Start with the ADA fundamentals that most often trip dispensers

Reach ranges (and the “over-obstruction” trap)

If the dispenser’s user-operable portion (sensor activation zone, button, or push area) is out of reach, it’s a problem even if the unit “fits” the wall.

Key reach-range basics (2010 ADA Standards):

• Unobstructed forward reach: 15" min to 48" max AFF
• Forward reach over an obstruction (like a counter): the allowable max height drops based on reach depth (commonly down to 44" max once the reach depth exceeds 20").

Practical AEC takeaway: if the dispenser is mounted near or over a deep vanity or behind a counter edge, don’t assume 48" AFF works—dimension the reach depth in elevation or section, not just the mounting height.

Operability (if any manual action is required)

If your selection includes a manual button/lever (or any user-actuated control), operable parts must:

• be usable with one hand
• require no tight grasping, pinching, or twisting
• require ≤ 5 lbf to activate

Touchless designs reduce—but don’t eliminate—risk. The “operable portion” still needs to be within reach range and usable for the intended approach.

Protruding objects: the dispenser can’t become a cane-detectability hazard

Wall-mounted dispensers often project more than you’d expect. ADA protruding object limits apply when the leading edge is:

• more than 27" and not more than 80" AFF, and
• located along a circulation path

In that band, projection is limited to 4" max into the circulation path.

Design strategies that actually work:

• Recessed alcoves sized so clear floor space isn’t compromised
• Side panels or wing walls with a bottom edge at 27" max to make the hazard cane-detectable
• Relocate dispensers off the “shoreline” path where users with vision impairments travel close to walls

Placement coordination: dispensers must not steal required clearances

Dispensers can accidentally reduce:

• door maneuvering clearances
• approach space to lavatories
• circulation width within tight multi-stall restrooms

Two coordination rules help prevent problems:

• Dimension the dispenser zone as part of the lavatory or accessory elevation (not “by field”).
• Coordinate the full accessory set (soap + faucet + towel + dryer + mirror) so the dispenser is reachable without forcing an awkward approach.

This is where “coordinated sets” (touchless faucet + soap) can simplify layout coordination—because the sensor logic and typical mounting intent are designed to work together.

Specifier checklist: what to require in submittals (so the install matches intent)

Include these items in your submittal review + install details:

• Mounting height (AFF) to the operable portion (not just the top of the housing)
• Approach type assumed (forward vs side) and whether a counter obstruction exists (reach depth dimensioned)
• Projection dimension (wall to leading edge) and whether the unit sits on a circulation path (4" protrusion rule)
• If manual: activation force and confirmation of compliant operability (≤ 5 lbf, no twisting/pinching)
• Service access plan (refill/battery access without removing the dispenser and without disturbing compliant clearances)

Note: items used only by service or maintenance personnel are treated differently than occupant-operable parts. Don’t let a service lock become the “operable part” for users.

Renovations and retrofits: common failure modes (and how to avoid them)

The “new dispenser, old vanity” mismatch

A retrofit often fails reach compliance because:

• vanity depth increased,
• backsplash geometry changed, or
• the dispenser moved behind the faucet zone.

Solution: in retrofit drawings, add a simple reach-depth diagram and call out the maximum allowed mounting height for that reach condition, not a generic 48" AFF note.

Protrusion surprises in tight rooms

Even if the dispenser is “inside the restroom,” it may still sit on a circulation path. If it projects too far, it can violate protruding object limits.

Solution: specify recessed or shielded mounting when corridor-like circulation exists, or shift the dispenser to a location where it does not reduce route width.

Commissioning and O&M: “compliant” also has to be maintainable

Accessibility isn’t just about initial placement. A dispenser that constantly drips, false-triggers, or requires removal for refills becomes an operational issue that can lead to “field fixes” that break compliance.

Commissioning checks facility teams should require:

• Confirm operable portion height (AFF) after finishes are complete
• Verify reach usability from the real approach (not a theoretical one)
• Verify no protrusion hazard in circulation zone (measure projection)
• Verify refill/battery access without moving the unit