Toilet Room Mirror Mounted Too High From The Bottom of Reflecting Surface

The Department of Justice considers accessibility of toilet rooms to be third priority in ADA compliance, and a common issue we see in this area relates to the toilet room mirrors.

For something so simple, toilet room mirrors in convenience stores are often mounted too high to comply with the ADA standard. The good news is it’s an easy fix.toilet room mirrow

According to the Americans with Disabilities Act, the rule is:

“Mirrors located above lavatories or countertops shall be installed with the bottom edge of the reflecting surface 40 inches (1015 mm) maximum above the finish floor or ground. Mirrors not located above lavatories or countertops shall be installed with the bottom edge of the reflecting surface 35 inches (890 mm) maximum above the finish floor or ground.”

Generally, for the past many years, the standard for architects and contractors has been “substantial compliance” to building codes, which for this item basically means that a contractor comes in, looks at the mirror, and decides whether it looks like a person in a wheelchair would be able to see themselves.

Because we now must adhere to the ADA, a civil rights law, “substantial compliance” just won’t cut it. The specific rule is that the toilet room mirror must be mounted 40 inches from the floor. According to, the average eye level of a person in a wheelchair is 43-51 inches. Using the 40-inch standard, the average person in a wheelchair would clearly be able to see his or her own face in the mirror.

We often see other “fixes” to this problem, such as a tilted mirror intended to give better viewing range to persons in wheelchairs. While these tilted mirrors are helpful, they do not exempt you from meeting the 40-inch rule.

We also see this problem in places that use thick frames around the mirror for design purposes, where the thickness of the frame takes the mirror above the 40-inch mark. If this framed mirrors are a look you’re interested in, you must make sure your frames do not put you out of compliance.

If you’re unsure whether your store meets this requirement, use a tape measurer to see whether the distance from the floor to the bottom of the reflective surface of the mirror exceeds 40 inches, and relocate your mirror if necessary.

As far as barrier removal goes, this is a simple one.

Brad-Gaskins-3Brad Gaskins has more than 30 years experience in the practice of architecture and a comprehensive understanding of professional practice nationwide. Brad brings a unique and valuable perspective to The McIntosh Group’s practice and clients, with a specific expertise in the Americans with Disabilities Act (ADA) and national building codes.  Brad has gained recognition as an expert witness for clients with ADA compliance complaints. He represents NACS, The Association for Convenience and Fuel Retailing, as a full voting member on the International Code Council (ICC), American National Standards Institute (ANSI) A117.1, Consensus Committee on Accessible and Usable Buildings and Facilities. His objective is to share, with the committee for their deliberations, the potential impact of the standards on the convenience store and truckstop industry.

This post was originally created for the National Association of Truck Stop Owners (NATSO). Read the original post at:

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