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Interesting articles about ADA, FHA, and ABA compliance inspections by ADA Inspections Nationwide, LLC.

Self-Service Shelving and the ADA - Be Careful Where you Look

Self Service Shelving in a Retail Establishment

Self Service Shelving in a Retail Establishment

Self-service shelving is covered in the Americans with Disabilities Act (ADA) in more than one place. It is important to be careful where you look.

2010 ADA Standard 225.2.2, Self-Service Shelving, states, “Self-service shelves shall be located on an accessible route complying with [Standard] 402. Self-service shelving shall not be required to comply with [Standard] 308.” Standard 308 covers reach ranges. The photo on the right is representative of self-service shelving in a retail establishment, or store.

Advisory 225.2.2, Self-Service Shelving, states, “Self-service shelves include, but are not limited to, library, store, or post office shelves.” So according to this Standard and Advisory self-service shelving never has to comply with Standard 308 for reach ranges.

However, 2010 ADA Standard 227.4, Food Service Lines, states, “Food service lines shall comply with [Standard] 904.5. Where self-service shelves are provided, at least 50 percent, but no fewer than one, of each type provided shall comply with [Standard] 308.”

2010 ADA Standard 904.5.1, [Food Service Lines] Self-Service Shelves and Dispensing Devices, states, “Self-service shelves and dispensing devices for tableware, dishware, condiments, food and beverages shall comply with [Standard] 308.”

So clearly this is a case at food service lines when self-service shelving has to comply with Standard 308. The graphic below is representative of self-service shelving in a food service line.

Self-Service Shelving in a Food Service Line

Self-Service Shelving in a Food Service Line

2010 ADA Standard 308.3.1, [Side Reach] Unobstructed, states, “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.” An exception for this Standard is that an obstruction shall be permitted between the clear floor or ground space and the element where the depth of the obstruction is 10 inches (255 mm) maximum. The graphic below is representative of this Standard and exception.

Side Reach Range Over Small Object

Side Reach Range Over Small Object

Plus, there is always a requirement to provide reasonable accommodations for disabled individuals. Items placed on shelving that is more than 48 inches above the finished floor should have a method for disabled individuals to access those items if they are different from those items less than 48 inches above the finished floor.

SUMMARY

Most self-service shelving does not have to comply with the ADA Standards for reach ranges, except for self-service shelving in food service lines. However, the requirement for reasonable accommodations can override this issue and should be taken into account in a facility.

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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.

Thank you.