Applicability of Interior Finish Requirements to Common Use Toilet Rooms

[John Ogden]

Do the interior finish requirements of section 1209.2.2 apply to a small, common-use bathroom? I suggest not.

Section 1209.2.2 of the '18 IBC requires a smooth, hard, nonabsorbent surface on walls and partitions within 2 feet of a water closet. But it also provides an exception for "toilet rooms that are not accessible to the public and that have not more than one water closet".

This section is not explicit in regards to "Common Use" areas, although I believe it is inferred because Public Use is defined separately. I equate "not accessible to the public" as meaning for anything other than Public Use. A common-use area is by definition not a public-use area.

I also note the Chapter 12 summary provided in the 2009 version of IBC in the chapter Effective Use of the IBC, which included the phrase "to resist water damage.... where water is frequently in use". A Public Use toilet area would would have a very different usage frequency compared to a Common Use one.

From this I conclude that the interior finish requirements of 1209.2.2 do not apply to a wall in a Common Use bathroom with only one water closet.

Does this make sense?

 

[RLGA]

I would agree with that.

 

[cda]

Welcome

That is a long title for your first question

 

[John Ogden]

Thanks for your input.

My client was told by an inspector that he would be required to put FRP on the walls because it was not a private bathroom, an opinion with which I do not agree.

I believe that the inspector is confusing the criteria for Accessibility (Chapter 11) with that of Interior Finishes (Chapter 12).

• The exceptions listed in section 1109.2 include "toilet rooms or bathing rooms accessed only through a private office, not for common or public use and intended for use by a single occupant".
• The exceptions listed in section 1209.2.2 include "toilet rooms that are not accessible to the public and that have not more than one water closet"

 

[ADAguy]

Typically the more restrictive applies, which one is?

 

[RLGA]

Thanks for your input.

My client was told by an inspector that he would be required to put FRP on the walls because it was not a private bathroom, an opinion with which I do not agree.

I believe that the inspector is confusing the criteria for Accessibility (Chapter 11) with that of Interior Finishes (Chapter 12).

• The exceptions listed in section 1109.2 include "toilet rooms or bathing rooms accessed only through a private office, not for common or public use and intended for use by a single occupant".
• The exceptions listed in section 1209.2.2 include "toilet rooms that are not accessible to the public and that have not more than one water closet"

Two separate issues, two separate applications. One is based on the accessibility of the restroom, while the other is based on durability and health issues--totally unrelated.

 

[John Ogden]

The inspector is now saying that the FRP is required because the bathroom must be accessible to the public.

The location is a 1000 sf. section of a strip mall. The space is divided into a front room (where customers might be) and a back room area, where the bathroom is.
There is no intention of leasing this space to a food-service operation. It will likely be a professional service, like real estate or insurance. I am not familiar with a code requirement that says the bathroom must accessible to the public in those circumstances.

thanks

 

[John Ogden]

Found it. Section 403.3 of the Plumbing Code. Less than 300 sf. of public access area would have opened the possibility. We have twice that.

403.3 Required public toilet facilities
Customers, patrons and visitors shall be provided with public toilet facilities in structures and tenant spaces intended for public utilization.....

Exception: Public toilet facilities shall not be required in:

1. Open or enclosed parking garages where there are no parking attendants.
2. Structures and tenant spaces intended for quick transactions, including takeout, pickup and dropoff, having a public access area less than or equal to 300 square feet (28 m2).

 

[ADAguy]

Great catch John! I'll be referring to this in the future.

 

[ADAguy]

1. Except 1, so if I have an attendant taking money in a parking structure I must have a public toilet?

 

[John Ogden]

It looks that way. Another reason the robots are taking over.

 

[RLGA]

Found it. Section 403.3 of the Plumbing Code. Less than 300 sf. of public access area would have opened the possibility. We have twice that.

403.3 Required public toilet facilities
Customers, patrons and visitors shall be provided with public toilet facilities in structures and tenant spaces intended for public utilization.....

Exception: Public toilet facilities shall not be required in:

1. Open or enclosed parking garages where there are no parking attendants.
2. Structures and tenant spaces intended for quick transactions, including takeout, pickup and dropoff, having a public access area less than or equal to 300 square feet (28 m2).

This is also in the IBC, Section 2902.3. The fact that this was the only restroom in the space was critical information to know. Had that been brought up earlier, this requirement would have been mentioned much sooner.

 

[steveray]

My default is provide the finishes or prove otherwise...It is usually required....

 

[ADAguy]

Also more durable and sanitary.

 

[steveray]

Also more durable and sanitary.

Which is the reason it is there...To assist in the ability and decrease the cost to maintain the room in a sanitary condition...

 

[John Ogden]

Thanks to all for the help. Sorry to withhold that critical information!