Tub Height

Back again…. At issue with the multi-family apartment is the height of a tub. Seems the developer installed luxurious soaking tubs with 22″ high by 5″ lips and this poses a potentail fall hazard for the occupant. All I’m seeing in ANSI is that there should be a tub side wall low grab bar 9″ above the tub lip and a high one at 33″ to 36″.