Which part of the dispenser the rule measures
The Standards never mention tampon or napkin dispensers, so the height comes from the general rule for operable parts. Section 106.5 defines one as a component used to insert or withdraw objects, or to activate, deactivate, or adjust the element. A coin slot takes an object; a push button, pull, or knob activates the machine; the delivery tray is where the product is withdrawn. Each of those is measured, not the top of the cabinet.
Section 205.1 requires operable parts in accessible rooms to comply with 309, and 309.3 places them within the reach ranges of Section 308. For an unobstructed forward or side reach, the highest control sits 48 in. maximum above the finish floor and the lowest sits 15 in. minimum. A tall dual vendor with the coin slot near the top and the tray near the bottom has to fit both ends inside that range.
Coin mechanisms, push buttons, and free-vend
Section 309.4 is the rule that decides the mechanism. Every operable part must work with one hand, without tight grasping, pinching, or twisting of the wrist, and with 5 pounds of force at most. A push button or a straight pull meets that. A small knob that has to be turned with a twist of the wrist does not.
Free-vend dispensers remove the coin slot, but the push or pull that releases the product is still an operable part and still has to meet 309.4 and the reach range. When a coin mechanism is converted to free-vend later, the height of the release does not change, so check it once at installation.
Surface-mounted, semi-recessed, or recessed
Dispensers are usually mounted in the open part of the restroom, on a wall people walk along. Section 307.2 limits any object with a leading edge between 27 in. and 80 in. above the floor to a 4 in. projection into the circulation path. A surface-mounted vendor cabinet is deeper than that, so it belongs in an alcove, in a corner outside the path of travel, or in a semi-recessed or recessed version that leaves 4 in. or less standing proud of the wall.
Recessing changes the rough-in, not the reach. The coin slot, button, and tray are still measured from the finish floor, and the 15 to 48 in. range still applies.
Floor space and reach over a counter
Section 305.3 requires a 30 by 48 in. clear floor space at the dispenser, and 305.5 lets it be positioned for either a forward or a parallel approach. Keep that space clear of the lavatory counter, the trash receptacle, and the door swing.
A dispenser mounted above a counter or vanity is reached over an obstruction. For a side reach, 308.3.2 limits the counter to 34 in. high and 24 in. deep, holds the high reach at 48 in. where the reach depth is 10 in. or less, and lowers it to 46 in. for a reach depth of up to 24 in. A deeper counter puts the dispenser out of reach; mount it on an open wall instead.
