This question deals with the basics of the ADA.
1. First, find out why a sharps container is being installed. If the sharps container is in a public area (for example, a restroom) and is to be used by the general public (for example diabetics who inject insulin by themselves), then the mounting height may not discriminate against wheelchair users and must be mounted at a height they can reach. If the sharps container is in a patient care area and this sharps container is intended exclusively for use by staff, then the ADA does not require a 48" mounting height; the ADA's staff work area exception exempts the staff work areas from being barrier-free on the condition that the employer make reasonable accommodation for all staff who are qualified to perform the work-related functions. See the text portion of the ADA for explanations of staff work area exception and reasonable accommodation. Note that a staff work area might be a small part of a room, it does not need to be an entire room.
2. There are additional considerations. Just because the federal ADA allows an exception does not necessarily mean that state and local jurisdictions will allow it; they are allowed to set more stingent requirements. The ADA is a federally-mandated minimum. Furthermore, check with your client; some clients deliberately choose to achieve higher levels of barrier-free compliance. For example, the VA has many wheelchair users on staff (including physicians), and the client may have their own criteria for making staff work areas meet particular standards. There are many good reasons for the 52" to 56" recommended mounting height, and the client should be closely involved in balancing the various considerations.
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Roland Binker AIA
Associate Principal
Perkins + Will
Arlington VA
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Original Message:
Sent: 12-24-2014 14:53
From: Gregg Ostrow
Subject: Mounting Height for Sharps Container
A Health System that I consult for is questioning if sharps containers need to be installed at an operational height of 48" A.F.F.to meet ADA requirements. The Centers for Health and Human Services published a document in 1998 stating that the standing operational standing height for a sharps container should be between 52" and 56" A.F.F. My opinion is that the 52"-56" A.F.F. mounting height would overrule the 48" A.F.F. mounting height. Any comments?
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Gregg Ostrow AIA
Architect
Gregg D. Ostrow, AIA
Boise ID
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