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2010 ADA Standards for Accessible Design

ADA Toilet Seat Cover Dispenser Height

Short answer

The ADA Standards set no height just for seat cover dispensers. A dispenser is an operable part under the definition in Section 106.5, so Section 309.3 places it within the reach ranges of Section 308: the covers must be reachable between 15 in. and 48 in. above the finish floor when nothing is in the way.

Requirements at a glance

RuleRequirementSection
Why the reach rules applyA seat cover dispenser is an operable part: a component used to insert or withdraw objects
Standards text
A component of an element used to insert or withdraw objects, or to activate, deactivate, or adjust the element.
106.5
ScopingOperable parts in accessible rooms and spaces comply with 309
Standards text
Operable parts on accessible elements, accessible routes, and in accessible rooms and spaces shall comply with 309 .
205.1
Height ruleWithin one or more of the reach ranges in Section 308
Standards text
Operable parts shall be placed within one or more of the reach ranges specified in 308 .
309.3
Unobstructed forward reach48 in. maximum high reach and 15 in. minimum low reach above the finish floor
Standards text
Where a forward reach is unobstructed, the high forward reach shall be 48 inches (1220 mm) maximum and the low forward reach shall be 15 inches (380 mm) minimum above the finish floor or ground.
308.2.1
Unobstructed side reach48 in. maximum high reach and 15 in. minimum low reach from a parallel approach
Standards text
Where a clear floor or ground space allows a parallel approach to an element and the side reach is unobstructed, the high side reach shall be 48 inches (1220 mm) maximum and the low side reach shall be 15 inches (380 mm) minimum above the finish floor or ground.
308.3.1
Forward reach over an obstruction48 in. maximum where the reach depth is 20 in. or less; 44 in. maximum where the reach depth is more than 20 in., up to a 25 in. reach depth
Standards text
Where a high forward reach is over an obstruction, the clear floor space shall extend beneath the element for a distance not less than the required reach depth over the obstruction. The high forward reach shall be 48 inches (1220 mm) maximum where the reach depth is 20 inches (510 mm) maximum. Where the reach depth exceeds 20 inches (510 mm), the high forward reach shall be 44 inches (1120 mm) maximum and the reach depth shall be 25 inches (635 mm) maximum.
308.2.2
OperationOne hand, no tight grasping, pinching, or twisting of the wrist; 5 pounds of force maximum
Standards text
Operable parts shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.
309.4
Clear floor space30 in. by 48 in. minimum at the dispenser
Standards text
The clear floor or ground space shall be 30 inches (760 mm) minimum by 48 inches (1220 mm) minimum.
305.3
Overlap with the water closet clearanceDispensers may overlap the clearance required around the water closet
Standards text
The required clearance around the water closet shall be permitted to overlap the water closet, associated grab bars, dispensers, sanitary napkin disposal units, coat hooks, shelves, accessible routes, clear floor space and clearances required at other fixtures, and the turning space. No other fixtures or obstructions shall be located within the required water closet clearance.
604.3.2
Spacing at a grab bar12 in. minimum between the bar and a dispenser above it; 1½ in. minimum below the bar or past its ends
Standards text
The space between the wall and the grab bar shall be 1½ inches (38 mm). The space between the grab bar and projecting objects below and at the ends shall be 1½ inches (38 mm) minimum. The space between the grab bar and projecting objects above shall be 12 inches (305 mm) minimum.
609.3
Rear grab bar heightSets where the bar sits on the rear wall: 33 in. minimum and 36 in. maximum to the top of the gripping surface
Standards text
Grab bars shall be installed in a horizontal position, 33 inches (840 mm) minimum and 36 inches (915 mm) maximum above the finish floor measured to the top of the gripping surface
609.4
Projection into a circulation path4 in. maximum for a unit whose leading edge is between 27 in. and 80 in. above the floor
Standards text
Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finish floor or ground shall protrude 4 inches (100 mm) maximum horizontally into the circulation path.
307.2

Source: 2010 ADA Standards for Accessible Design, U.S. Access Board. State and local codes can be stricter, and the authority having jurisdiction has the final word.

Finish floor0"12"24"36"48"60"15 to 48 in.Reach to the covers, …ADA 308.2.144 in. maxForward reach over th…ADA 308.2.233 to 36 in.Rear grab bar topADA 609.4
Heights above the finish floor, drawn to scale. Reach to the covers, unobstructed: 15 to 48 in. above the finish floor (ADA 308.2.1). Forward reach over the water closet, deeper than 20 in.: 44 in. max above the finish floor (ADA 308.2.2). Rear grab bar top: 33 to 36 in. above the finish floor (ADA 609.4).

Why there is no single number

The Standards name toilet paper dispensers in 604.7 and sanitary napkin disposal units in 604.3.2, but a seat cover dispenser never appears by name. What covers it is the definition of an operable part in Section 106.5: a component used to insert or withdraw objects. Pulling a cover out of the unit is exactly that.

Section 205.1 sends every operable part in an accessible room to Section 309, and 309.3 sends its height to the reach ranges in Section 308. For an unobstructed forward or side reach, the point where a user takes hold of the cover must sit between 15 in. and 48 in. above the finish floor. The top of the cabinet can be higher; the rule measures the reach, not the housing.

Reaching over the water closet

A dispenser centered on the rear wall above the tank is reached over an obstruction. Section 308.2.2 then limits the high reach to 48 in. where the reach depth is 20 in. or less, and to 44 in. where the reach depth exceeds 20 in., with 25 in. as the deepest reach allowed. Measure the depth from the front of whatever is in the way to the face of the dispenser.

A unit on the side wall or the partition beside the water closet avoids the question, because the approach is a side reach from the seat. That is also where the dual-access units that serve two compartments through one partition are mounted.

Sharing the wall with the rear grab bar

Section 604.3.2 allows a dispenser to overlap the clearance around the water closet, so the rear wall is open to it. The rear grab bar is not. Under 609.3, anything mounted above the bar needs 12 in. of clear space, and anything below it or past its ends needs 1½ in.

With the bar top at 33 to 36 in. under 609.4, a dispenser above it starts a full 12 in. higher than that, and its covers still have to be reachable at 48 in. maximum. That leaves little or nothing to work with, which is why most layouts put the seat cover dispenser on the side wall or partition, or under the rear bar with the 1½ in. gap.

Choosing a seat cover dispenser

Read the spec sheet for where the covers pull from, since that point is what the reach range measures. Recessed and semi-recessed models keep the projection within the 4 in. limit of 307.2 wherever the unit stands in a circulation path; a surface-mounted unit is fine on a wall or partition inside the compartment.

The covers should pull free with one hand, without pinching or wrist twisting and with no more than 5 pounds of force, to satisfy 309.4. Keep a 30 by 48 in. clear floor space in front of or beside the unit under 305.3; inside the stall, the water closet clearance supplies it.

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Commercial toilet seat cover dispensers

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Toilet Seat Cover Dispensers buying guide and specs

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ADA Toilet Seat Cover Dispenser Height: common questions

The 2010 ADA Standards give no dedicated height. The dispenser is an operable part, so Section 309.3 applies the reach ranges of Section 308: the covers must be reachable between 15 in. and 48 in. above the finish floor for an unobstructed reach. Measure to the point where a cover is gripped, not to the top of the cabinet.

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