TDLR considers single toilets paths of circulation

[Meadowbend99]

I had a violation on a project for the sink, which is an ADA compatible sink and installed properly in a single restroom.
(Me)
1. (307.2) You noted a violation for a protruding object in the Restroom, showing the wall mounted toilet lavatory. It has been my understanding that this refers to objects within the circulation path. A circulation path is defined as An exterior or interior way of passage from one place to another for pedestrians, typically referring to walks, hallways, courtyards, elevators, platform lifts, ramps, stairways, and landings, which would not include a restroom.

(Inspector)
The full definition of a circulation path per 2012 TAS states:

106.5.19 Circulation Path. An exterior or interior way of passage provided for pedestrian travel, including but not limited to, walks, hallways, courtyards, elevators, platform lifts, ramps, stairways, and landings.

Our office has previously submitted numerous questions to TDLR technical information, the state agency that enforces the 2012 TAS, concerning this issue and the response has been the same. The path from the water closet to the lavatory in a restroom is considered a circulation path and if the bottom leading edge of the lavatory is mounted above 27” it is a protruding object for the visually impaired. The words “including but not limited to” in the definition of a circulation path would include the path from the water closet to the lavatory in a restroom.


If you've come across this before what are you advising your clients to do? Lower the lavatory so that the bottom of the bowl is at 27"? Install a skirt around it?

 

[ADAguy]

This is a combination of performance and minimum prescriptive guidelines for you to design by.
Run into this all the time.

 

[steveray]

Does the part of the lav that is above 27" high stick out 4"?

I guess it has to be 8" at 27"...It can never comply for forward approach...

 

[ADAguy]

look at the ADA section through a lav, the 27" with a sloping knee space beneath allows a wheelchair to pull beneath and rotate through the knee space.
At issue would be the lavs adjacency at corners where a cane detectable end panel or curb would be required to detect the projection.

 

[Sleepy]

None of those items listed as part of a Circulation Path sound like anything within any room, it all sounds like how pedestrians get to the room. Contrast that with the discussion on Accessible routes (206.2.4) which does include the path to individual Elements, such as toilets and lavatories. So I would argue that the space within a toilet room is not part of a Circulation Path but is a part of an Accessible route and thus the protruding object rule does not apply to the lavatory itself.

 

[Francis Vineyard]

If you've come across this before what are you advising your clients to do? Lower the lavatory so that the bottom of the bowl is at 27"? Install a skirt around it?

"So in California, if you can approach the side of the lavatory you will most likely always have a protruding object and a cane detectable barrier is needed. This can be as simple as providing a side piece to the counter where the leading edge goes down to 27”or less AFF. But keep in mind, this side piece might need to provide 18” minimum clear from the centerline of the lavatory in California if it goes below 27” AFF."

https://steppingthruaccessibility.com/the-lavatory/#.Wvwr5Ygvzcs

 

[JPohling]

I would never consider the wall mounted lav in a single occupancy toilet room a protruding object. Sorry just not buying it.

 

[steveray]

I would never consider the wall mounted lav in a single occupancy toilet room a protruding object. Sorry just not buying it.

Maybe if you are running real fast from the lav to toilet? Or vise versa?

 

[georgia plans exam]

This is more than ridiculous. What do they expect you to do? I have never seen a curb or an end panel or anything like it installed at a lavatory in an accessible restroom. Maybe I am crazy but, I think that the idea behind the 4" projection rule is so that a person who uses a cane or otherwise hugs the wall to navigate themselves does not get an unpleasant surprise by running into an object along the way (circulation path). It would be no surprise and would be expected to find a protrusion, such as a lavatory, in a restroom. I'm with JP on this, not buying it. GPE.