T. 6-30-92 DJ 202-PL-161 JUL 8 1992 DIRECTOR WODATCH Mr. John Baker Customer Service Manager DATE J. L. Industries 4450 West 78th St. Circle Bloomington, Minnesota 55435 DEPUTY Dear Mr. Baker: LIB This letter responds to your correspondence regarding the DATE application of the Americans with Disabilities Act Accessibility Guidelines to semi-recessed and surface-mounted fire extinguishers with respect to compliance with S4.4 Protruding Objects. SPECIAL The ADA authorizes the Department of Justice to provide COUNSEL technical assistance to individuals and entities with rights or BREEN obligations under the Act. This letter provides informal guidance to assist you in understanding the ADA accessibility DATE standards. However, this technical assistance does not constitute a legal interpretation of the statute and it is not binding on the Department. First, you note a potential conflict between fire codes that BLIZARD require the installation of portable fire extinguishers and the ADA requirement, which prohibits projections of more than four DATE inches when the leading (bottom) edge of the object is between 27 inches and 80 inches above the floor. Although fire extinguishers traditionally are mounted with the top at 60 to 72 inches above the floor, if the local fire code does not specifically prohibit a lower installation, the required fire HARLAND extinguishers can be mounted with the lower edge of the protrusion at 27 inches above the floor. When the leading edge DATE is at or below 27 inches, the presence of the object can be detected in the normal sweep of a long cane used by many individuals who are blind, and the projection of the object can cc: Records, Chrono, Wodatch, Harland, FOIA udd:Harland.Baker 01-01004 - 2 - be more than 4 inches. Mounting the extinguisher lower on the wall also has the incidental advantage of assuring that the highest operable part (the door handle) is within the reach range of a person who uses a wheelchair, as required by S 4.27.3. Secondly, you ask if the protrusion of the door handle could be exempted from being considered as part of the allowable projection. The ADA standards do not specifically exempt hardware or other operating mechanisms from the requirements for protruding objects in S 4.4.1; therefore, the protrusion of the handle would have to be considered as part of the allowable total. If you choose to mount the semi-recessed cabinet with its lower edge at 27 inches, the projection of the handle is no longer a problem. I hope this information is useful to you and will assist you in understanding and applying the requirements of the ADA. Sincerely, John L. Wodatch Director Office on the Americans with Disabilities Act 01-01005 J.L. INDDUSTRIES 4450 West 78th St. Circle Bloomington, Minnesota 55435 Phone 612/835-6850 Fax (612) 835-2218 April 20, 1992 Ms. Barbara S. Drake Deputy Assistant Attorney General Civil Rights Division U.S. Department of Justice P.O. Box 66118 Washington, D.C. 20035-6118 SUB: Americans with Disabilities Act, Public Law 101-336 Dear Ms. Drake: J.L. Industries is a manufacturer of products for the construction industry. We are writing with two questions of interpretation pertaining to Section 4.4, Protruding Objects, of the ADA Accessibility Guidelines for Buildings and Facilities, as it relates to one of our product lines, fire extinguishers and fire extinguisher cabinets. Firstly, the most commonly used fire extinguishers on the market (5 lb. and 10 lb. multi-purpose dry chemical) have cylinder diameters ranging from 4-1/4" to 6", dimensions which exceed the allowable projection of 4", per 4.4.1. To be sure, in most cases these units will be housed in metal cabinets, which are then partially recessed into the wall and usually result in a projection of less than 4". However, there are many instances in which an interior wall will not be thick enough to accommodate a recessed cabinet, necessitating, then, the mounting of the extinguisher in a special bracket on the surface of the wall. APR 30 1992 01-01006 This will generally project beyond the allowable amount - yet, to delete the fire extinguisher would be to violate the local or national fire code. It would therefore appear that the potential exists for a conflict between the ADA and the fire codes. Our first question concerns how such a conflict would be addressed. Secondly, most fire extinguisher cabinets are equipped with door- operating hardware, e.g., a pull handle which, in a very small area, projects beyond the surrounding face of the cabinet. (Please note the enclosed drawings which illustrate this). Our second question is, Could such door-operating hardware be exempted from the 4" maximum projection as stipulated in Section 4.4.1? In other words, provided the cabinet itself conforms to the 4" rule, could the hardware only then project beyond the 4"? Thank you very much for considering these matters. I look forward to your early reply. Respectfully, John Baker Customer Service Manager JB/ske cc: Kirby Bayerle VP Sales & Marketing 01-01007 J. L. INDUSTRIES 4450 W. 78th St. Circle Bloomington, Minnesota 55435 (Form) SEMI-RECESSED CABINET Phone 612/835-6850 SCALE 1:4 FAX 612/835-2218 01-01008