I am an architect with a few hundred C-stores under my belt. Fixture suppliers design and build sales and service counters directly for the owners. One owner recently received a huge ADA violation complaint letter (from a law firm) I am helping to resolve. One issue is the sale counter, which is 36” high end to end broken up with a few front facing displays. The complaint alleges violation of the front approach standard, with no toe/knee space nor a 34” high work surface. I am seeing some references and your NATSO article that implies an accessible cashier/transaction counter can be 36” long, 36” high and allow for a 48×30 wheelchair space. Does the ADA not consider signing a receipt or check an action that requires a 34” high work surface?

— Paul I.

ANSWER: No.  The signing of a receipt or a check is a quick transactional action and not a long term work action and therefore does not require a work surface.  As such under the 2010 ADA Standards these are considered sales/service counters and not work surfaces.  Per Section 904.4.1 sales/service counters are required to be a maximum of 36″ high.  You are allowed EITHER a forward or parallel approach to the counter.  A parallel approach does not require toe or knee space.  Please note that California requires sales/service counters to be 34″ high, the same as work surfaces.

904.4.1 Parallel Approach. A portion of the counter surface that is 36 inches (915 mm) long minimum and 36 inches (915 mm) high maximum above the finish floor shall be provided. A clear floor or ground space complying with 305 shall be positioned for a parallel approach adjacent to the 36 inch (915 mm) minimum length of counter.

EXCEPTION: Where the provided counter surface is less than 36 inches (915 mm) long, the entire counter surface shall be 36 inches (915 mm) high maximum above the finish floor.

904.4.2 Forward Approach. A portion of the counter surface that is 30 inches (760 mm) long minimum and 36 inches (915 mm) high maximum shall be provided. Knee and toe space complying with 306 shall be provided under the counter. A clear floor or ground space complying with 305 shall be positioned for a forward approach to the counter.

I hope this answers your question, and feel free to reach out for any other questions or clarification.

– Brad