Expert: Sharon Toji - 9/23/2011

Question
You answered a question 2/5/10 about Washington ADA restroom signs.
Part of your answer was:
The signs can be any color, but the words and pictograms do have to have a strong contrast with the sign background.

There is an amendment to the IBC that the State of  Washington added several years ago.

1101.2.9 (ICC A117.1 Section 703.6.3.1) International symbol of accessibility. Where the International Symbol of Accessibility is required, it shall be proportioned complying with ICC A117.1 Figure 703.6.3.1. All interior and exterior signs depicting the International Symbol of Accessibility shall be white on a blue background.

I hope I am not offending you by sending you this correction.I was looking for an answer to an ADA issue that I am involved with.
ADA Compliant Eyewash
I am a Structural-Mechanical-Plumbing-Fire Inspector for a city.
I wrote a correction because a medical clinic added four eyewash faucets. Before the installation I told the plumber that at least one of the eyewashes would have to be ADA compliant. Well now its final time and they don't want to comply.
The plumber is playing stupid about the whole ordeal. I do know ANSI is silent about eyewashes but almost every eyewash manufacturer makes an ADA Compliant Eyewash. Now how does that work? I have ADA compliant but I do not have a standard to make it work? It is obvious to me that the standard eyewash will not work for a handicapped person but the architect is asking for some sort of connection to the code. He says the eyewash is for employees only.
Now looking at ANSI standards for an eyewash I am ready to tell them they need more than one ADA because of the 10 second ruling for distance. But I am even having a hard time getting them to comply for one. Do you have any suggestions?
Thank You,
Larry LaDuke

PS you may answer this where ever or however you want.

Answer
Dear Larry, I"m sorry about the error for Washington ISA signs. I do remember now that the State of Washington did require blue and white for the ISA. Years ago, I used to have a file on every state. Washington was rather unique, along with California, in having something that was more compliant than the federal standard. California also requires blue and white, but does have an exception that says the "authority" can allow a different color, and most people make it whatever color they wish -- which is usually blue and white -- and don't ask permission. It does not appear to ever be challenged. Actually, there are some times when blue and white is not the best color, particularly in California, because we have the restroom door sign, which has to contrast with the door. Doors are often blue, or a dark color that does not contrast with blue, so the sign will need to be some other color. Then, it's necessary to use a different color, when the ISA is on the door sign. Or -- the entire sign system is blue and white, and the ISA signs "disappear" so serve their function better when they are a different color. Usually, unless I know the person is asking a question about California, I answer in terms of the federal Guidelines. That was rather sloppy of me! So, thanks for the reminder, and I'll be sure to put in a disclaimer on ADA sign questions from now on.

The eyewash question is a puzzle! Ordinarily, I would say that you take all the various pieces and functions of an eyewash system, and require compliance with those. Unless eyewash stations are stated as exempt from those standards, they should comply, in my opinion. That would be reach range, knee and toe clearance, approach, and not having to grasp, twist, etc. I assume they would fall somewhat into the category of sinks or lavatories, or maybe even drinking fountains.

Now, as to whether eyewashes have to comply at all -- are you saying that you required that a minimum of one would comply or that the Washington code requires it? I suppose it does make sense that the eyewashes are for employees, and of course the ADA doesn't require much for employees until a specific employee requires something as a reasonable accommodation. However, if the particular element is for the common use of employees, rather than something that is part of specific work stations, then they have to be compliant. I sometimes see eyewash stations out in corridors, rather than inside specific rooms. If that is the case, I can see how it would be reasonable to require that they be usable by someone in a wheelchair, or with a mobility impairment. If eyewash manufacturers make them, then they must think there is a requirement under at least some circumstances. However, if they are placed so they are only used by specific employees within specific workstations, I can see why, if the state building code does not specifically require them, the plumber may want to protest your requirement as being beyond the code.

I will see if I can get an answer from a couple of places, and come back to this question if I get something useful.

Again, thanks for the reminder about the ISA color for the State of Washington.

Sharon Toji