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2012 TAS Chapters 2, 8, and 9

Lesson 8: Kitchens, dwelling units, and built-in elements

TAS 804, 809, 811, 902, and 904, plus the 233 scoping table that decides which residential facilities apply them · 14 practice questions

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Chapter 8 of the 2012 Texas Accessibility Standards, Special Rooms, Spaces and Elements, turns from general building blocks toward specific room types: kitchens and kitchenettes, and the residential dwelling unit treated as a whole space with its own internal accessible route. Chapter 9's built-in elements add the work surfaces and counters GCHS prices out on rehab and inspection work. This lesson also covers Section 233, the Chapter 2 scoping table deciding which residential facilities have to build any of this, and how it relates to the limits on TAS coverage from lesson 1.

Kitchen and kitchenette clearance: Section 804.2

Section 804.1 requires any kitchen or kitchenette a facility provides to comply with Section 804. Section 804.2 sets the clearance between opposing counters, appliances, or walls, and the number depends on the layout. A pass-through kitchen, with two entries and counters, appliances, or cabinets on opposing sides, needs 40 inches minimum clearance. A U-shaped kitchen, enclosed on three contiguous sides, needs 60 inches minimum. Spaces that do not provide a cooktop or conventional range are excepted from 804.2. Applying the 40-inch pass-through figure to a U-shaped galley is exactly the kind of measurement error that fails an otherwise-workable kitchen on paper.

Kitchen work surface, sink, and storage: Sections 804.3 through 804.5

Section 804.3 requires, in residential dwelling units that must comply with Section 809, at least one section of counter 30 inches wide minimum to serve as the kitchen work surface, mounted no higher than 34 inches above the finish floor, or adjustable from 29 to 36 inches, with knee and toe clearance underneath complying with Section 306 from lesson 2. Section 804.4 requires the kitchen sink to comply with Section 606, the same standard governing an accessible bathroom sink. Section 804.5 requires at least 50 percent of a kitchen's shelf and storage space to comply with Section 811, covered later in this lesson, so half of the cabinet and shelving a homeowner actually uses has to sit within a reachable height, not just the counter.

Key numbers: kitchen clearance and fixtures

804.2 pass-through kitchen: 40 in. minimum clearance. 804.2 U-shaped kitchen: 60 in. minimum clearance. 804.3 work surface (dwelling units under 809): 30 in. wide minimum section, 34 in. high maximum (or adjustable 29-36 in.). 804.4 sink: complies with Section 606. 804.5 storage: at least 50 percent of shelf space complies with Section 811.

Kitchen appliances: Section 804.6

Section 804.6 requires clear floor space at each kitchen appliance a wheelchair user needs to approach and use, with controls mounted within a reach range complying with Section 308 and operable under Section 309, both covered in lesson 2. A dishwasher needs clear floor space adjacent to its door. A range or cooktop with knee space underneath needs the underside insulated or otherwise configured so a seated user is not burned. A side-hinged oven door needs the Section 804.3 work surface next to its latch side, and a bottom-hinged door needs it beside one side of the door. A refrigerator-freezer needs at least 50 percent of its freezer storage positioned no higher than 54 inches above the floor. Each of these is a small, specific fix on a rehab job, not a wholesale kitchen redesign.

Residential dwelling units: the route and turning space inside the unit, Sections 809.1 through 809.2.2

Section 809.1 states that a dwelling unit required to provide mobility features must comply with 809.2 through 809.4. Section 809.2 requires an accessible route under Chapter 4 within the unit itself, not just up to its front door. Section 809.2.1 requires that route to connect all spaces and elements of the unit, and Section 809.2.2 requires every room it serves to provide a turning space complying with Section 304, the same space from lesson 2 and lesson 3. A unit is not accessible just because a wheelchair user can get in the front door; the standard follows room to room.

Residential dwelling units: kitchen, bathrooms, and communication features, Sections 809.3 through 809.5

Section 809.3 requires a kitchen inside a covered dwelling unit to comply with Section 804, so nothing about being inside a residential unit changes the numbers already covered. Section 809.4 requires at least one bathroom to comply with Section 603, with no fewer than one of each fixture type meeting applicable requirements, with the fixtures located in the same toilet and bathing area, tying back to lesson 6. Section 809.5 covers communication features for a unit required to provide them: building fire alarm wiring and visible alarm appliances, smoke detection notification, a hard-wired doorbell with an audible tone and visible signal, a way to see a visitor without opening the entry door (180 degree range of view), and, where an entry voice-communication system exists, compliance with Section 708.4.

Residential facility scoping: Section 233, and how it relates to lesson 1

Section 233.1 names group homes, halfway houses, shelters, and similar social service center establishments that provide temporary sleeping accommodations or residential dwelling units that are subject to these standards. Section 233.2 says entities subject to HUD's Section 504 regulations comply with those HUD regulations in lieu of these standards. For a non-HUD entity's new construction, Section 233.3.1.1 requires at least 5 percent of units, no fewer than one, to provide mobility features complying with 809.2 through 809.4, and Section 233.3.1.2 requires at least 2 percent, no fewer than one, to provide communication features complying with 809.5. For additions (233.3.3), the 233.3.1 minimums apply only to the added units until the total meets the minimum; altered units have their own requirements (233.3.4); and Section 233.3.5 requires these units to be dispersed among the various unit types rather than clustered.

Section 233 is not a stand-alone section. It sets only the minimum number of residential dwelling units that must comply with Chapter 8, and its advisory says residential facilities must also meet the rest of TAS. Whether a given residential building is subject to TAS at all is a coverage question for TDLR's rules in 16 TAC Chapter 68, covered in lesson 1, not something Chapter 8 or Section 233 answers. The federal Fair Housing Act is a separate framework: the advisory to 233.1 describes it as requiring accessible and adaptable design in certain residential structures with four or more multifamily dwelling units, so it is not aimed at a single-family home. GCHS should confirm which rules and funder requirements apply to each project rather than assume that TAS or the Fair Housing Act does.

Key numbers: Section 233 scoping

233.1: group homes, halfway houses, shelters, and similar social service center establishments. 233.2: HUD Section 504-covered entities follow the HUD regulations instead. 233.3.1.1 and 233.3.1.2, new construction by a non-HUD entity: at least 5 percent of units (no fewer than one) with mobility features (809.2-809.4); at least 2 percent (no fewer than one) with communication features (809.5).

Storage: Section 811

Section 811.1 requires storage a facility provides, shelving, cabinets, closets, and similar built-in storage, to comply with Section 811. Section 811.2 requires a clear floor or ground space complying with Section 305 in front of it. Section 811.3 requires it to comply with at least one reach range in Section 308. Section 811.4 requires any operable part, a cabinet pull or closet rod mechanism, to comply with Section 309. This is the section 804.5's kitchen storage rule points to, and it applies the same way to a linen closet outside the kitchen.

Work surfaces and counters: Sections 902 and 904

Section 902.3 sets the height of a dining or work surface at 28 to 34 inches above the finish floor; the kitchen work surface in 804.3 has its own limit, 34 inches maximum. Section 904 covers several built-in counter types outside a kitchen, and this lesson takes two of them. Section 904.3.2 caps a check-out aisle counter's surface at 38 inches maximum, with edge protection on the aisle side no more than 2 inches above it. Section 904.4.1 requires a sales or service counter's parallel approach portion to be at least 36 inches long, 36 inches high maximum. Section 904.4.2 requires its forward-approach portion to be at least 30 inches long, also 36 inches high maximum, with knee and toe clearance underneath. A front desk GCHS evaluates at a community facility is checked against 904, not the kitchen counter numbers in 804.

Pass-through and U-shaped kitchen clearances Plan views of two kitchen layouts under TAS 804.2: a pass-through kitchen open at both ends needs 40 inches minimum clearance between opposing counters, appliances, or walls; a U-shaped kitchen enclosed on three sides needs 60 inches minimum clearance. A note below gives the kitchen work surface height under 804.3, 34 inches maximum or an adjustable 29 to 36 inches, and the check-out aisle counter height limit under 904.3.2, 38 inches maximum. Pass-through kitchen (open both ends) Counter / appliances Counter / appliances 40 in. min. clearance (804.2) U-shaped kitchen (enclosed 3 sides) Counter / appliances 60 in. min. clearance (804.2) Kitchen work surface (804.3): 30 in. wide min., 34 in. high max., or adjustable 29-36 in. Dining/work surfaces (902.3): 28-34 in. high. Check-out aisle counter (904.3.2): 38 in. max.
Kitchen layout decides the clearance number: 40 inches minimum for a pass-through kitchen, 60 inches minimum for a U-shaped kitchen, both under Section 804.2.

Why this matters for GCHS

GCHS runs into these numbers on kitchen remodels for elderly and low-income homeowners: measuring the gap between a new run of cabinets, checking a replacement counter's height, or confirming that shelving a homeowner actually uses sits within reach. On a group-home or shelter-type project, the Section 233 percentages decide how many units need mobility and communication features at all, before any 809 or 804 dimension gets checked. On an ordinary private home, checking coverage under 16 TAC Chapter 68 and the funder's own requirements before citing TAS or Section 233 keeps GCHS from citing the wrong standard to a homeowner or a funder.

Practice questions

1. A GCHS evaluator measures 36 inches of clear floor space between the base cabinets on opposite walls of a pass-through kitchen with a conventional range (open to the dining area at the far end and to the hall at the near end). Is this compliant with Section 804.2?

  1. No; a pass-through kitchen with a range needs 40 inches minimum clearance between opposing counters, appliances, or walls
  2. Yes, because a pass-through kitchen only needs 36 inches, the same width as an accessible route, when it has two entries
  3. Yes, because clearance under 804.2 is required only in U-shaped kitchens and pass-through kitchens are left to the designer
  4. No, because a pass-through kitchen must instead provide 60 inches of clearance, the same as a U-shaped kitchen

2. A U-shaped kitchen with a cooktop, enclosed by counters on three contiguous sides, measures 54 inches of clearance between the opposing runs. Is this compliant?

  1. Yes, because a U-shaped kitchen uses the same 40-inch minimum as a pass-through kitchen, and 54 inches exceeds it comfortably
  2. No; a U-shaped kitchen with a cooktop needs 60 inches minimum clearance between opposing runs
  3. No, because U-shaped kitchens are not addressed by TAS, so the evaluator has nothing to measure against
  4. Yes, 54 inches exceeds any reasonable clearance

3. Under Section 804.3, in a dwelling unit required to comply with Section 809, what width and height requirements apply to the required kitchen work surface?

  1. There is no minimum width; only a height limit applies
  2. At least 30 inches wide, mounted no higher than 34 inches above the floor, or an adjustable surface between 29 and 36 inches
  3. At least 24 inches wide, mounted no higher than 30 inches above the floor, with a fixed height that may not be adjustable at all
  4. At least 36 inches wide, with no height limit, as long as knee and toe clearance is provided underneath

4. Under Section 804.4, which TAS section governs an accessible kitchen sink?

  1. Section 603
  2. Section 604
  3. Section 606
  4. Section 608

5. Under Section 804.5, what portion of kitchen shelf and storage space must comply with Section 811, and what does 811 itself require?

  1. 100 percent of shelf space; Section 811 applies only to closets, not kitchens
  2. There is no shelf-space requirement; only counters are regulated
  3. 25 percent of shelf space; Section 811 sets only a maximum shelf depth
  4. 50 percent of shelf space; Section 811 requires clear floor space, a reach-range-compliant height, and reach-compliant operable parts

6. Under Section 804.6, what must TAS-covered kitchen appliances provide?

  1. Nothing, because appliances a homeowner supplies are excluded from Chapter 8 and only cabinets are regulated
  2. A grab bar mounted beside each appliance, at least 36 inches long and 33 to 36 inches above the floor
  3. Clear floor space at each appliance, with controls mounted within a compliant reach range
  4. A sink adjacent to every appliance

7. Under Sections 809.2 through 809.2.2, what must a residential dwelling unit required to provide mobility features include inside the unit itself?

  1. A turning space only in the kitchen
  2. An accessible route, but no turning space requirement
  3. An accessible route connecting all spaces and elements of the unit, with a turning space complying with Section 304 in every room the route serves
  4. Only an accessible entrance door; interior rooms are not regulated

8. Under Section 809.3, where a covered residential dwelling unit includes a kitchen, what standard applies?

  1. A separate residential-only kitchen standard in Section 809.3 that has its own clearances and no cross-reference to other sections
  2. Section 804, the same kitchen and kitchenette requirements covered earlier in this lesson
  3. No standard; unit kitchens are exempt
  4. Section 902, the dining and work surface section, which sets every kitchen requirement for units

9. Under Section 809.4, how many bathrooms and fixtures must be accessible in a covered residential dwelling unit, at minimum?

  1. Only the bathroom nearest the kitchen, and only its water closet and lavatory, since tubs, showers, and other fixtures are not covered by Section 809.4
  2. At least one bathroom complying with Section 603, with one of each fixture type provided meeting applicable requirements
  3. Every bathroom and every fixture in the unit, since Section 809.4 has no minimum-count language
  4. None; bathrooms inside dwelling units are exempt

10. Which of these is an example of a communication feature required under Section 809.5 in a covered residential dwelling unit?

  1. A wider entry doorway, at least 36 inches clear, so a wheelchair user can pass through
  2. A lower kitchen countertop, with a section 34 inches high maximum and knee space underneath
  3. A second turning space in the bedroom, in addition to the turning space required elsewhere in the unit
  4. Perceivable notification, such as a visible smoke alarm signal or a doorbell with a visible signal

11. Section 233.1 names group homes, halfway houses, shelters, and similar social service center establishments. For new construction by a non-HUD entity, what percentages of units, at minimum, must provide mobility features (809.2-809.4) and communication features (809.5) respectively, under 233.3.1.1 and 233.3.1.2?

  1. 5 percent (no fewer than one) mobility features; 2 percent (no fewer than one) communication features
  2. 2 percent (no fewer than one) mobility features; 5 percent (no fewer than one) communication features
  3. 50 percent of all units, with no distinction between feature types
  4. 10 percent (no fewer than one) mobility features; 10 percent (no fewer than one) communication features

12. Under Section 902.3, what is the height range for the top of a dining surface or work surface above the finish floor?

  1. 30 to 36 inches
  2. 34 to 40 inches
  3. 28 to 34 inches
  4. 24 to 30 inches

13. A GCHS evaluator measures a check-out aisle counter at 39 inches above the finish floor. Is this compliant with Section 904.3.2?

  1. Yes, because 904.3.2 allows a check-out counter surface up to 40 inches when edge protection is provided
  2. Yes, because check-out counters have no height limit
  3. No, because check-out aisles are prohibited under TAS
  4. No; Section 904.3.2 caps the check-out aisle counter surface at 38 inches maximum

14. A GCHS evaluator is asked whether Chapter 8's kitchen requirements (804 and 809) automatically apply to the kitchen of a privately funded single-family home being rehabbed for an elderly homeowner. What is the sound answer?

  1. Not automatically. TDLR's rules in 16 TAC Chapter 68 decide whether TAS covers the building, and Section 233 only counts units
  2. No, because kitchens are never covered by any accessibility law, and no funder or agency can require accessible features in a rehab
  3. Yes, because Section 233 sets percentages that apply to every residence, so every single-family rehab must reserve part of its rooms for mobility features
  4. Yes, 804 and 809 always apply to any residential kitchen regardless of ownership, funding, or the type of building

Glossary

Pass-through kitchen
A kitchen open to an adjoining space at both ends; needs 40 inches minimum clearance between opposing counters, appliances, or walls under Section 804.2.
U-shaped kitchen
A kitchen enclosed by counters, appliances, or walls on three contiguous sides; needs 60 inches minimum clearance under Section 804.2.
Residential dwelling unit
A self-contained residential space regulated under Section 809, with its own internal accessible route, turning space, kitchen, bathroom, and communication feature requirements when required to provide mobility features.
Communication features
Perceivable notification features, such as visible smoke-alarm signaling, a doorbell with a visible signal, a way to see a visitor without opening the door, and compliant entry voice-communication systems, required under Section 809.5.
Section 233 residential facility scoping
The Chapter 2 provisions setting what share of units in facilities such as group homes, halfway houses, and shelters must provide mobility and communication features; whether TAS covers a residential building at all is decided by TDLR's rules in 16 TAC Chapter 68, covered in lesson 1.
Check-out aisle counter
A retail check-out counter surface capped at 38 inches maximum above the finish floor under Section 904.3.2, distinct from a sales or service counter under 904.4.