Counter Measures: Codes

pg. 5 mikiten

Erick Mikiten, AIA LEED-AP Mikiten Architecture

Erick Says:

As a wheelchair rider, I often encounter problems at service counters. Sometimes it’s a design shortcoming, but often it’s a management issue that crops up after final inspection. The California Building Code (CBC) defines four related counters: service counters, check out aisles, point-of-sale devices and dining surfaces. Let’s look at some common problems, and then talk about how you can prevent them.


Here’s what it looked like from my point of view.

Design Issues
Here’s a service counter at an Amtrak station I was at recently. A tiny accessible counter is on the left, but the agent can’t see it or reach it, so there’s no place for an actual transaction between a wheelchair riding customer and the agent!

Maybe the designer thought just having a check-writing spot was good enough, but that’s not the code’s intent. This was clearly a design problem for the architect to solve.

How about this Clipper Card kiosk at the Powell Street BART, with (amazingly) no low counter at all? And the sloping face makes it even more difficult to interact with the employees behind it.

It’s brand new, and apparently the kiosk designer didn’t know the code. If you, as an architect, show a counter or point of sale location on your drawings, note that it must be accessible, so that the fabricator has guidance.

Usage & Maintenance
A more common problem is that the required accessible portion of the counter is pushed to the side, or tacked onto the ‘real’ counter, so employees think it’s for them. They clutter it up with cutlery, napkins, recycling bins and more. Some examples:codes4 codes6

11B-108 of the CBC requires that owners and operators ensure “maintenance of accessible features.” But if employees don’t know something’s a required accessible feature, how can they maintain its availability?

I’ve asked many dozens of employees whether they know why the counter is there and maybe 5% do. I recently found a rare uncluttered low dining counter at a restaurant but three employees insisted that it was for take-out use only and that I couldn’t sit there. I prevailed after an unpleasant debate but the restaurant probably reverted back when I left.

codes7 There are two things the architect can do:

First, design the accessible counter so that it is experienced from the employee point of view as space for a transaction. Here’s a great counter at Berkeley’s Ed Roberts Campus. High and low areas have equal dimensions, the employee can alternate sitting and standing for comfort, the purpose is clear, and it welcomes everyone. Second, wherever the purpose of the space could be ambiguous, you can add signage like this to clarify it.codes8

This idea of instructional signage is useful in many places. In accessible restrooms (that often become storage rooms) I put signage saying “No storage permitted within this accessible restroom, except if located higher than 80” above the floor.”

Instructional signage is being discussed for a future version of the CBC, but as architects who want our well-designed accessibility features to actually be available to the people who need them, we should be proactive and place signs like these in our buildings. This gives employees – and the people who need the features – a fighting chance.

Counter Dimensions Summary:
See Division 2 for scoping requirements (when you need them). Division 9 gives detailed requirements for Built-in Elements. They all need to be adjacent to an accessible Walking Surface as defined in Division 4.
1. Section 11B-227 & 904.8 – Check-Out Aisles:
A. Maximum 38” high with maximum lip 2” high on the aisle side (think: edge of a grocery checkout
conveyor belt.)
B. Check-writing surface: 28” to 34” high.
C. 4” x 4” International Symbol of Accessibility (ISA) at accessible check-out aisle (when not all
aisles are accessible
2. Section 11B-227.3 & 904.4 – Sales and Services Counters: At least 36” long, no more than 34” high,
with the accessible position the same depth as the rest of the counter. (Sorry, Amtrak!).
A. Parallel approach: Center the long side of a 30”x48” clear floor space with the counter.
B. Forward approach: This is preferred, as it lets the user face the employee. Knee and toe clear
ance required. Center the short side of the clear floor space on the counter.
3. Section 11B-227 &904 – Point-of-Sale Devices: Must comply with 11B-309 (Operable Parts),
30”x48” clear floor space, with display screen requirements similar to ATM machines.
4. Section 11B-226, 227.4 & 902 – Dining Surfaces: Minimum 5 percent of seating and standing spaces must have clear floor space with forward approach and knee/toe clearance. Tops between 28”
and 34” high. These also apply to work surfaces provided for use by customers.


Kerwin Lee, AIA CASp ICC -Certified Accessibility Inspector and Plan Examiner ICC – Certified Building Plan Examiner

Kerwin says:

The code is silent or lacks a lot of details as to how accessible a counter needs to be. Not all counters require full accessibility. A service or point of sales counter may only required enough space to write a check or sign a charge slip, although the signing of charge slips has given way to the point of sales machines (debit and credit sales). A transaction counter at a bank can require a lot of paper work as well as exchange of information. A higher level of access and usability is required here. If the client or designer of the Clipper Card Booth in Erick’s example serves only the function of giving out information, perhaps a transaction counter is not necessary. If people can sign up for clipper cards at the booth, requiring paper work, then there is something lacking. It is up to the owner/operator and designer to determine how much access is required functionally to meet the needs of the facility or location but always error on the side of providing (more) access.

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