHA laws for building owners, tenants and managers. Also, ADAIN offers consulting for home modifications as a CAPS consultant for people wishing to age in place in their homes. For a complete list of services please see ADAIN Services.

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