Accessible Dining Surfaces on US Restaurant and Hotel Projects: What Sections 226 and 902 of the 2010 ADA Standards Say About Tables, Bars and Counters
The share, the dispersion, the height and the clearance under the top, read from the text of the 2010 ADA Standards
When a restaurant, café or hotel dining room is fitted out in the United States, the table schedule is not only a list of shapes and finishes. A share of the dining surfaces has to meet accessibility requirements for height and for the space under the top, and those requirements are written into the 2010 ADA Standards for Accessible Design, published by the Department of Justice.
This article reads sections 226 and 902 of those Standards, and the two building-block sections they call, 305 and 306, for an FF&E contractor or project buyer who is specifying tables, bar tops and booths. FBM Furniture works with companies only: Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers. It sets out what the text says. It does not say whether a particular table complies, and it is not legal advice; the project designer decides which standards and which edition apply and how many accessible surfaces the plan needs.
What the Standards are, and what they are not
The Department of Justice overview that opens the 2010 Standards says they set minimum requirements, both scoping and technical, for newly designed and constructed or altered State and local government facilities, public accommodations and commercial facilities to be readily accessible to and usable by individuals with disabilities. Scoping says how many of an element a facility must provide and where; the technical sections say what an element must measure.
That framing matters for furniture. The Standards describe the facility and its elements. They do not certify a product, and the share and the placement are set for the space, not for a single table. The same point is made on our page for office storage and lockers: a catalogue label reading “ADA compliant” does not establish what a particular project needs.
Section 226: how many dining surfaces
Section 226.1 says that where dining surfaces are provided for the consumption of food or drink, at least 5 percent of the seating spaces and standing spaces at the dining surfaces shall comply with section 902. It adds that where work surfaces are provided for use by other than employees, at least 5 percent shall comply with 902 as well.
Two exceptions follow. Sales counters and service counters are not required to comply with 902; they are addressed in section 904.4, which our companion article on reception and service counters reads. Check writing surfaces provided at check-out aisles that are not required to comply with 904.3 are also not required to comply with 902.
The advisory to 226.1 adds that, in facilities covered by the ADA, the requirement does not apply to work surfaces used only by employees, and that employers may need to procure or adjust work stations on an as-needed basis. Section 226.2 requires the dining surfaces and work surfaces that comply with 902 to be dispersed throughout the space or facility containing dining surfaces and work surfaces. The text sets the share and the dispersion. It does not give the designer a rounding rule in these two sections, so the count on a given plan is the designer’s to settle.
Which furniture counts as a dining surface
The advisory to 902.1 says that dining surfaces include, but are not limited to, bars, tables, lunch counters and booths. On a hospitality schedule that can reach several line items, not only the loose dining table: bar tops, lunch counters and booth tables are all named in the advisory. The advisory also lists examples of work surfaces, including writing surfaces, study carrels and student laboratory stations.
The line item matters because the requirement is counted at the seating spaces and standing spaces. A restaurant with a bar and a dining room has dining surfaces of different types, and the schedule needs to show which line is which, at which outlet, with what quantity, so that the designer can count against the plan. Our page on restaurant and café tables sets out the schedule fields that let a maker price each table type from one code, with the quantity per outlet or area.
Section 902: what an accessible surface must measure
Section 902.1 says dining surfaces and work surfaces shall comply with 902.2 and 902.3. The table below sets out what those two sections require, together with the figures in 305 and 306 that 902.2 calls.
| Requirement | Section | What the text says |
|---|---|---|
| Clear floor space | §902.2, §305.3 | A clear floor space complying with §305, positioned for a forward approach. §305.3 sets the size at 30 inches (760 mm) minimum by 48 inches (1220 mm) minimum. |
| Toe clearance | §902.2, §306.2 | Knee and toe clearance complying with §306. Space between the floor and 9 inches (230 mm) above it is toe clearance, 25 inches (635 mm) maximum in depth, 17 inches (430 mm) minimum in depth where it is required as part of a clear floor space, and 30 inches (760 mm) wide minimum. |
| Knee clearance | §902.2, §306.3 | Space between 9 inches (230 mm) and 27 inches (685 mm) above the floor is knee clearance, 25 inches (635 mm) maximum in depth at 9 inches. Where required, it is 11 inches (280 mm) deep minimum at 9 inches above the floor and 8 inches (205 mm) deep minimum at 27 inches above the floor. Between those heights it may reduce at 1 inch (25 mm) of depth for each 6 inches (150 mm) of height. It is 30 inches (760 mm) wide minimum. |
| Height of the top | §902.3 | The tops of dining surfaces and work surfaces are 28 inches (710 mm) minimum and 34 inches (865 mm) maximum above the finish floor or ground. |
Section 305.4 adds that, unless otherwise specified, clear floor space is permitted to include knee and toe clearance complying with 306. The toe clearance section also says that space extending more than 6 inches (150 mm) beyond the available knee clearance at 9 inches above the floor is not considered toe clearance. These are measurements of the empty volume under the top, which is set by the top’s thickness and by the apron, base or legs below it. They are read on the finished item, not on the top alone.
Specifying tables for a US project?
Send your table schedule, outlet layouts and project location. Our team will review them and get back to you.
Children’s dining surfaces
Section 902.1 permits dining surfaces and work surfaces for children’s use to comply with 902.4 instead. Section 902.4 sets a top height of 26 inches (660 mm) minimum and 30 inches (760 mm) maximum above the finish floor, with a clear floor space positioned for a forward approach, and it permits knee clearance 24 inches (610 mm) minimum above the finish floor. An exception says that dining surfaces and work surfaces used primarily by children 5 years and younger are not required to comply with 902.4 where a clear floor space complying with 305 is provided for a parallel approach.
A project that includes a children’s dining area, such as a family restaurant or a hotel kids’ club, can therefore carry two sets of measurements on its schedule. They are separate lines with separate codes.
What to put on a table schedule line
Because the figures are measurements of the finished item in place, they belong on the drawing and on the schedule line, in the buyer’s words, and not only in a product description. For each table, bar top or booth table type, consider recording:
- Item code and outlet. One code per type, with the quantity per outlet, area or phase, so that the designer can count surfaces against the plan.
- Top height. The height from the finish floor to the top, as drawn, with the tolerance the project allows.
- Space under the top. The clear depth and width at the knee and toe levels, drawn on the section, including the apron and the base or legs.
- Base type and fixing. Whether the item is freestanding or fixed, because the position of a fixed item is set on the plan.
- Which surfaces the designer has designated as accessible. Put the designation on the schedule, so the maker prices the designated lines to the stated measurements.
- Top material and thickness. The thickness affects the space under the top, so it belongs beside the height. Our page on table tops for commercial furniture covers specifying marble, sintered stone and laminate for use.
When a maker returns a sample or a drawing for approval, check the stated measurements against the schedule. Our note on inspection by product group describes how tables are checked on their tops, dimensions and bases, and why seating, tables and upholstery have different points on the schedule.
Questions for the project designer
- Which edition of the accessibility standards does this project follow, and does section 226 apply to this facility?
- How many seating spaces and standing spaces does each outlet have at dining surfaces, and how many surfaces does the plan designate?
- Which item codes on the schedule are the designated surfaces, and where are they on the plan?
- Are there children’s dining surfaces, and are they on separate codes?
- Do any bar tops, lunch counters or booth tables need the same treatment as loose tables?
- For fixed items, do the drawn height and the space under the top match the section drawing?
FBM Sourcing’s note on ADA compliance for hotel FF&E and bathrooms covers ADA specification points for hotel FF&E and bathrooms, and our page on commercial furniture compliance for the United States sets out United States rules relevant to commercial furniture.
Source and date
This article reads the 2010 ADA Standards for Accessible Design, Department of Justice, September 15, 2010, as published on ADA.gov (PDF), sections 226, 305, 306 and 902, read on 21 October 2026. Standards and their adoption by authorities can change; check the edition your project follows with the project designer.
Frequently asked questions
How many dining surfaces must be accessible under the 2010 ADA Standards?
Section 226.1 says at least 5 percent of the seating spaces and standing spaces at the dining surfaces shall comply with section 902, and section 226.2 says they shall be dispersed throughout the space or facility. The project designer counts against the plan.
What height must an accessible dining surface be?
Section 902.3 says the tops of dining surfaces and work surfaces shall be 28 inches (710 mm) minimum and 34 inches (865 mm) maximum above the finish floor or ground. Dining surfaces for children’s use may follow section 902.4, which sets 26 to 30 inches (660 to 760 mm).
What space is needed under the table?
Section 902.2 calls for a clear floor space positioned for a forward approach and for knee and toe clearance complying with section 306. Section 305.3 sets the clear floor space at 30 by 48 inches (760 by 1220 mm) minimum. Section 306 sets the knee and toe clearance depths and a minimum width of 30 inches (760 mm).
Do bar tops, lunch counters and booths count as dining surfaces?
The advisory to section 902.1 says dining surfaces include, but are not limited to, bars, tables, lunch counters and booths. Sales counters and service counters are excepted from section 902 by section 226.1 and are addressed in section 904.4.
Does a product label that says ADA compliant settle the requirement?
No. The Standards set scoping and technical requirements for a facility and its elements. How many dining surfaces a plan needs, and which items are designated, is settled on the plan by the project designer.
How does FBM Furniture charge?
For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and your team is welcome to attend.
Specifying tables for a US project?
Send your table schedule, outlet layouts and project location. Our team will review them and get back to you.