Accessible Paper Towel Dispensers in Toilet Rooms
Paper Towel Dispenser Too High Above the Finished Floor and Protruding More Than 4 Inches from the Wall
Paper towel dispensers in toilet rooms can be a source of non-compliance of the Americans with Disabilities Act (ADA) for Title II and III facilities. Common violations can include dispenser actuators mounted too high above the finished floor and dispensers that protrude into the circulation path. The photo on the right shows an actuator with both violations. This dispenser extends approximately 9 inches from the wall and it is not within the 27-inch detection zone for protruding objects. The actuator is more than 48 inches above the finished floor.
The 2010 ADA Standards require wall-mounted elements that are mounted more than 27 inches and less than 80 inches above the finished floor to extend 4 inches or less from the wall. 2010 ADA Standard 307.2, Protrusion Limits, states, “Objects [elements] with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finish floor or ground shall protrude 4 inches (100 mm) maximum horizontally into the circulation path.” The 1991 ADA Standard for this requirement is similar. The graphic below is representative of these Standards.
Protruding Objects Limitations
When a cane is used and the element is in the 27-inch detectable range, it gives a person sufficient time to detect the element with the cane before there is body contact. Elements located on circulation paths, including operable elements such as paper towel dispensers, must comply with requirements for protruding objects. This requirement exists throughout a Title II and Title III facility, including within toilet rooms.
The actuators must be within the reach ranges of the ADA Standards. The reach ranges in the 2010 ADA Standards limit these actuators, also known as operable parts, to 15-48 inches above the adjacent finished floor for a forward or side approach. The 1991 ADA Standards also limit the actuators, known as operating mechanisms, to 48 inches above the adjacent finished floor, or 54 inches if the reach is from a side approach not over an obstruction. For most installations the limit will be 15-48 inches above the finished floor because of the requirement to remove barriers to accessibility regardless of the age of the installation.
There are installations that will satisfy these requirements. One is to install a combination paper towel dispenser and waste receptacle that is recessed into the wall. The photo below is representative.
Recessed Toilet Paper Dispenser and Waste Receptacle
Another installation is installed within an alcove with the waste receptacle below. See the photo below.
Paper Towel Dispenser and Waste Receptacle in Alcove
In each example above the actuator needs to be no more than 48 inches above the finished floor.
SUMMARY: Paper towel dispensers in toilet rooms can be a source of non-compliance of the ADA for Title II and III facilities. Recessed dispensers can avoid violations of the ADA for protruding objects and height above the finished floor.
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