Feminine hygiene units are among the last things to get specified in an accessible toilet room and among the first things an inspector flags. The dispenser and the disposal receptacle each carry their own governing dimensions, and a unit that clears the reach range can still fail on protrusion or clear floor space.

This guide gives you the exact heights, clearances, and citations to move straight into drawings, plus where to pull dimensionally accurate specification dispensers and Revit/CAD assets. It covers the 2010 ADA Standards, where ICC A117.1 and state amendments diverge, and the placement geometry that causes most real-world failures.

ADA Spec Requirements for Hygiene Units

Two element types govern this work, and they are not interchangeable. The dispenser is an operable part: a vend lever, push button, or coin slot the user activates. The disposal receptacle is a fixture with a deposit opening. Each is governed by a different section of the standard.

That distinction drives every mounting decision downstream. A dispenser answers to reach range and operability rules. A receptacle answers to placement, clearance-overlap, and deposit-opening rules. Treat them as one problem and you will mis-spec one of them.

The recurring failure mode is predictable. Units get treated as a punch-list afterthought, mounted by whatever height the cabinet top suggests, then flagged at inspection. Front-loading the constraints at the design phase is the cheaper path.

Which Codes Actually Govern Placement

Three layers of authority apply, and they stack. The 2010 ADA Standards for Accessible Design are the federal baseline. ICC A117.1, referenced by the International Building Code (IBC), is the building-code path most projects are actually enforced through. State and local amendments sit on top of both.

Searching “ada bathroom requirements” alone gives you an incomplete picture. The ADA is civil rights law, not a building code, and most projects clear inspection against the locally adopted code edition rather than the federal standard directly. The U.S. Access Board maintains the federal text, but your jurisdiction decides what gets enforced.

The highest-impact state overlay is California Title 24 (CBC Chapter 11B), which carries stricter obstruction and placement rules than the federal baseline. Treat this section as orientation. The dimensions come next.

When State Amendments Override the Federal Baseline

California is the clearest example. CBC 11B-604.7 fixes the disposal opening at 19 inches minimum above the finished floor and dictates a sidewall position the federal standard leaves open. A spec drawn to the 2010 ADA alone can be noncompliant in California.

California is not necessarily unique. Some states adopt their own accessibility provisions or a building-code edition that can be stricter than the federal text on a given dimension, while others adopt codes certified as equivalent to the 2010 ADA. The point for specifiers is that equivalence is not guaranteed, so a mounting height locked from the federal standard alone can still miss a local requirement.

The practical takeaway for specifiers is fixed: pull the locally adopted code edition before you commit a single mounting height to the drawing set. The federal number is the floor, not the answer.

Mounting Heights and Reach Ranges (§308)

This is the heart of the spec. The operable-part rule governs dispensers, and it is measured to the part the user touches: the vend lever, coin slot, or push button. Not the cabinet top. Not the bottom of the unit.

For an unobstructed approach, that operable part must fall within the reach range: 15 inches minimum and 48 inches maximum above the finished floor. The phrase that recurs across the code and every authoritative source is worth committing to memory: no higher than 48 inches and no lower than 15 inches above the finished floor.

Section 309.3 places the operable part within the §308 reach ranges, and §309.4 governs how it must operate. The measurement point is the mechanism the user touches, every time.

Obstructed vs. Unobstructed Reach

Reach range tightens when something sits in front of the unit. For an obstructed high forward reach, the maximum drops to 48 inches where the reach depth is 20 inches or less, then to 44 inches where depth runs between 20 and 25 inches.

Obstructed high side reach follows its own steps. The maximum holds at 48 inches for a depth of 10 inches or less, drops to 46 inches for depth up to 24 inches, and the obstruction itself must be no higher than 34 inches.

This is where partition-mounted and recessed units behind a lavatory deck or shelf get mis-specified. A 48-inch centerline drawn without accounting for the counter or grab bar in front of it is a common and avoidable error.

Dispensers vs. Disposal Receptacles: Different Rules

A dispenser is an operable part. It answers to the §308 reach range and the §309 operability rules: no tight grasping, pinching, or twisting, and no more than 5 pounds of force to activate. A coin mechanism complicates both, since the slot can sit above the reach range and the coin action can demand a grasp-and-twist motion an inspector will flag.

A free-vend dispenser removes that complication at the source. With no coin slot, there is no grasp-and-twist motion and no slot to push above the reach range. The SD8000 courtesy dispenser is one example of a free-vend design that sidesteps the §309 operability questions a coin unit raises. GGI’s broader line of prefilled feminine care dispensers works the same way.

The disposal receptacle is governed differently. Its deposit opening is positioned for accessibility, commonly at 19 inches minimum above the finished floor where state code specifies, as in the California provision above. The feminine care dispenser collection and sanitary napkin disposal receptacles split along exactly this element-type line.

Clear Floor Space and Clearance Overlap (§604)

Placement geometry is where most real failures happen. 

The required water closet clearance is 60 inches wide and 56 inches deep minimum under the 2010 ADA Standards (§604.3.1). The building-code path (ICC A117.1, and CBC 11B-604.8.1.1 in California) splits the depth further: 56 inches for a wall-hung bowl and 59 inches for a floor-mounted bowl. It must stay unobstructed.

Section 604.3.2 names the only elements permitted to overlap that clearance: grab bars, the toilet paper dispenser, a seat-cover dispenser, coat hooks, shelves, and sanitary napkin disposal units. The list is short and specific.

The implication for your drawing is direct. A wall-mounted napkin disposal unit is explicitly allowed to overlap the water closet clearance. A freestanding floor receptacle that intrudes on that clear floor space is not, and a unit that earns its place on the §604.3.2 list is the cleaner spec.

Sidewall Positioning Relative to the Toilet Paper Dispenser

The disposal unit belongs on the sidewall, in the zone between the rear wall and the toilet paper dispenser, adjacent to the TP dispenser. That keeps it within reach from the water closet without crowding the transfer space.

Coordinate it with the TP dispenser, which sits 7 to 9 inches in front of the bowl to its centerline, with its outlet at 19 inches AFF or higher, and clear of the grab bars. Stack the disposal opening, the TP dispenser, and the grab bar in your elevation so none of the three conflicts in the reach zone.

Mounting type changes the trade-off. A partition-mounted unit can serve two compartments but must be verified from the accessible side specifically. A wall-mounted unit is simpler to position against the sidewall zone.

Turning Space and Protruding Objects

The 60-inch turning circle, or a T-shaped turn, has to remain clear. Surface-mounted units that project into the room can violate the §307 protruding-object limit: no more than 4 inches of projection for anything mounted between 27 and 80 inches above the finished floor.

In a tight single-user room, that constraint is why recessed or semi-recessed units are often the cleaner spec. They keep the projection out of both the turning space and the protruding-object zone.

Surface-Mounted, Recessed, and Partition-Mounted Options

Each mounting type trades against the clearances above. The right choice depends on wall depth, room size, and how much clear floor space you have to protect.

• Surface-mounted is the easiest retrofit, but it has to clear the §307 4-inch protrusion limit and stay out of the water closet clearance. The stainless steel ND-1E receptacle is a representative surface-mounted disposal unit for spec language on deposit-opening height and cabinet gauge.

• Recessed is the strongest option for tight clearances and turning space, since it pulls the unit out of the projection zone. It requires wall depth and blocking coordination at the design phase, not after.

• Partition-mounted units can serve two stalls through a dual-access body. Verify reach and operability from the accessible compartment, since that is the side the standard cares about.

For spec language, the durability details belong on the cut sheet: steel gauge, lock type, and capacity. A typical unit might read as 22-gauge steel with a keyed cabinet, which is the kind of dimensioned detail a submittal needs rather than a product claim.

Writing the Spec: Cut Sheets, Submittals, Revit/CAD

Translate the dimensional rules into specification-ready language. The spec should capture mounting type, operable-part height, deposit-opening height, finish and gauge, free-vend versus coin operation, and an ADA compliance statement tied to the adopted code edition.

Your submittal checklist is short: a cut sheet with a dimensioned elevation, the mounting height called to the operable part, and a clearance diagram showing the unit against the §604 water closet space. Those three documents answer most reviewer questions before they are asked.

Dimensionally accurate manufacturer families reduce coordination errors that generic blocks introduce. GGI’s Specifications & Revit Files page hosts downloadable PDF spec sheets across the dispenser line (SD2000 through SD9000) and the TD1000 and TD9200 disposal receptacles, plus a request form for Revit (RFA), CAD (DWG), and spec files. That page, not scattered product listings, is where the BIM assets live.

Common Compliance Failures and How to Avoid Them

Most failures trace back to a handful of mistakes, each with a corrective dimension already covered above.

• Operable part spec’d above 48 inches because the cabinet top was used as the reference instead of the vend mechanism. Measure to the part the user touches.

• Floor-standing receptacle intruding on the 60-inch turning space or the water closet clearance. Choose a wall- or partition-mounted unit that the §604.3.2 list permits to overlap.

• Disposal opening below 19 inches or positioned outside the rear-wall-to-TP-dispenser zone. Hold the opening at the state-specified minimum and keep it on the sidewall.

• Coin-operated dispenser creating a grasp-and-twist or above-reach operability concern. A free-vend unit removes the issue.

• State amendment overlooked because only the federal ADA was referenced. Confirm the locally adopted edition, Title 24 especially, before locking heights.

For the mounting-type trade-offs behind several of these, the breakdown in wall-mounted versus free-standing receptacles maps onto the clearance-intrusion point directly. The accessibility-standards detail in menstrual product dispensers: types, features, accessibility standards goes deeper on the dispenser side.

The Dimensions That Decide the Spec

The spec comes down to a few numbers and one habit. Measure the dispenser to its operable part and hold it between 15 and 48 inches. Keep the deposit opening at the state-specified minimum, commonly 19 inches. Protect the 60-inch turning circle and the water closet clearance, and keep surface-mounted projection under 4 inches in the 27-to-80-inch band.

The habit is checking the locally adopted code edition before any of those numbers go final. The federal standard sets the floor; Title 24 and other state amendments set what actually gets inspected. Draw to the stricter of the two and the punch-list flag never happens.