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Trash Enclosures — Accessible or not?

Janis Kent, Architect, CASp © November, 2014

Trash enclosures are one of the items we tend not to talk about or even think about much – out of sight, out of mind, and for years it was thought no access was required. But a trash enclosure should have some measure of access – the question is how much?

If the trash enclosure is used by employees only, it is required to be designed and constructed so one can approach, enter, and exit the enclosure. Generally, a common use circulation path is required in new construction for employee only work areas but if the trash enclosure is fully exposed to the weather it is exempted from these requirements within the space, although it would still need to be located on an accessible route.

The ADA Standards exempts raised employee work areas that are less than 300 SF and raised 7” or more if it is essential to the work being done. It also exempts employee only spaces that are less than 1,000 SF and defined by partitions, furnishing, and built-ins. Either of these exemptions might apply to a trash area at an interior location. Do note, that neither of these exemptions are allowed per the California Building Code.

Another aspect on trash enclosures – barrier removal. If the enclosure is used only by employees there are no barrier removal requirements for existing trash enclosures. The Department of Justice states that barrier removal does not pertain to employee only areas since employees have protection under Title I of the ADA. Depending upon when the enclosure was built, though, you may still be required to provide a path of travel to the enclosure itself with the ability to approach, enter, and exit. This would be true if it was not constructed in compliance with access regulations in place at the time of construction.

According to ADA for the most part, an employee only trash enclosure might be similar to a mechanical or supply storage room or a janitor closet and not be considered a primary function area. What this means for alterations in general is, there are no path of travel obligations unless the enclosure itself is being altered.

All of the above is based on trash enclosures used by employees only. If used by the public or if it is located in multi-family housing facilities there are additional requirements for common-use facilities that would apply. And do be aware of requirements for trash chutes in common use facilities which, at a minimum, would require 5 lbs maximum operating force and the ability to be used with one hand. Also, be aware that if the trash enclosure or trash chute room has a closer on the door, one would need to make the space within the enclosure larger so one does not get trapped and can exit the space. Many things to consider for our throw-aways.


Be aware that your local City or County may have additional requirements that are more restrictive than the State or Federal requirements. Also, this article is an interpretation and opinion of the writer. It is meant as a summary – current original regulations should always be reviewed when making any decisions.

© Janis Kent, Architect, CASp 2014