T.   12-22-93



								JAN 3 1994



Mr. Richard W. Church
President
Plumbing Manufacturers Institute
800 Roosevelt Road
Building C, Suite 20
Glen Ellyn, Illinois 60137-5833

Dear Mr. Church:

	This letter responds to your correspondence regarding the
application of the Americans with Disabilities Act (ADA) to
drinking fountains.

	The ADA authorizes the Department of Justice to provide
technical assistance and information to individuals and entities
who have questions about the Act or the Department's Standards
for Accessible Design (Standards). This letter provides informal
guidance to assist you in understanding and complying with the
ADA accessibility standards. However, this technical assistance
should not be viewed as legal advice or a legal opinion about
your rights or responsibilities under the ADA.

	The answers to the questions in your letter of September 2,
1993, appear below in like order. In the interest of
conciseness, rather than repeat each question, we enclose a copy
of your letter for your reference.

  A.  You asked for an explanation of the requirement that the
      water flow be within three inches of the front edge of a
      fountain with a round or oval bowl. Recent innovations in
      the design of drinking fountains forced the inclusion of
      this requirement because many individuals who use
      wheelchairs found it impossible to lean far enough over the
      projecting rim of large bowl fountains to take a drink even
      when the fountain was otherwise in compliance with the
      requirements in the Uniform Federal Accessibility Standards
      or the ANSI A117.1 Standard. This problem is alleviated
      when the water stream can be reached within three inches of
      the projecting rim.



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  B.  A drinking fountain that provides for a front approach and
      is mounted 27 inches above the floor or ground surface meets
      the minimum knee space height requirement of Section 4.15.5
      and also satisfies the provision of Section 4.4.1 that when
      the bottom edge of an object is at or below 27 inches above
      the floor, it may project any amount.

  C.  When considering the direction of approach and the
      requirements of Section 4.4.1, if the "hi" section of a "hi-
      lo" fountain presents a hazard as a protruding object, it
      may be necessary to install the fixture in an alcove or to
      provide a cane-detectable element.

  D.  In the Standards, the words "maximum" or "minimum" are never
      specified when there is an allowable range of dimensions.
      This practice does not appear to cause any confusion in
      applying the standard for the height of grab bars or the
      diameter of handrails. We believe that "maximum" and
      "minimum" are implicit in this convention. For example, a
      range of "17 in to 19 in" means a minimum of 17 inches and a
      maximum of 19 inches.

  E.  The requirement for a fountain "at a standard height
      convenient for those who have difficulty bending," can be
      satisfied by applying conventional industry standards such
      as you cite.

	Please feel free to contact the Public Access Section any
time you have questions or need information. The Department
maintains a telephone information line to provide technical
assistance regarding the rights and obligations of individuals,
businesses, agencies, and others covered or protected by the ADA.
This technical assistance is available by calling 202-514-0301
(voice) or 202-514-0383 (TDD) between 1:00 p.m. and 5:00 p.m.,
Monday through Friday.

                                      Sincerely,



                                   John L. Wodatch
                                        Chief
                                Public Access Section

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