Site Accessibility Evaluation
Title II (Public Services: State and Local Government)
FOR RECORD:
FROM: Robert L. Hernandez, Title II ADA/Section 504 – Manager
DATE: 01/17/2025
SUBJECT: Fire Annex & Parking Self-Evaluation
1. On 12/12/2016, Title II ADA / Section 504 Coordinator(s) from the Office of Accessibility performed a Title II - Americans with Disabilities Act (ADA) Self-Evaluation. This evaluation was performed in accordance with 1991/2010 ADA Standards for Accessible Design.
2. Priorities for removing barriers are assigned in accordance with the ADA Checklist for Existing Facilities, promulgated by the ADA National Network. The checklist follows the four priorities listed in the Department of Justice ADA Title III regulations. These priorities are equally applicable to state and local government facilities:
Priority 1 - Accessible approach and entrance
Priority 2 - Access to goods and services
Priority 3 - Access to public toilet rooms
Priority 4 - Access to other items such as water fountains and public telephones
3. Corrective actions to findings were / will be submitted to the City maintenance work request system and will be managed in accordance with the City Transition Plan. Note: Recommended corrections may be modified where appropriate. Corrections are developed in consideration of the “Program Access” provisions of Title II, where applicable.
4. A copy of this report will be maintained by the Office of Accessibility. Updates to the findings included in this report will be available at the following link: https://access6.bluedag.com/access/barriers/GfhHF91nlvMItTaD4rVzj85XBKNZxywJ. Alternatively, this link is available from the Office of Accessibility’s webpage on the City of Colorado Springs website.
City of Colorado Springs Title II ADA/Section 504 – Manager
30 S. Nevada Ave, Suite 301
Colorado Springs, CO 80903
ADACompliance@coloradosprings.gov
Atch 1. City of Colorado Springs, ADA Self-Evaluation Report
Sincerely,
Robert Hernandez
Table of Contents
Findings
Exterior - Parking
BFID: 184217
There are approximately 30 parking spaces in the parking lot, although difficult to tell due to the deterioration of the striping. Based on 30 spaces, 2 accessible parking spaces are required, 1 of which should be van accessible.
Accessible parking spaces should be located on the shorted accessible route. Since this parking lot serves both the fire station and the annex, the accessible parking could be located in the middle.
Access aisles shall be marked so as to discourage parking in them.
BFID: 184218
Floor and ground surfaces shall be stable, firm, and slip resistant
Parking spaces and access aisles serving them shall comply with 302. Access aisles shall be at the same level as the parking spaces they serve. Changes in level are not permitted.
Floor and ground surfaces shall be stable, firm, and slip resistant and shall comply with 302.
2010 ADAS Section 502.4
Parking spaces and access aisles serving them shall comply with 302. Access aisles shall be at the same level as the parking spaces they serve. Changes in level are not permitted.
BFID: 185598
Parking space identification signs shall include the International Symbol of Accessibility. Signs identifying van parking spaces shall contain the designation "van accessible."
Parking space identification signs shall include the International Symbol of Accessibility complying with 703.7.2.1. Signs identifying van parking spaces shall contain the designation "van accessible." Signs shall be 60 inches (1525 mm) minimum above the finish floor or ground surface measured to the bottom of the sign.
Exterior - Accessible Routes
BFID: 184219
There is a 1/2" lip and 1" gap between the curb ramp and the street gutter.
The curb ramp does not have detectable warnings.
The curb ramp slope exceeds the maximum running slope (Parallel to the direction of travel) allowable of 8.33%.
Curb ramps should have the least possible slope but in no case more than 8.3% (1:12).
Curb ramps on accessible routes shall comply with 406, 405.2 through 405.5, and 405.10.
BFID: 184220
- No detectable warnings
- A ramp face running slope measuring 21.1%.
- A top landing measuring up to a 3.2% slope.
-The landing has up to 1/2" vertical lift from a utility cut out and pour back which is sinking
Curb Ramps
BFID: 184222
1/4 inch is the maximum vertical rise. Changes in level between 1/4 inch and 1/2 inch must be beveled at 1:2 or less.
Changes in level greater than 1/2 inch must be by way of a ramp.
Changes in level between 1/4 inch (6.4 mm) high minimum and 1/2 inch (13 mm) high maximum shall be beveled with a slope not steeper than 1:2.
2010 ADAS Section 303.2
Changes in level of 1/4 inch (6.4 mm) high maximum shall be permitted to be vertical.
Exterior - Entrance
BFID: 194657
When the slope in the direction of travel of any walk exceeds 1 unit vertical in 20 units horizontal (5-percent slope), it must be constructed as a ramp. Surface cross slopes must not exceed one unit vertical in 48 units horizontal (2-percent slope).
The running slope of walking surfaces shall not be steeper than 1:20. The cross slope of walking surfaces shall not be steeper than 1:48.
BFID: 184177
Changes in level are not permitted at required clear floor or ground space except that slopes not steeper than 1:48 shall be permitted.
Floor or ground surfaces of a clear floor or ground space shall comply with 302. Changes in level are not permitted.
BFID: 184175
.
The door does not open with a maximum force of 15 lbs to release a latch. Not an ADA finding. It is the pressure set by states that have a stated maximum exterior pressure.
Automatic doors and automatic gates shall comply with 404.3. Full-powered automatic doors shall comply with ANSI/BHMA A156.10 (incorporated by reference, see "Referenced Standards" in Chapter 1). Low-energy and power-assisted doors shall comply with ANSI/BHMA A156.19 (1997 or 2002 edition) (incorporated by reference, see "Referenced Standards" in Chapter 1).
BFID: 184176
1/4 inch is the maximum vertical rise. Changes in level between 1/4 inch and 1/2 inch must be beveled at 1:2 or less.
Changes in level greater than 1/2 inch must be by way of a ramp.
Changes in level between 1/4 inch (6.4 mm) high minimum and 1/2 inch (13 mm) high maximum shall be beveled with a slope not steeper than 1:2.
2010 ADAS Section 303.2
Changes in level of 1/4 inch (6.4 mm) high maximum shall be permitted to be vertical.
BFID: 184191
In existing buildings and facilities where not all entrances are accessible doors that are accessible shall be identified by the International Symbol of Accessibility. Directional signs that indicate the location of the nearest accessible entrance shall be provided at entrances that are not accessible. Directional signs including the International Symbol of Accessibility indicating the accessible route to the nearest accessible entrance shall be provided at junctions when the accessible route diverges from the regular circulation path.
Where not all entrances comply with 404, entrances complying with 404 shall be identified by the International Symbol of Accessibility complying with 703.7.2.1. Directional signs complying with 703.5 that indicate the location of the nearest entrance complying with 404 shall be provided at entrances that do not comply with 404.
Interior - General
BFID: 184181
Hand-activated door/gate opening hardware, handles, pulls, latches, locks, and other operating devices on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, tight pinching or twisting of the wrist to operate. Hardware shall be 34 inches minimum and 48 inches maximum above the finish floor or ground.
Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.
BFID: 184180
Where a clear floor or ground space allows a parallel or front approach and the side reach is unobstructed, the high side reach shall be 48 inches maximum above the finish floor or ground and the low side reach shall be 15 inches minimum above the finish floor or ground.
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.
2010 ADAS Section 308.3.1
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.
BFID: 184182
Spout outlets shall be 36 inches maximum above the finish floor or ground.
Also, The drinking fountain alcove is only 31-3/4" wide which makes side approach impossible.
Spout outlets shall be 36 inches (915 mm) maximum above the finish floor or ground.
BFID: 184193
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.
Interior - Offices
BFID: 184184
Hand-activated door/gate opening hardware, handles, pulls, latches, locks, and other operating devices on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, tight pinching or twisting of the wrist to operate. Hardware shall be 34 inches minimum and 48 inches maximum above the finish floor or ground.
Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.
BFID: 184185
Door openings shall provide a clear width of 32 inches minimum. Clear openings of doorways with swinging doors shall be measured between the face of the door and the stop, with the door open 90 degrees. There shall be no projections into the required clear opening width lower than 34 inches above the finish floor or ground. Projections into the clear opening width between 34 inches and 80 inches above the finish floor or ground shall not exceed 4 inches.
Door openings shall provide a clear width of 32 inches (815 mm) minimum. Clear openings of doorways with swinging doors shall be measured between the face of the door and the stop, with the door open 90 degrees. Openings more than 24 inches (610 mm) deep shall provide a clear opening of 36 inches (915 mm) minimum. There shall be no projections into the required clear opening width lower than 34 inches (865 mm) above the finish floor or ground. Projections into the clear opening width between 34 inches (865 mm) and 80 inches (2030 mm) above the finish floor or ground shall not exceed 4 inches (100 mm).
BFID: 184179
Hand-activated door/gate opening hardware, handles, pulls, latches, locks, and other operating devices on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, tight pinching or twisting of the wrist to operate. Hardware shall be 34 inches minimum and 48 inches maximum above the finish floor or ground.
Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.
BFID: 184187
Hand-activated door/gate opening hardware, handles, pulls, latches, locks, and other operating devices on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, tight pinching or twisting of the wrist to operate. Hardware shall be 34 inches minimum and 48 inches maximum above the finish floor or ground.
Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.
BFID: 184192
Hand-activated door/gate opening hardware, handles, pulls, latches, locks, and other operating devices on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, tight pinching or twisting of the wrist to operate. Hardware shall be 34 inches minimum and 48 inches maximum above the finish floor or ground.
Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.
Interior - Conference Room
BFID: 184188
Hand-activated door/gate opening hardware, handles, pulls, latches, locks, and other operating devices on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, tight pinching or twisting of the wrist to operate. Hardware shall be 34 inches minimum and 48 inches maximum above the finish floor or ground.
Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.
BFID: 184189
When the slope in the direction of travel of any walk exceeds 1 unit vertical in 20 units horizontal (5-percent slope), it must be constructed as ramp. Surface cross slopes must not exceed one unit vertical in 48 units. Horizontal (2-percent slope).
At least one accessible route shall connect accessible building or facility entrances with all accessible spaces and elements within the building or facility which are otherwise connected by a circulation path unless exempted by 206.2.3 Exceptions 1 through 7.
2010 ADAS Section 403.3
The running slope of walking surfaces shall not be steeper than 1:20. The cross slope of walking surfaces shall not be steeper than 1:48.
Interior - Unisex - formerly Men's Restroom
BFID: 184194
In addition, the sign does not have tactile/Braille.
Tactile Characters on signs shall be located 48 inches minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character. Mounting location shall be determined so that a person may approach within 3 inches of signage without encountering protruding objects and shall be located so that a clear floor space of 18 inches minimum by 18 inches minimum, centered on the tactile Characters, is provided beyond the arc of any door swing between the closed position and 45 degree open position.
Tactile characters on signs shall be located 48 inches (1220 mm) minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches (1525 mm) maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character.
BFID: 184195
Hand-activated door/gate opening hardware, handles, pulls, latches, locks, and other operating devices on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, tight pinching or twisting of the wrist to operate. Hardware shall be 34 inches minimum and 48 inches maximum above the finish floor or ground.
Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.
BFID: 184196
Water supply and drain pipes under lavatories and sinks shall be insulated or otherwise configured to protect against contact. There shall be no sharp or abrasive surfaces under lavatories and sinks.
Water supply and drain pipes under lavatories and sinks shall be insulated or otherwise configured to protect against contact. There shall be no sharp or abrasive surfaces under lavatories and sinks.
BFID: 184197
Faucet controls and operating mechanisms shall be operable with one hand and shall not require tight grasping, pinching or twisting of the wrist. The force required to activate controls shall be no greater than 5 lb. Lever-operated, push-type and electronically controlled mechanisms are examples of acceptable designs. Self-closing valves are allowed if the faucet remains open for at least 10 seconds.
Controls for faucets shall comply with 309. Hand-operated metering faucets shall remain open for 10 seconds minimum.
BFID: 184198
Dispensers must have all operable parts a maximum of 48 inches above the floor.
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.
BFID: 184199
Dispensers must have all operable parts a maximum of 48 inches above the floor.
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.
BFID: 184200
Where a forward reach is unobstructed, the high forward reach shall be 48 inches maximum above the finished floor.
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.
BFID: 184201
The side grab bar must extend at least 54 inches minimum beyond the rear wall and start a maximum of 12 inches from the rear wall.
The rear grab bar must be a minimum of 36 inches long and extend from the centerline of the toilet 12 inches minimum on one side and 24 inches minimum on the other side.
Grab bars shall be installed in a horizontal position, 33 inches minimum and 36 inches maximum above the finish floor measured to the top of the gripping surface.
Grab bars for water closets shall comply with 609. Grab bars shall be provided on the side wall closest to the water closet and on the rear wall.
BFID: 184202
The height of accessible water closets shall be a minimum of 17 inches and a maximum of 19 inches measured to the top of a maximum 2-inch high toilet seat.
The seat height of a water closet above the finish floor shall be 17 inches (430 mm) minimum and 19 inches (485 mm) maximum measured to the top of the seat. Seats shall not be sprung to return to a lifted position.
BFID: 184203
The centerline of the toilet must be 16 to 18 inches from the side wall.
The water closet shall be positioned with a wall or partition to the rear and to one side. The centerline of the water closet shall be 16 inches (405 mm) minimum to 18 inches (455 mm) maximum from the side wall or partition, except that the water closet shall be 17 inches (430 mm) minimum and 19 inches (485 mm) maximum from the side wall or partition in the ambulatory accessible toilet compartment specified in 604.8.2. Water closets shall be arranged for a left-hand or right-hand approach.
BFID: 184204
Toilet paper dispensers shall be 7 inches minimum and 9 inches maximum in front of the water closet measured to the centerline of the dispenser. The outlet of the dispenser shall be 15 inches minimum and 48 inches maximum above the finish floor and shall not be located behind grab bars. Dispensers shall not be of a type that controls delivery or that does not allow continuous paper flow. There shall be a clearance of 1 1/2 inches minimum below the grab bar.
Toilet paper dispensers shall comply with 309.4 and shall be 7 inches (180 mm) minimum and 9 inches (230 mm) maximum in front of the water closet measured to the centerline of the dispenser. The outlet of the dispenser shall be 15 inches (380 mm) minimum and 48 inches (1220 mm) maximum above the finish floor and shall not be located behind grab bars. Dispensers shall not be of a type that controls delivery or that does not allow continuous paper flow.
BFID: 184205
Doors shall not swing into the clear floor space required for any fixture unless the toilet room or bathing room is for individual use and a clear floor space 30 inches by 48 inches is provided within the room beyond the arc of the door swing.
Doors shall not swing into the clear floor space or clearance required for any fixture. Doors shall be permitted to swing into the required turning space.
Interior - Unisex - formerly Women's Restroom
BFID: 184206
In addition, the sign is not tactile/Braille.
Tactile Characters on signs shall be located 48 inches minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character. Mounting location shall be determined so that a person may approach within 3 inches of signage without encountering protruding objects and shall be located so that a clear floor space of 18 inches minimum by 18 inches minimum, centered on the tactile Characters, is provided beyond the arc of any door swing between the closed position and 45 degree open position.
Tactile characters on signs shall be located 48 inches (1220 mm) minimum above the finish floor or ground surface, measured from the baseline of the lowest tactile character and 60 inches (1525 mm) maximum above the finish floor or ground surface, measured from the baseline of the highest tactile character.
BFID: 184207
Hand-activated door/gate opening hardware, handles, pulls, latches, locks, and other operating devices on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, tight pinching or twisting of the wrist to operate. Hardware shall be 34 inches minimum and 48 inches maximum above the finish floor or ground.
Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.
BFID: 194658
Door locking mechanisms should be push button and release upon activation of the door hardware.
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.
BFID: 184208
Water supply and drain pipes under lavatories and sinks shall be insulated or otherwise configured to protect against contact. There shall be no sharp or abrasive surfaces under lavatories and sinks.
Water supply and drain pipes under lavatories and sinks shall be insulated or otherwise configured to protect against contact. There shall be no sharp or abrasive surfaces under lavatories and sinks.
BFID: 184209
Faucet controls and operating mechanisms shall be operable with one hand and shall not require tight grasping, pinching or twisting of the wrist. The force required to activate controls shall be no greater than 5 lb. Lever-operated, push-type and electronically controlled mechanisms are examples of acceptable designs. Self-closing valves are allowed if the faucet remains open for at least 10 seconds.
Controls for faucets shall comply with 309. Hand-operated metering faucets shall remain open for 10 seconds minimum.
BFID: 184210
Dispensers must have all operable parts a maximum of 48 inches above the floor.
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.
BFID: 184211
Where a forward reach is unobstructed, the high forward reach shall be 48 inches maximum above the finished floor.
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.
BFID: 184212
The side grab bar must extend at least 54 inches minimum beyond the rear wall and start a maximum of 12 inches from the rear wall.
The rear grab bar must be a minimum of 36 inches long and extend from the centerline of the toilet 12 inches minimum on one side and 24 inches minimum on the other side.
Grab bars shall be installed in a horizontal position, 33 inches minimum and 36 inches maximum above the finish floor measured to the top of the gripping surface.
Grab bars for water closets shall comply with 609. Grab bars shall be provided on the side wall closest to the water closet and on the rear wall.
BFID: 184213
The height of accessible water closets shall be a minimum of 17 inches and a maximum of 19 inches measured to the top of a maximum 2-inch high toilet seat.
The seat height of a water closet above the finish floor shall be 17 inches (430 mm) minimum and 19 inches (485 mm) maximum measured to the top of the seat. Seats shall not be sprung to return to a lifted position.
BFID: 184214
The centerline of the toilet must be 16 to 18 inches from the side wall.
The water closet shall be positioned with a wall or partition to the rear and to one side. The centerline of the water closet shall be 16 inches (405 mm) minimum to 18 inches (455 mm) maximum from the side wall or partition, except that the water closet shall be 17 inches (430 mm) minimum and 19 inches (485 mm) maximum from the side wall or partition in the ambulatory accessible toilet compartment specified in 604.8.2. Water closets shall be arranged for a left-hand or right-hand approach.
BFID: 184215
Controls shall be operable with one hand and shall not require tight grasping, pinching or twisting. Controls for the flush valves shall be mounted on the wide side of toilet areas, no more than 48 inches above the floor.
Flush controls shall be hand operated or automatic. Hand operated flush controls shall comply with 309. Flush controls shall be located on the open side of the water closet except in ambulatory accessible compartments complying with 604.8.2.
BFID: 184216
Toilet paper dispensers shall be 7 inches minimum and 9 inches maximum in front of the water closet measured to the centerline of the dispenser. The outlet of the dispenser shall be 15 inches minimum and 48 inches maximum above the finish floor and shall not be located behind grab bars. Dispensers shall not be of a type that controls delivery or that does not allow continuous paper flow. There shall be a clearance of 1 1/2 inches minimum below the grab bar.
Toilet paper dispensers shall comply with 309.4 and shall be 7 inches (180 mm) minimum and 9 inches (230 mm) maximum in front of the water closet measured to the centerline of the dispenser. The outlet of the dispenser shall be 15 inches (380 mm) minimum and 48 inches (1220 mm) maximum above the finish floor and shall not be located behind grab bars. Dispensers shall not be of a type that controls delivery or that does not allow continuous paper flow.
BFID: 194652
Grab bars shall be installed in a horizontal position, 33 inches minimum and 36 inches maximum above the finish floor measured to the top of the gripping surface and the space between the grab bar and the top of the tank shall be 1-1/2 inches minimum.
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, except that at water closets for children's use complying with 604.9, grab bars shall be installed in a horizontal position 18 inches (455 mm) minimum and 27 inches (685 mm) maximum above the finish floor measured to the top of the gripping surface. The height of the lower grab bar on the back wall of a bathtub shall comply with 607.4.1.1 or 607.4.2.1.
BFID: 194653
The side grab bar must extend at least 54 inches minimum beyond the rear wall and start a maximum of 12 inches from the rear wall. A 42 inch grab bar installed the maximum distance from the rear wall (12 inches) will leave the leading end 54 inches from the rear wall.
Grab bars shall be installed in a horizontal position, 33 inches minimum and 36 inches maximum above the finish floor measured to the top of the gripping surface.
The side wall grab bar shall be 42 inches (1065 mm) long minimum, located 12 inches (305 mm) maximum from the rear wall and extending 54 inches (1370 mm) minimum from the rear wall.