Employee Work Areas and the ADA - Basic
Employee Work Area Behind Counter
Employee work areas in public accommodations and state or local government facilities are subject to the Americans with Disabilities Act (ADA). An employee work area is defined as all or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas because work is not normally performed in these spaces. The photo on the right is representative of an employee work area behind the counter at a quick service restaurant.
This article will discuss the accessible components of an employee work area including a means to approach, enter and exit the employee work area, for larger employee work areas an accessible circulation path, a means of egress from the employee work area, and an audible fire alarm system with at least the wiring for a visual warning.
Except for very small employee work areas of less than 300 SF, the main accessibility issue under Title II and Title III of the ADA is compliance with the ADA for approach, entry and exit of the employee work area. In other words, the door to enter and exit the employee work area. See the graphic below for a representation of this Standard. What is not stressed in the graphic is for the entry/exit door to also be fully compliant with the ADA.
Approach, Entry and Exit Criteria for Employee Work Area
Common use circulation paths within employee work areas that are 1000 SF or larger should comply with the Standards for accessible routes. This typically includes width, slope, and condition of the floor. If the employee work area is less than 1000 square feet the space is not required to comply with the Standards for accessible circulation paths. The graphic below is representative of an employee work area greater than 1000 SF with a compliant circulation path.
Employee Work Area Greater Than 1000 SF
The graphic below is an employee work area that is less than 1000 SF and a circulation path is not required.
Employee Work Area Less Than 1000 Sf and No Circulation Path
A means of egress should be available for the employee work space. An accessible means of egress, as defined by the International Building Code (IBC), is a “continuous and unobstructed way of egress travel from any point in a building or facility that provides an accessible route to an area of refuge, a horizontal exit, or a public way.” Accessible means of egress are not required to be added in alterations to existing facilities. See the graphic below for a representation of egress components.
In the graphic above, there are multiple egress paths from this facility including the front entry and other emergency exits. There are interior and exterior staircases from the upper floors that lead to the exterior and lower levels of the facility. The primary design features of an emergency egress installation to be concerned with include doors, route widths, protruding objects, handrails, and steps systems.
Fire Alarm with Visual and Audible Warning
Employee work areas should have at least an audible emergency alarm source. Where employee work areas have audible alarm coverage, the wiring system shall be designed so that visible alarms complying with the Standards can be integrated into the alarm system. This is stating that the wiring for a visible alarm should be installed if an audible alarm is installed. For an existing facility with an audible alarm system, the wiring for a visual alarm may be difficult to confirm.
So now we can look at some graphics depicting different types of employee work areas that are common. Employee work areas can come in many different arrangements depending on the purpose of the facility. Employee work areas can be completely separate from publicly accessible areas such as in the quick service restaurant shown in the photo above where the employee work area is behind the sales counter. In a doctor’s office the employee work areas are mixed in with the patient waiting area, corridors to the exam rooms, the exam rooms, toilet rooms, mechanical rooms, and employee break room. See the graphic below for a representation.
Doctors Office with Employee Work Areas
An important note is that toilet rooms, break rooms, and kitchenettes used by employees are not exempt from the ADA Standards, even if the public is prevented from accessing these spaces. This is because the functions in these rooms are not work. The graphic below is a common retail space.
Common Retail Space
In summary, at a minimum, ADA compliant accessibility in an employee work area should include:
a means to approach, enter and exit the employee work area
for larger employee work areas an accessible circulation path
a means of egress from the employee work area
an audible fire alarm system with at least the wiring for a visual warning.